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4.4 Electronic Manual Authorization.
4.4.1 Submit an Application. Certificate holders will submit their application for an electronic manual system to the responsible Flight Standards office in writing. The FAA will review the application package for accuracy and completeness and notify the certificate holder in writing of any application deficiencies. Before the responsible Flight Standards office accepts the application package, the certificate holder will be required to correct all of the deficiencies. A certificate holder’s application package for authorization to use an electronic manual or manual system should include the following:
4.4.1.1 Letter of Intent. The application should contain the certificate holder’s Letter of Intent to use an electronic manual system.
4.4.1.1.1 Estimated Date of Implementation. The letter should include the estimated date on which the certificate holder would like to implement the electronic manual system.
4.4.1.1.2 Primary Point of Contact (POC). The letter should include the certificate holder’s primary POC for the electronic manual system application process.
4.4.1.2 The Master Manual for 14 CFR Part 91K, 121, 125, or 135. An application to use an electronic manual system for 14 CFR part 91K, 121, 125, or 135 should include a copy of the master manual as described in paragraph 4.3 above. The manual is required by OpSpec A025 and should address the guidelines set forth in this AC, contain policies and procedures, and list each manual maintained and distributed by the electronic manual system. The FAA will not accept an application that does not include the master manual.
4.4.1.3 A Description of the Electronic Manual—14 CFR Parts 133 and 145. An application to use an electronic manual for 14 CFR parts 133 and 145 should include a description of the electronic manual as described in paragraph 4.3 above.
4.4.1.4 Manuals Included in the System. The application should state specifically which manuals the certificate holder intends to maintain and distribute electronically. All of the applicable manuals should be included. For example:
• Flight Operations Manuals (FOM) by title;
• Ground operations manuals by title;
• Maintenance manuals by title;
• Training program manuals by title;
• Electronic MELs;
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• General policy manuals by title; and
• User manuals (e.g., flight planning system and other hardware/software applications) by title.
4.4.1.5 How Electronic Manuals Will Be Provided to the FAA. The application should explain how electronic manuals will be furnished/provided to the responsible Flight Standards office, including an explanation of how revisions and future electronic manuals will be provided.
4.4.1.6 Electronic Access to an MEL. Title 14 CFR parts 91K, 121, 125, and 135 require a certificate holder or program manager to have FAA approval and OpSpec authority to provide access to an MEL via electronic means.
Certificate holders desiring to provide electronic access to an MEL must specify that in the application and include details on how electronic access will be provided.
4.4.2 Demonstration Phase. The FAA will require a certificate holder to demonstrate the electronic manual system. The items requiring demonstration will typically include at least the following:
4.4.2.1 System Functionality. The certificate holder should demonstrate how the electronic manual system works. Specifically, the demonstration should show how manuals are accessed. If access is different for certain users, the demonstration should include how information is accessed by each group.
4.4.2.2 Revision Status. For electronic manuals used in 14 CFR parts 91K, 121, 125, and 135 operations, the demonstration should show how each electronic manual displays the date of latest revision in a manner in which a person can immediately ascertain it (see paragraph 4.3.7 above). Additionally, the demonstration should show how revisions are posted to electronic manuals.
4.4.2.3 Security Protocols. The demonstration should include how the system prevents unauthorized access and/or unauthorized modifications to manual content.
4.4.2.4 QC Procedures. The demonstration should show how the QC and auditing procedures work.
4.4.3 Successful Completion of Application for Approval or Acceptance and Authorization.
When a certificate holder successfully completes the approval (applicable only to electronic access to an MEL) or acceptance process, the FAA will authorize the electronic manual system by signing and issuing OpSpec A025.
4.4.4 Unsuccessful Application. If the certificate holder fails to submit an acceptable application or fails to successfully demonstrate the manual system process, the responsible Flight Standards office will reject the application and provide an explanation to the certificate holder in writing.
5-1 CHAPTER 5. VOLUNTARY DISCONTINUANCE BY CERTIFICATE HOLDER
5.1 Voluntary Discontinuance. If a certificate holder elects to discontinue using electronic signatures, an electronic recordkeeping system, or an electronic manual system, they will inform the responsible Flight Standards office in writing. Once informed, the responsible Flight Standards office will amend the certificate holder’s OpSpec A025 to remove the authorization voluntarily discontinued. Certificate holders that voluntarily discontinue the use of electronic signatures, an electronic recordkeeping system, and/or an electronic manual system should include the following information in their discontinuance letter.
5.1.1 Letter of Discontinuance for Electronic Signatures.
5.1.1.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the electronic signatures.
5.1.1.2 The letter should contain a description of how the certificate holder intends to transition from using electronic signatures to using pen-and-ink signatures.
5.1.1.3 The letter should contain a description of how electronically signed documents and records will be reproduced and retained in accordance with the requirements of 14 CFR in hardcopy form.
5.1.1.4 If an electronic signature is used in conjunction with an electronic recordkeeping system, the FAA will likely initiate procedures to withdraw authority to use the electronic recordkeeping system.
5.1.2 Letter of Discontinuance for an Electronic Recordkeeping System.
5.1.2.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the electronic recordkeeping system.
5.1.2.2 The letter should contain a description of how the certificate holder intends to transition from electronic records to paper records. The description should include how the certificate holder intends to ensure the content of the paper records match the electronic content, including having the required signatures.
5.1.2.3 The letter should include the estimated date the paper records will be ready for FAA review.
5.1.3 Letter of Discontinuance for an Electronic Manual System.
5.1.3.1 The letter from the certificate holder should include the projected date the certificate holder intends to discontinue using the system and provide hardcopy manuals, if required by appropriate 14 CFR parts.
5.1.3.2 The letter should contain a description of how the certificate holder intends to transition from electronic manuals to paper manuals. The transition
5-2 description should include procedures for the certificate holder to audit the paper manuals by comparing them to the electronic manuals and reconcile any differences.
5.1.3.3 The letter should include the estimated date the hardcopy manuals will be provided to the responsible Flight Standards office.
6-1 CHAPTER 6. ADMINISTRATIVE
6.1 Questions About This Advisory Circular (AC). If you have questions about the material in this AC or would like to provide feedback, you may contact:
• The Air Transportation Division at Room # 834, 800 Independence Avenue, SW, Washington DC, 20591, or by phone at 202-267-8166; and/or
• The Aircraft Maintenance Division at 8th Floor, 800 Independence Avenue, SW, Washington, DC 20591, or by phone at 202-267-1675.
6.2 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.
6.3 Other Related Regulations, Guidance, and Reading Material (current editions).
6.3.1 Regulatory References:
• Public Law (PL) 104-13, Paperwork Reduction Act of 1995.
• PL 105-277, Government Paperwork Elimination Act.
• PL 106-229, Electronic Signatures in Global and National Commerce Act (E-Sign Act).
• Title 14 CFR Parts 43, 61, 65, 91, 119, 121, 125, 129, 133, 135, 137, 141, 142, 145, and 147.
• Office of Management and Budget (OMB) Circular A-130, Managing Information as a Strategic Resource.
6.3.2 FAA Order 8900.1, Flight Standards Information Management System. Certificate holders can find Order 8900.1 on the Dynamic Regulatory System (DRS) at https://drs.faa.gov.
6.3.2.1 Title 14 CFR Part 121 Dispatch and Flight Release Requirements— Electronic Signatures, Amendments, and Disposition. Information regarding electronic signatures on a dispatch or flight release, electronic amendments to a dispatch or flight release, and/or electronic recordkeeping of a dispatch or flight release is contained in Volume 3, Chapter 25, Section 1, Basic Requirements and Policy Applicable to All Air Carriers.
6.3.2.2 Title 14 CFR Part 121 En Route Communication Records. Information on the electronic retention of en route communication records in accordance with 14 CFR § 121.711 is contained in Volume 3, Chapter 25, Section 1.
6.3.2.3 Title 14 CFR Parts 121 and 135 Recordkeeping Systems Acceptance or Approval Process. Information and guidance to be used by PIs when accepting or approving certificate holder recordkeeping systems is contained
6-2 in Volume 3, Chapter 31, Section 2, Requirements for Approval, Acceptance, and Authorization.
6.3.2.4 Title 14 CFR Parts 121 and 135 Crewmember and Aircraft Dispatcher Records. Volume 3, Chapter 31, Section 3, Crewmember and Aircraft Dispatcher Records, contains detailed information regarding crewmember and aircraft dispatcher records in accordance with the requirements of 14 CFR parts 121 and 135, as applicable.
6.3.2.5 Title 14 CFR Parts 121 and §
135.411(a)(2) Maintenance Records.
Volume 20, Chapter 7, Maintenance Recordkeeping System, contains detailed information regarding the evaluation of an air carrier’s maintenance recordkeeping system.
6.3.2.6 Title 14 CFR Part 91K Non-CAMP Program Manager’s, 14 CFR § 125.247 Certificate Holder’s, and 14 CFR § 135.411(a)(1) Maintenance Records. Volume 3, Chapter 31, Section 6, Evaluate an Owner’s or Operator’s Maintenance Records as Required by § 91.417, contains information for Airworthiness inspectors on how to evaluate 14 CFR part 91K non-CAMP and 14 CFR part 135 maintenance records.
6.3.2.7 Title 14 CFR Part 145. Volume 6, Chapter 9, Section 6, Inspect a Repair Station’s Record System, contains detailed information on repair station electronic signatures and electronic recordkeeping.
6.3.2.8 Operations Specification (OpSpec) A025, Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manual Systems.
Information on how to issue OpSpec A025 is contained in Volume 3, Chapter 18, Section 3, Part A Operations Specifications—General, OpSpec/MSpec/TSpec/LOA A025.
6.3.2.9 OpSpec A061, Electronic Flight Bag (EFB) Program. Information related to authorization to use an EFB program is contained in Volume 3, Chapter 18, Section 3, OpSpec/MSpec/LOA A061.
6.3.3 FAA Order 8000.79, Use of Electronic Technology and Storage of Data.
6.3.4 Related ACs:
• AC 90-117, Data Link Communications.
• AC 91-78, Use of Electronic Flight Bags.
• AC 91.21-1, Use of Portable Electronic Devices Aboard Aircraft.
• AC 120-64, O perational Use and Modification of Electronic Checklists.
• AC 120-76, Authorization for Use of Electronic Flight Bags.
6.3.5 Other Reading Material:
• OMB Memorandum M-00-15, OMB Guidance on Implementing the Electronic Signatures in Global and National Commerce Act.
• Federal Information Processing Standards (FIPS) Publication 186-5, Digital Signature Standard (DSS) at https://doi.org/10.6028/NIST.FIPS.186-5.
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Appendix A A-1 APPENDIX A. SAMPLE LETTER OF INTENT Note: Certificate holders should use this AC to identify the various requirements for the Letter of Intent contents.
[Requester Letterhead] To: [Responsible Flight Standards office] From: [Requester] Date: [Date] Subject: Use of Electronic System – (Signatures/Recordkeeping/Manuals) This letter is to inform you that [requester] intends to use an electronic (signatures and/or recordkeeping and/or manual) system for [describe what the system will be used for]. This system has been established using the guidelines outlined in FAA Advisory Circular (AC) 120-78 (as amended).
Company facilities, equipment, and personnel are available for your review at [address] on [date]. Please contact [name] at [telephone] to arrange a visit to review the system and to discuss any FAA concerns.
Sincerely, [Requester]
Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.
Subject: AC 120-78B, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals Date: _____________________ Please check all appropriate line items:
An err or (pro ce dural or typographical) has been noted in paragraph ____________ on page _______.
Recommend paragraph _____________ on page __________ be changed as follows:
______________________________________________________________________ ______________________________________________________________________ In a future change to this AC, please cover the following subject:
(Briefly describe what you want added.)
______________________________________________________________________ ______________________________________________________________________ Other comments:
______________________________________________________________________ ______________________________________________________________________ I would like to discuss the above. Please contact me.
Submitted by: Date: ______________________