The FAA’s refusal to acknowledge reality rears its ugly head in Advisory Circular 120-76B, Guidelines for the Certification, Airworthiness, and Operational Use of Portable Electronic Flight Bags. In this AC, the FAA—in a standalone bold-type note, warns users of portable devices that display charts and moving maps that “Class 1 or Class 2 EFBs must not display own-ship position while in flight.”
In other words, the FAA, in its infinite wisdom, does not want you to use an Apple iPad or Android device with moving-map software and the computer’s internal or an external GPS receiver to verify your aircraft’s position. If, for example, you are flying near the edge of Class B airspace without a clearance into that airspace, the FAA would rather that you avoid that airspace boundary using a chart and the view of the ground to fix your position. Or, if you can’t see the ground, then perhaps a slightly more accurate VOR cross-check, if that’s the only navigation equipment available. Preferably, of course, your airplane has its own certified and accurate Waas-capable GPS receiver and a built-in certified moving-map, but not all aircraft are so equipped.
Never mind the fact that the uncertified GPS-driven moving map on the iPad is far more accurate than many navigation sources. The FAA’s feeling is that if pilots were to rely on the iPad’s or an external uncertified GPS, they would be straying into special-use airspace (SUA) all the time.
This is backwards thinking.
First of all, ever since iPad moving maps began using GPS to show own-ship position, pilots have been using them to navigate and to avoid SUA. There is a high probability that devices such as these have prevented many cases of improper SUA penetration.
Second, the UK’s own air traffic control service providers, Nats, as far back as 2009, endorsed the use of a portable non-certified GPS device to help pilots avoid SUA. Nats and Airbox Aerospace collaborated on the original Aware airspace alerting and positional awareness device, and now that functionality is offered in an iPad/iPhone app.
When the Aware system was launched in 2009, Nats director of safety Gretchen Burrett said, “Infringements into controlled airspace are a serious safety concern for private and commercial pilots. In the complex airspace over the UK, it is imperative that all aircraft respect airspace boundaries so we can all share the sky safely. By keeping pilots conscious of nearby airspace boundaries as they fly, Aware helps pilots to steer clear of accidental infringements. Nats is proud to have been involved with this project, which we believe will be a major asset for airspace safety.”
U.S. pilots, especially those flying business jets and using iPads, worry that they will be penalized if they are caught using own-ship position information on their mobile devices. And in fact, all the moving-map iPad apps now have a software switch to turn off own-ship position display. This seems to be something that iPad app developers inserted as a means of gaining approval for use in airline and charter company cockpits. Some pilots carefully turn off own-ship display after landing.
AC 120-76B is an advisory circular and hence only advisory in nature. ACs are not regulatory, although they may reference regulations. In the case of own-ship position display, it seems that while the FAA recommends against use of this excellent feature, there is no regulation prohibiting its use (unless part of a commercial operators’ OpSpecs). Of course, own-ship display on a non-certified device should be used with caution and as a backup to other more precise techniques. But, because there is no regulation that tells pilots what they can use to determine their position when lacking any technological system besides their Mark 1 eyeballs, then there is no reason why an iPad app with a suitable GPS source can’t aid that purpose.
Can you think of any controlled-flight-into-terrain accidents when an iPad with own-ship and also terrain/obstacle display might not have helped the pilots?
The FAA needs to get real and maybe even consult with the folks at Nats. Own-ship display on non-certified devices is here to stay, pilots of all stripes are using it and such a display offers a clear and compelling safety benefit.