Paper vs. Plastic

International Operations Manual

Eddie sez:

Note: What follows is more of a history lesson than anything else. We've made a lot of progress on how to go "paperless" and if you want an update to the oceanic method, see: Paperless Oceanic.

I think I am high tech, no doubt about it. I program in C. I write the HTML for this website in raw code. Even my motorcycle has throttle-by-wire. This carries through to the airplane where we've issued every pilot a fully loaded iPad Pro and have paid for a full suite of iPad applications. But I had a very hard time giving up my paper plotting chart.

But I have, in fact, done just that. But it was the months-long process of writing this article that gave me that final push.

What follows comes from a series of flights where we made the move from paper to paperless, from paper to plastic. Some of our first attempts were laughable, but there isn't a lot out there on how to do this. So perhaps you can bypass our missteps and go right to something that works. You might be wondering about the legality of doing anything on an iPad in a high-tech cockpit. That is a concern, I hope that I have answered that question here: Portable Electronic Devices.

We've settled on a several iPad applications, most notably ARINCDirect, Jeppesen Flight Deck (also known as JeppFD), and Garmin Pilot. There are other helpful applications, also covered below. There isn't yet a purpose built application for oceanic plotting, so none of these are as good as we like. But they are good enough for going paperless now.

Oh yes, I have to acknowledge that using an iPad isn't always the best solution: iPad vs Paper.

Everything here is from the references shown below, with a few comments in an alternate color.


Photo: Paper vs. iPad, from Eddie's planning table.

But before we ditch all our paper, what must we carry in paper form? As far as I can tell:

  • Aircraft registraion.

  • Certificate of Airworthiness.

  • Pilot's license.

  • Pilot's medical certificate.

  • Mexican insurance and Mexican annual multiple entry permit (if applicable to your operation). That brings up the point that if you do have special permits and insurance for specific countries, you should check for their paper requirements.

Last revision:


Cover Story:


A Summary


If you don't have the electronic means, you will need to print the following:


Photo: Paper, from Eddie's planning table.

Plastic (iPad)

You might have a better solution, but here is our path to paperless oceanic operations:


Photo: iPad, from Eddie's planning table.

Master Document


  • Master Document — You will need to have a copy of your flight plan printed and annotated as the "Master Document."

Plastic (iPad)

  • Master Document — The ARINCDirect iPad application will automatically place a flight plan in the format of your choice under the "Flight Plan" tab. You can annotate it with "Master Document" and the necessary recordings right onto this copy, archiving everything when you are done.
  • ARINCDirect — If you use Rockwell-Collins ARINCDirect, this App will be your favorite tool. It provides an easy way to manage and view your flight plans, weather, NOTAMs, aircraft performance, and charts. It may be the closest thing to "one stop shopping" for paperless operations. There are other options, such as those from ForeFlight and Universal, but they pale by comparison.

Oceanic Checklist


  • Oceanic Checklist and RVSM/NAV Performance Log — This checklist makes sure we don't forget the important stuff and it gives us a place to record many of the things we are supposed to record. We've added all of the steps to our Master Document so we no longer need this as a separate piece of paper.

Plastic (iPad)

GoodReader — If you are going to use a document outside your normal flight planning application you are probably going to be dealing with a PDF file. The ARINCDirect application can read a PDF and allow some typing, but GoodReader is better.



  • Equal Time Points — We have these ETPs computed for us with the flight plan. Over the North Atlantic you will usually get three each for three city pairs for a total of nine. You will get an engine-out ETP which considers the loss of an engine. You will also get a depressurization ETP which considers keeping both engines but having to descend to an altitude where oxygen masks are not needed. Finally, you will get an ETP that allows you to stay at altitude with both engines but just have to turn around, typically called a "Medical ETP." I pick the middle of these three and plot one ETP per city pair.

Plastic (iPad)

  • Equal Time Points — Even if I plan on plotting electronically I'll print out the ETP summary because it is just too much of a pain to flip between iPad pages to find the correct of the three types of each ETP and then to the plotting chart while memorizing the type of ETP, the city pair, and the coordinates.
  • Dissenting view: one of our pilots prefers no paper and simply does a cut and paste to eventually get the ETPs entered. (I think this takes too long.)

Track Message


  • Track Message — To fly over the North Atlantic High Level Airspace (formerly called MNPSA), you will need the track message, even if you are nowhere near the tracks. So you have to have it on the airplane and this typically means you have to print it out.

Plastic (iPad)

  • Track Message — If you have the current track message on your iPad you are good to go.

Data Link Checklist



  • Weather — I have to admit I felt silly about this one. The airplane provides us with so much current weather but after almost four decades of having to have printed weather, continued to do so for many years. But no longer.

Plastic (iPad)

  • Weather — The iPad really shines here, especially if you have a broad band Internet connection. See iPad Applications for some of our favorites.



  • NOTAMS — I have hated NOTAMs for as long as I've been flying. My technique was to survive by: (1) printing them out, (2) scanning for key words like "closed," and (3) using a highlighter to make it easier to ensure your eyes only target the important stuff.

Plastic (iPad)

  • NOTAMS — Here again the iPad really shines, especially if you have a broad band Internet connection. See iPad Applications for some of our favorites.

Plotting Charts


  • A "Plotting Chart" — If you buy these in bulk, Jeppesen will sell you a plotting chart for $6.00. We used to buy them by the case. There are versions you can download, but they are not easy to print.

Plastic (iPad)

  • A "Plotting Chart" — There are electronic methods which I'll cover below.

Filling Out the Master Document



Photo: Paper master document, front page

One of the nice things about a paper master document is the fact you can write something on it, the clearance for example, and be done with it. Then when you look back on it, maybe weeks or years later, you can remind yourself that you have been meaning to improve your handwriting. But it is very quick.


Photo: Paper master document, oceanic page

With the oceanic legs of the master document you also have the ability to get things recorded very quickly and have a sense of history about the whole thing. But you might have to work at getting everything in there that needs to be recorded neatly.

Plastic (iPad)


Photo: iPad master document, front page, paper

If you are transposing from a data link clearance, retyping onto the iPad is certainly neater and easier to read after the fact. If, on the other hand, you are recording from a clearance given over the radio, this could mean an extra step having to write the clearance on a notepad first.


Photo: iPad master document, oceanic page, paper

I noticed that the iPad user for our example trip was able to keep himself occupied with his typing chores and perhaps that is an advantage to using the iPad.

Oceanic Checklist / RVSM/NAV Performance Log



Photo: Oceanic checklist and RVSM/Nav performance log example, paper.

Perhaps my favorite thing about paper checklists is that they hang around until completed. Having that piece of paper on your clipboard reminds you that things are left undone. We have now given up the practice of recording IRS performance at the end of a flight because our hybrid IRSs do that automatically.

Plastic (iPad)


Photo: Oceanic checklist and RVSM/Nav performance log example, iPad.

Our iPad version of this checklist is the same as the paper version and entries can be made by drawing, such as the check marks, or by typing. Here again the iPad version can be neater and offers better archival options. But once again it takes a little longer.

We have since weaved this checklist into our master document. So even in our quest to rid ourselves of paper, we managed to reduce the total number of documents too.

Plotting Chart


Oceanic Plotting Chart (Paper)


Photo: Completed oceanic plotting chart example, paper. (Click image for full size)

A paper plotting chart is easier and, for now, faster. In the example plotting chart all of the North Atlantic Track system was north of our position and I only plotted the "A" and "F" tracks so as to remind myself where I needed to avoid track altitudes if diverting north. I plotted ETPs for CYYT-EINN, CYYT-LPAZ, and LPAZ-EINN. (In each case the engine out, medical, and pressurization ETPs were all within 100 nm of each other.) I think the entire exercise took all of five minutes. The magnetic variation appears on the chart, but is a bit hard to read, so I transfered those to lower in the chart. (Of course the magnetic variation changes so these values were off by a degree or two in some cases.)

I also added my 2-degree check positions. I did so using the Cross-Points function of my FMS and each addition took all of 30 seconds.

Plastic (iPad)


Photo: Completed oceanic plotting chart example, iPad. (Click image for full size)

We first tried a plotting chart that can be downloaded earlier on the day of the flight so as to have the current tracks already drawn. Entering the aircraft's route was easy enough, but finding the magnetic course and distances were a bit more difficult than with the paper version. (More on that to come.) The pilot elected to enter each ETP and the PNR. This chart does not include magnetic variation, so the the pilot referenced those off the FMS, which means they were more current than with the paper version.

We have since given up on downloading a PDF chart in favor of using the chart from JeppFD with a little help from Garmin Pilot. But more on that below.

The Plotting Process (Course)

The Plotting Process: Finding True/Magnetic Course



Photo: Paper plotting

I won't go into the mechanics of plotting on paper here. For that, you can see: Plotting. But I will summarize those steps here to provide a contrast with plotting on the iPad.

Plastic (iPad)


Photo: iPad plotting

The plotting process on the iPad is the same, but the steps needed are quite different. If you know how to plot on paper, you just need to learn how to draw, measure courses, and measure distances on the iPad.

Course Measuring



Photo: Paper course measuring

Determining a true course is simply a matter of reading off a carefully placed plotter: Plotting / True Course. You will also need to determine a magnetic course and that is done by adding or subtracting the magnetic variation given on the chart.

Plastic (iPad)

Our first attempt:


Photo: iPad course measuring

If a plastic plotter works on paper, why not on an iPad? You can do it, but it requires some practice. You need to increase the scale until usable, and then carefully place a plastic plotter over the course line without causing the selected view to change. Our PDF plotting chart did not have magnetic variation so we had to reference that from the FMS.

A second try:


Photo: Measuring True Course with JeppFD

If you are using JeppFD, pressing the plotter icon brings up a plotter that you can center over the waypoint in question. It isn't very accurate, since the width of the line can throw off your course by two or three degrees. But it is easier than the first method. With this method, I think you should be able to dispense with converting true to magnetic, since your master document should have true and magnetic.

A hybrid solution:

I like the presentation of JeppFD, especially for post position plots. But I don't think the electronic plotter is accurate enough. One of our pilots simply inputs the two waypoints as a separate track and reads the course directly. Once again I think this is cumbersome. I think cutting and pasting the route into Garmin Pilot and reading it right off the screen is just what is called for.


Photo: Garmin plotting chart with LFPB-KBED route and North Atlantic Track example

Distance Measuring



Photo: Paper distance measuring

Determining distance is done with a set of dividers or by constructing a to-scale ruler from paper: Plotting / Distance.

Plastic (iPad)

Our first attempt:


Photo: iPad distance measuring

Determining distance on an iPad plotting chart appears to be the biggest challenge. When you place a paper ruler on the iPad the scale or position tends to change. If you've successfully built your ruler, when you move the ruler to the course you could end up changing the zoom and render your ruler useless. One workaround is to use the scale of the plastic plotter and converting the printed scale into something usable mentally.

A second try:


Photo: Makeshift iPad dividers

My next attempt was to take my original dividers (the kind with the very sharp points that punch holes through paper and scratch iPad screens) and replaced the points with two sewing machine needles with the sharp ends turned into the dividers so the business end of the dividers are blunt. This way you won't scratch your screen. You need to ensure you do not change the scale of the screen when moving from your course line to the line of longitude to determine distance. This is still not easy: The ARINC-Direct chart doesn't have subdivided lines of latitude and JeppFD's lines don't have graduated lines.

A third method:

You can also cut and paste the points into the route definition screen to get an exact distance. I know pilots who think this is the way to go, but I think it is too much trouble.

The hybrid approach:


Photo: Garmin Pilot presentation (Courtesy Steven Foltz)
Click photo for a larger image

Some applications are better than others for this kind of cross-check. You can cut and paste your route into Garmin Pilot and get a quick look at true and magnetic courses as well as the distance between points. You can check out Garmin Pilot here:

Post-Position Plot



Figure: Two Degree Check Error Example, from Eddie's notes.

We check our progress about ten minutes after waypoint passage to make sure we are headed to the correct coordinates. Over the years we figured out that doing this about two degrees on longitude after a waypoint when going approximately east-west improves our accuracy since we eliminate half of the interpolation. But this is a necessity with papero only. More about this: Post Position Plot.

Plastic (iPad)

Our first attempt (and a pretty good one):


Photo: Two-degree check entered manually into JeppFD

Making a post-position plot using JeppFD with the iPad is quite easy. You derive the coordiantes from your FMS and then press the course line in the approximate position. Then it is just a matter of correcting the approximate latitude and longitude with exact numbers and pressing "done."

A better idea (iPad):


Photo: Portable GPS position on iPad using JeppFD

There is an even better way to ensure you remain on course. See An alternative to plotting, below.

Choosing an electronic plotting chart

Of course this begs the question: which version of electronic oceanic plotting chart should you use? As far as I know, the options aren't as good as they should be:

  • Track Ready Charts — There are a few commercial vendors who will give you charts with daily tracks depicted so all you need to do I add your own expected routing, ETPs, and whatever else you use routinely. We've found the charts of Apollodor to be especially useful, but the $80/year might be a bit pricey for some. When combined with a good application for drawing and entering text, such as GoodReader, this might be your best option when it comes to plotting on the iPad.
  • images

    Photo: Apollodor plotting chart with KBED-LFPB route and North Atlantic Track example

    We've had good success entering data and drawing lines and arrows onto the chart but saving all these annotations can be hit an miss. (As you can see, not all our ETPs and lines came through. Of course this isn't the chart's fault and it could have been operator error.

  • ARINCDirect En Route Charts — The en route chart offered by ARINC direct is okay. It will automatically add your flight plan and the tracks. But there aren't enough lines of longitude to realistically plot. As far as I know, ARINCDirect doesn't give your a way of saving the end product other than doing a screen grab by pressing the Home button and the power button at the same time.
  • images

    Photo: ARINCDirect plotting chart "screen grab" with KBED-LFPB route and North Atlantic Track example

    The longitude lines are very light, making measuring courses and distances more difficult. Of course there is a paradox to using a chart drawn by the ARINCDirect App: since it uses the same database as your Master Document, you could argue that there is no need to measure courses and distances at all. But, on the other hand, the entire exercise is to offer a cross check. How can you do that using the same App?

  • JeppFD — The Jeppesen En Route Charts — The Jeppesen en route chart available in JeppFD will automatically plot your course if you cut and paste the waypoints into the JeppFD flight plan. But, as with the ARINCDirect offering, there doesn't appear to be a way to archive the full resolution chart when you are done.
  • images

    Photo: Jeppesen plotting chart with LFPB-KBED route and North Atlantic Track example

    A nice feature of the JeppFD chart is you can enter points with exact coordinates, but there is no way to draw an arrow from a label to the point.

  • Garmin Pilot — Like JeppFD, you can cut and paste your route into Garmin Pilot. But unlike JeppFD, you can get the course and distance with a simple tool.
  • images

    Photo: Garmin plotting chart with LFPB-KBED route and North Atlantic Track example

    Garmin Pilot might be considered an unnecessary luxury if you have ARINCDirect and I suppose that might be true. At $600 per year for the premium version, Garmin Pilot isn't cheap. But it offers you an independent view of what ARINCDirect is giving you.


Photo: Multiple screen grabs of plotting charts merged into one

You can get greater detail if you take several screen grabs from your iPad, zoomed into each point. Click on the photo for a larger view.

There is a common problem when it comes to doing any plotting task on the iPad without any paper, and that is having to page between the master document and the chart. If, for example, you want to plot the best ETP between Gander and Shannon when using paper, you thumb through the pages to find the three qualifying items, typically the engine out, depressurization, and medical ETPs. When you find the one you want, you circle the latitude and longitude and then move over to your paper chart for plotting. With an iPad, you will have to scroll up and down to find each qualifying ETP, you will have to memorize the ETP distances, and once you have the ETP you want you'll have to memorize the crossing longitude (for a mostly east-west course). Then you page over to the plotting chart and hope you've memorize which city pair you selected and the corresponding longitude.

Post Flight Archives



Photo: Eddie's desk filled with paperwork from past oceanic trips.

There is no regulatory requirement to keep oceanic flight records but an accepted practice is 6 months. Even if you do everything by the book, you should keep these records for at least that long. Why? Well, for example, if the airplane in front or behind you fail to observe proper Mach Number Technique, you may be called to prove that you did.

But having all that paperwork loitering around your office can be cumbersome. And what if you would like to look at something older than 6 months? It is gone forever.

Plastic (iPad)


Photo: Example DropBox of oceanic trips

An archival record of oceanic trips is very easy to maintain in a paperless world using a file transfer application that is iPad friendly. Using DropBox, for example, is a great way to move things from your iPad to a computer with a large hard drive.

The Pros


Paper is familiar and for the most part faster than each equivalent task on an iPad.

Paper checklists linger until complete and help you to remember remaining tasks need to be addressed.

You don't have to worry about keeping the battery fresh and you won't be stranded by an out-of-date subscription. Every now and then I get surprised when a subscription has lapsed or the application needs an update and refuses to run at all once in flight. An out of date paper chart can be better than no chart at all.

Plastic (iPad)

If you are disciplined about it, it is easier to keep iPad oceanic material up to date, there is less cockpit clutter, and archives are quite easy.

The Cons


Paper products can be time consuming and expensive to print and keep up to date. On a long trip, the cockpit can get quite congested with paper unless you come up with an effective organization strategy. Then there is the problem with archiving. We flew around 700 hours per year in the charter GV I used to fly and we had three very tall filing cabinets filled with oceanic paperwork. (Until I threw everything away that was older than 6 months.) But even if you do maintain three very large filing cabinets, finding something you are looking for can be a frustrating experience.

Plastic (iPad)

Many of the routine tasks required during an oceanic flight take longer to accomplish with an iPad and I would argue are less precise. You will be tempted many times over to say, "good enough" when trying to determine a magnetic course or distance. When things get really hectic on the ground about to plunge right into oceanic airspace, you are often too busy with other logistics than to spend an extra 30 minutes plotting electrons when the same task takes only 5 minutes with paper.

Do you really have to plot?

If there was a way to accomplish the necessary cross check of your navigation system without plotting that is easier and more accurate than the old school method, wouldn't that be the way to go?

The world has changed, but not every FAA or SAFA inspector has caught up, so what you have here is a genuine "gray area."

[AC 91-70B, ¶] Up to now the only recommended method of cross-checking aircraft position in the oceanic airspace environment was manual plotting on a chart. However, a panel of aviation industry and FAA personnel completed an Operational Safety Assessment of methods for cross-checking oceanic flight navigation. The panel determined that an alternative to manual plotting, by which aircraft position could be checked through use of aircraft FMS-driven navigation displays and indications, would provide for an equivalent level of safety.

But you might want to also consider this from the same FAA document:

[AC 91-70B, ¶] Plotting your route on your chart will increase your situational awareness as you execute your trip through oceanic and remote continental airspace.

If, like me, you are all for increasing your situational awareness, head on over to Plotting.

The ICAO and EASA are silent when it comes to answering the question "Do I have to plot" but their regulations seem to assume that you are plotting. If you are trying to get an FAA Letter of Authorization or Operations Specification that has anything to do with long range navigation, the inspector is going to assume you know how to plot and solemnly swear that you do indeed plot whenever you get a chance. So you are in a bit of a conundrum. But let's assume you've got all your authorizations and don't fear the SAFA inspector with the clipboard. Can you get an equivalent level of safety with an easier method? I think so.

How about an independent GPS?

The reason we plot our position about 10 minutes (or 2 degrees of longitude when going approximately east or west) after each waypoint crossing is to ensure we are headed for the correct coordinates. If we had entered the next waypoint a degree or more in error, the ten minute check should make that obvious before we have a loss of separation. But wouldn't an independent GPS be able to tell us that too?

A distinct advantage of using a portable GPS with an iPad plotting application is you can scale the map display to get better detail than you would with a paper chart. Let's say you were using a 2-nm SLOP to the right but had made a 1-degree latitude error to the left. The combination of a right offset and a left error could be undetectable on a paper chart even after 10 minutes, but would be easily seen on an iPad.

Another advantage is that being able to scale the chart may show errors sooner than 2 degrees of longitude or 10 minutes. You might consider making your check at 1 degree of longitude or 5 minutes instead.

We bought a GPS "Puck" called the "Dual Electronics XPGS160 Multipurpose Universal 5 Device Bluetooth GPS Receiver with Wide Area Augmentation System and Portable Attachment" from In case you were wondering, see But is that legal?

The puck has a rechargeable battery that seems to last long enough for an oceanic crossing, but it has a USB charger that allows it to work indefinitely. It can link with up to 5 iPads and it powers up fairly quickly.

We can't seem to get the GPS receiver built into our iPads to work reliably in our G450, and yet we hear this isn't a problem in a G550. (The G450 cockpit comes right off the G550 assembly line, so this remains a mystery.) But even if you find your iPad GPS receiver works okay in your cockpit, this unit has WAAS and should be more accurate.


Photo: GPS "Puck" from XGPS
Click photo for a larger image

Using JeppFD with your course entered (you can cut and paste it from your flight plan), you can zoom into the leg with enough resolution to see that you are on course well before the 2-degree or 10-minute point. Here is a shot from a recent flight of ours. The CYYT-LPLA refers to an equal time point. Notice the airplane symbol is slightly right of course, showing that we have a 1NM Strategic Lateral Offset (SLOP) in place.


Photo: Two degree check using independent GPS Puck
Click photo for a larger image

Of course this begs the question, what will a 1-degree error look like? In the example photo, our oceanic clearance has us flying from North 59° West 040° to North 59° West 030° but the FMS was mistakenly programmed to head one degree latitude north (North 60° West 030°). Since the aircraft is headed toward where the FMS thinks it should be, there will not be any indication by the aircraft avionics that there is a problem. Plotting the aircraft's actual latitude and longitude about ten minutes after leaving North 59° West 040° would reveal the error potentially before a loss of separation with surrounding aircraft. If, on the other hand, you had a portable GPS receiver that links to your iPad, you could have an even quicker method of finding out you have a problem.


Photo: GPS Symbol shown at W038 headed for N60 W030 instead of N59 W030 (The classic 1 degree error).

Note that we entered the course into JeppFD with the error, we didn't actually fly it this way.

Operating a portable GPS receiver that is independent of the aircraft systems would seem to be the ideal crosscheck of your aircraft avionics. But is that legal? The basic regulation seems to indicate that it is, provided you can determine the device in question "will not cause interference with the navigation or communication system" of your aircraft. But how can you make that determination?

These rules were established in 1961 but were relaxed considerably in 2000 and again in 2006 with the release of Advisory Circular 91-21.1B which gave operators the latitude to allow the use of non-transmitting Personal Electronic Devices (PEDs) and gave some guidance on Transmitting PEDs and Medical PEDs. Operators were also given guidance on how to make these determinations. But no guidance was given for PEDs that transmit and receive GPS signals.

The bottom line to these rules is that you can use an iPad in the cockpit if (1) your cockpit is "PED-tolerant" and (2) the iPad has been adequately tested. These steps can be very difficult or very easy. If your manufacturer states they've done the tests and calls your aircraft PED-tolerant, you pass Step 1. Similarly, if your aircraft has a built in WiFi system, you can also assume you are PED-tolerant and have Step 1 done. What about your iPad? If you are a Jeppesen Customer a simple phone call can get you proof of Step 2. More about all of this: Portable Electronic Devices.

[14 CFR 91, ¶91.21 Portable electronic devices.

(a) Except as provided in paragraph (b) of this section, no person may operate, nor may any operator or pilot in command of an aircraft allow the operation of, any portable electronic device on any of the following U.S.-registered civil aircraft:

(1) Aircraft operated by a holder of an air carrier operating certificate or an operating certificate; or

(2) Any other aircraft while it is operated under IFR.

(b) Paragraph (a) of this section does not apply to—

(1) Portable voice recorders;

(2) Hearing aids;

(3) Heart pacemakers;

(4) Electric shavers; or

(5) Any other portable electronic device that the operator of the aircraft has determined will not cause interference with the navigation or communication system of the aircraft on which it is to be used.

(c) In the case of an aircraft operated by a holder of an air carrier operating certificate or an operating certificate, the determination required by paragraph (b)(5) of this section shall be made by that operator of the aircraft on which the particular device is to be used. In the case of other aircraft, the determination may be made by the pilot in command or other operator of the aircraft.

What is an EFB?

If you are operating commercially, AC 120-76D gives you a few more hoops to jump through. But even if you are operating under 14 CFR 91 and your company doesn't place additional restrictions on you, this advisory circular gives you some things you really ought to consider.

Displaying your aircraft position generated by the portable GPS on installed displays, for example, is possible. But it opens a can of worms. But doing so on the iPad isn't a problem.

A portable GPS is clearly a PED and not an EFB.

If you are looking in the regulations for a blanket statement that clearly says: "Yes, you can display your aircraft's position on your iPad," you aren't going to find it. You need to understand the context and evolution of AC 120-76. Previous versions specifically prohibited the display of "own-ship" position on EFBs, except on the ground for situational awareness. The current version, AC 120-76D, ¶9 removes that language with some words about displaying EFB Applications on installed avionics. So that has been taken to mean you can display own-ship position on an iPad. Matt Thurber of Aviation International News did us all a favor by asking the FAA directly. His article is available in the references below.

There is much more to EFBs than just this. See: Portable Electronic Devices.

[AC 120-76D, ¶6] An EFB is any device, or combination of devices, actively displaying EFB applications. EFBs are characterized by the following:

  • An EFB hosts applications, which are generally replacing conventional paper products and tools, traditionally carried in the pilot’s flight bag. EFB applications include natural extensions of traditional flight bag contents, such as replacing paper copies of weather with access to near-real-time weather information.
  • In order to qualify as an EFB application, the failure effect must be considered a minor hazard or have no safety effect.
  • Acceptable EFB applications are listed in Appendices A and B. These EFB applications may be overlaid or integrated.
  • EFBs cannot replace any installed equipment required by operational or airworthiness regulations.
  • EFB applications have no certification requirements for installation under aircraft type design (refer to AC 20-173).

[AC 120-76D, ¶9]

  • In the context of this AC, EFB equipment components supporting EFB applications are “installed” when they are incorporated into aircraft type design under 14 CFR part 21, or as a proper alteration under 14 CFR part 43, § 43.3. All other components supporting EFB functionality are considered “portable,” regardless of how often they are removed from the aircraft.
  • Airworthiness regulations do not apply to portable EFB components other than for specifications associated with the installed components (i.e., mounting (size and weight), power (maximum electrical load, voltage, and current frequency), and data connectivity (input/output (I/O) data specifications and security)). Regardless, this AC is applicable to any portable EFB components (e.g., mount, display, external Global Positioning System (GPS), cables/cords/adapters, and portable wireless transmitters) supporting an applicant’s authorization for use.
  • Display of EFB applications on installed displays may require differentiation to enable the flightcrew member to distinguish between the installed avionics display and the supplemental or “secondary” EFB display. For guidance on the design of installed components supporting EFB functionality, refer to AC 20-173.
  • Portable components supporting EFB applications are considered PEDs. For a PED to be considered an EFB, the PED must actively display Types A and/or B software application(s) (e.g., when a PED is displaying personal email, the PED is not considered an EFB; when the same PED is authorized and actively displaying a Type B aeronautical chart application, it is then considered an EFB).


It seems many pilots flying oceanic are using portable GPS units as an added measure of insurance against failures in their aircraft avionics. But these same pilots are quick to hide these units when a SAFA inspector shows up. The regulations seem to give you some latitude to use such a device, but also to give the inspector the latitude to cite you for doing so. What gives?

I think an aircraft with avionics sophisticated enough to cross an ocean are probably robust enough to not be bothered by a portable GPS receiver. I also think performing a post position accuracy check with a portable GPS is superior to doing a ten minute plot. But I also think the regulations haven't yet caught up with technology. The way I read them — and I could be wrong:

  1. If your aircraft is "PED-tolerant" or has a built in WiFi, you can use a portable GPS unit.
  2. If you have documentation proving iPad or EFB testing, you can use plastic over paper.

What if there is a GPS outage or if your portable GPS unit fails? The paper skills are still a vital weapon in any international pilot's arsenal. You ought to keep your proficiency with paper even after you have become a plastic guru.

14 CFR 91, Title 14: Aeronautics and Space, General Operating and Flight Rules, Federal Aviation Administration, Department of Transportation

A Report from the Portable Electronic Devices (PED) Aviation Rule Making Committee (ARC) to the Federal Aviation Administration (FAA), September 30, 2013

Advisory Circular 91.21-1D, Use of Portable Electronic Devices Aboard Aircraft, 8/25/06, Department of Transportation

*Advisory Circular 91-70A, Oceanic and International Operations, 8/12/10, U.S. Department of Transportation

* This version of AC 91-70 has been superseded but it retained because it contains older guidance that helps place current guidance into perspective.

Advisory Circular 91-70B, Oceanic and International Operations, 10/4/16, U.S. Department of Transportation

Advisory Circular 120-76D, Authorization for Use of Electronic Flight Bags, 10/27/17, U.S. Department of Transportation

FAA to allow display of own-ship position on EFB apps, Aviation International News, January 2018, p. 52.