EASA NPA 2016-12 EFB 1/3 EFB Admin Remarks From: Hans-Conrad Stamm (SWISS / OFI) in coordination with Lufthansa EFB Hamonisation Group representing EFB Administrators from AUA Austian Airlines, Brussels Airline, Eurowings/Germanwings, Lufthansa Passage, Lufthansa Cityline, Lufthansa Cargo, SWISS) Date: Dez 2016 Feedback from LH EFB Hamonisation Group & SWISS regarding proposed “EASA NPA 2016-12 Transposition of provisions on electronic flight bags from ICAO Annex 6” (RMT.0601 — 4.10.2016) Executive Summary of the NPA 2016-12 EFB The NPA is published to maintain a high level of safety with regard to the use of EFBs by ensuring a harmonised implementation of the current provisions of AMC 20-25. It includes a proposal for an operational approval for the use of EFB applications by commercial air transport (CAT) operators. General Remarks LX The proposed NPA 2016-12 has the goal to harmonize the implementation of the AMC 20-25 and to give EFB system providers, application developers, operators and regulators guidance how to implement an EFB solution. The 138 page NPA is very detailed and covers all relevant areas. It supports the basic principle that an EFB system should support the pilots and should support a safe operation. Nevertheless in some parts the guidance is very specific, restrictive and complex. This could lead to: - It will increase complexity, manpower needed and time to implement an EFB solution for system suppliers, operators and regulators. - It is questionable if a regulation this complex and specific can cope in all cases with technology innovations especially in the IT- and EFB-Area. It is more likely that it could hinder new, smart, convenient or innovative solutions in future. As a general feedback the document should be reduced to be less complex, less specific and less detailed. Especially regarding IT- Issues it should not focus on « how things are done » (because this can change fast) but on what is « the aim to reach ». Specific Remarks: AMC1.CAT.GEN.MPA.141(a) (h) Viewable stowage (pg21) What does this mean? If the pilot cannot access the EFB controls, how shall a shutdown be possible? OFI - eOperations Hans-Cornad Stamm / CMD A32x / Manager eOperations Swiss International Air Lines Ltd. Swiss Global Air Lines Ltd. www.swiss.com EASA NPA 2016-12 EFB 2/3 EFB Admin Remarks AMC3.CAT.GEN.MPA.141(b) TYPICAL TPYE B APPLICATIONS (pg25) (b)..., but without a display of aircraft/own-ship position, except in the specific case of day VFR operations only. Lufthansa Group including SWISS rates the benefits of OSP on digital maps higher than the acompanied risks. Until Nov 2016 Lufthansa Group has operated ~2,5 Mio flights with OSP on EFB charts, and there are no negative reports about this feature. In contrary safety department has come to the conclusion that OSP could have avoided previous incidents where no OSP was available. LHP and SWISS B777 OSP on EFB incorporates these features: - Position of certified aircraft system sources (FMS, GPS) for OSP on charts. - OSP is only to be used for orientation on the map, symbol is a circle - crew procedure and training how to use OSP by crews Lufthansa Group including SWISS propses that OSP is allwoed on EFB, maybe under the some to be defined requirements. AMC1.SPA.EFB.100 (b) (pg 32) AMC1.NCC.GEN.131 (b) (pg 61) AMC1.SPO.GEN.131 (b) (pg 80) What is a “qualified/verified input data”, "appropriate industry standards"? What is the aim of this paragraph? OFI - eOperations Hans-Cornad Stamm / CMD A32x / Manager eOperations Swiss International Air Lines Ltd. Swiss Global Air Lines Ltd. www.swiss.com EASA NPA 2016-12 EFB 3/3 EFB Admin Remarks AMC1.SPA.EFB.100 (b) (pg 37) Term “partitioned” is to specific and outdated, it does not include other possible means of IT Security measurements like iOS sandbox principle or virtual machines. Proposal to: o DELETE “and partinioned” o CHANGE the (e.g. to “e.g. separated partitions, virtual machines, sandbox, etc)“ AMC6.SPA.EFB.100 (b) (pg 49) Why is this special to AMMD? Transfer medium could also be an online data-transmission e.g. update over wifi or download from an app-store. Or the app or the entire service could be in the cloud. What is the aim of this statement? AMC8.SPA.EFB.100 (b) (pg 52) ...prevail if there is a difference from IFW... IFW will in nature always be different from the classic wx information. The qualification of weather sources as reliable should be evaluated by the operator. (end of document) OFI - eOperations Hans-Cornad Stamm / CMD A32x / Manager eOperations Swiss International Air Lines Ltd. Swiss Global Air Lines Ltd. www.swiss.com .