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.
6-3
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: ______________________