Advisory 

Circular 

 

Subject: OBTAINING DESIGN AND 

PRODUCTION APPROVAL OF AIRPORT 

MOVING MAP DISPLAY APPLICATIONS 

INTENDED FOR ELECTRONIC FLIGHT 

BAG SYSTEMS

Date: 4/30/07 

Initiated by: AIR-130 

AC No: 20-159 

1. What is the purpose of this Advisory Circular (AC)? 

a. This is a joint Flight Standards Service (AFS) and Aircraft Certification Service (AIR) 

AC. This AC will guide you in obtaining a design and production approval under Technical 

Standard Order (TSO) C-165, Electronic Map Display Equipment for Graphical Depiction of 

Aircraft Position, for the software and database used to provide an airport moving map display 

(AMMD) intended for use on a Class 2 electronic flight bag (EFB) for ground operations. Use 

this AC in conjunction with the guidance in AC 120-76, Guidelines for the Certification, 

Airworthiness, and Operational Approval of Electronic Flight Bag Computing Devices, if you 

are a manufacturer applying for technical standard order authorization (TSOA) as a means to 

enable use of an AMMD in an EFB under the allowance described in AC 120-76 paragraph 8.f. 

b. This AC does not apply to any other Type C applications as defined in AC 120-76, such 

as an electronic map display (EMD) with own-ship symbol intended for use while airborne. 

2. Who does this AC apply to? We wrote this AC for operators and applicants. This AC is 

not mandatory and does not constitute a regulation. In it, we describe a means, though it is not 

the only means, to obtain a TSOA for an “incomplete system.” However, if you use the means 

described, you must follow it in all respects. 

3. Related references. All references in this AC to FAA documents are to the current version. 

The current version is available on the internet at http://rgl.faa.gov/. 

a. FAA ACs.

(1) AC 20-115, RTCA, Inc., Document RTCA/DO-178B. 

(2) AC 20-153, Acceptance of Data Processes and Associated Navigation Databases.

(3) AC 120-74, Parts 91, 121, 125, and 135 Flight Crew Procedures during Taxi 

Operations.
4/30/07 AC 20-159 

 

2 

(4) AC 120-76, Guidelines for the Certification, Airworthiness and Operational 

Approval of Electronic Flight Bag Computing Devices. 

(5) AC 91.21-1, Use of Portable Devices Aboard Aircraft.

b. FAA TSOs. TSO-C165, Electronic Map Display Equipment for Graphical Depiction of 

Aircraft Position, dated September 30, 2003.

c. RTCA, Inc. Documents. 

(1) RTCA/DO-178B, Software Considerations in Airborne Systems and Equipment 

Certification, dated December 1, 1992 and its equivalent, EUROCAE document ED-12B, 

Software Considerations in Airborne Systems and Equipment Certification. 

(2) RTCA/DO-257A, Minimum Operation Performance Standards for the Depiction of 

Navigational Information on Electronic Maps, dated June 25, 2003. 

(3) RTCA/DO-272A, User Requirements for Aerodrome Mapping Information, dated 

August 3, 2005 and its equivalent, EUROCAE document ED-99A, User Requirements for 

Aerodrome Mapping Information. 

4. How this AC relates to current EFB policy. 

a. AC 120-76 describes certain functions, called “applications” that may be displayed 

using an EFB. Some applications, called Type A and B applications, may be hosted on Class 2 

EFBs. Type A and B applications do not require Aircraft Certification Service (AIR) design 

approval in Class 1 or 2 EFBs. Class 2 EFBs are considered portable electronic devices. AC 

120-76 provides a means for these portable electronic devices to be connected to mounting 

bracket(s), aircraft power, and data connectivity ports. 

b. The AMMD, which provides depiction of an own-ship symbol for ground operations, is 

not identified as a Type A or B application. It can be approved as a Type C application if the 

manufacturer obtains a design approval. The industry standard for the application was 

developed by RTCA Special Committee 181 and is published in RTCA/DO-257A. The FAA 

references RTCA/DO-257A in FAA TSO-C165, which defines the minimum level of functional 

capability and performance for both portable and installed electronic map displays. 

c. TSO-C165 defines that the AMMDs failure condition for misleading information is 

classified as “minor” and the failure condition for the loss of function is classified as “no effect.” 

Recognizing the nature of these failure effects and considering the potential safety enhancement 

of improved situation awareness on the airport surface, we describe a streamlined process to 

allow own-ship position on an AMMD using a TSOA for an “incomplete system.” The resulting 

AMMD software and database, authorized under TSO-C165 with a design and production 

approval, is eligible for use in an EFB as described in AC 120-76 paragraph 8.f. This application 

of an incomplete system TSOA is unique to Class 2 EFBs since compliance to airworthiness 

regulations is not established in these instances. The incomplete TSOA provides an appropriate 
4/30/07 AC 20-159 

 

3 

assurance of quality and functionality of the AMMD, and AC 120-76 describes acceptable 

requirements for equipment compatibility and configuration control of the integrated system. 

d. The TSOA includes both a design and production approval. Production approval is 

required to manufacture the AMMD software and database. Manufacturers must have in place 

an FAA-approved quality control system to receive a production approval for the AMMD 

software and database under a TSOA. 

5. AMMD functionality and limitations. 

a. This AC provides a means of compliance to obtain a TSOA for an incomplete AMMD 

system. The TSOA is an acceptable means of providing AMMD functionality for ground 

operations. This AC is not applicable for design approval of any other Type C applications, such 

as an electronic map display (EMD) with own-ship symbol while airborne. 

b. The intended function of AMMD is to help flight crews orient themselves on the airport 

surface and improve pilot positional awareness during taxi operations. AMMD function is not 

sufficient to be used as the basis for maneuvering and assumes compliance with the operational 

guidelines in AC 120-74, Parts 91, 121, 125, and 135 Flight Crew Procedures during Taxi 

Operations. 

c. In this AC, the position source for the AMMD must be received from an approved 

source (e.g., sensor with TSO-C129a, TSO-C145a or other installed GNSS sensor). 

6. How to obtain a TSOA for an incomplete system AMMD. 

a. If you apply for a TSOA for an incomplete system under the provisions of this AC, you 

must cite compliance with all the AMMD requirements in TSO-C165 except as noted in 

paragraphs 6b and 6c below. FAA aircraft certification office (ACO) staff will guide you using 

FAA Order 8150.1, Technical Standard Order Program. You must ensure that the software and 

database is compatible with the EFB system computing platform on which it is intended to 

function. AMMD software and database approved under TSOA may be installed on various 

EFB systems. In your application package you must include software and database installation 

instructions and a compatibility description to address the AMMD installation for each 

applicable platform. 

b. The following TSO-C165 requirements are not applicable to an incomplete system with 

AMMD software and database only: 

(1) Flight plan function (RTCA/DO-257A section 2.2.1.2). 

(2) Schematic drawings and wiring drawings (TSO-C165 paragraphs 5.a(3), 5.a(4), 

5.b(4), and 5.b(5)). 

(3) Materials and process specifications (TSO-C165 paragraphs 5.a(8) and 5.b(6)). 

(4) Equipment calibration procedures (TSO-C165 paragraph 5.b(2)). 
4/30/07 AC 20-159 

 

4 

(5) Display parameters (RTCA/DO-257A section 2.2.3). 

c. Certain deviations to TSO-C165 apply to this incomplete system. You must request the 

deviations described below using the procedure specified in TSO-C165 paragraph 3.f: 

(1) Environmental qualification (TSO-C165 paragraphs 3.d, 5.a(7) and 5.b(7)). Since 

the incomplete system does not include hardware, compliance with these requirements cannot be 

assessed. An acceptable, alternate means of compliance is to limit the installation to EFBs that 

obtain authorization for use under AC 120-76, which requires assurance of non-interference to 

installed systems (see AC 91.21-1). 

(2) System-level Installation/Interface procedure and limitations (TSO-C165 paragraph 

5.a(2)). Since the incomplete system is not intended for installation in an aircraft it is not 

appropriate to refer to a “separate approval for installation”. Replace Note required by 

TSO-C165 paragraph 5.a(2) and substitute the following in the installation procedures: 

This EFB airport moving map display (AMMD) with own-ship position symbol 

has been authorized under TSO-C165. Use of this application with an EFB in 

14 CFR Parts 121, 125, or 135 and Part 91, subpart F operations requires 

authorization for use in compliance with AC 120-76. 

7. Additional guidance on compliance to TSO-C165. The following paragraphs provide 

clarification of certain TSO-C165 requirements as they apply to the authorization for an 

incomplete system.

a. Software qualification. The software must comply with all the requirements of 

RTCA/DO-178B appropriate to Level D software (or its equivalent). The following paragraphs 

provide guidance on certain RTCA/DO-178B objectives as they relate to the incomplete system. 

(1) RTCA/DO-178B, Table A-2 objective 7 and Table A-6 objective 5: You must 

establish compatibility with the hardware platform and operating system during target computer 

compatibility testing. Since AMMD loss of function is considered to have no effect, there is no 

need to specifically evaluate compatibility with other Type A and B software applications that 

are outside the scope of the TSOA. Include the results of all tests in the TSO qualification test 

report required by TSO-C165 paragraph 5.a(10). If compatibility is established with several 

different hardware platforms and operating systems, including different versions of an operating 

system, these tests should be repeated for each unique configuration of hardware and operating 

system. The high-level functionality and requirements, as referenced in RTCA/DO-178B 

paragraph 6.4.3a, should include the following characteristics: 

(a) Proper operation of all EFB controls that interface with the application software 

(per RTCA/DO-257A section 2.1.5). 

(b) Proper display performance, operating characteristics, and status indications (per 

RTCA/DO-257A section 2.2.4). 

(c) Demonstration of the AMMD function’s ability to detect and fully remove 

depiction of own-ship position when the position sensor horizontal positional accuracy exceeds 
4/30/07 AC 20-159 

 

5 

the maximum value specified in RTCA/DO-257A sections 2.3.1.1.1 and 2.3.1.1.2 or when the 

position source becomes unavailable. We recommend the manufacturer consider using a tighter 

accuracy threshold to ensure the own-ship symbol is depicted on the correct runway or taxiway. 

(d) Demonstration of the AMMD function’s ability to detect and fully remove 

depiction of directionality of own-ship position as specified in RTCA/DO-257A section 2.3.1.2 

(such as when aircraft is stopped, or during a slow taxi). 

(e) Demonstration of the AMMD function’s ability to detect and fully remove 

depiction of own-ship position when the EFB’s operating system attempts to corrupt memory 

allocation or cause other erroneous information (e.g., task or interrupt conflicts). 

(f) Demonstration of the AMMD function’s ability to detect and fully remove 

depiction of own-ship position when airborne, or when taxi speed exceeds 40 knots ground 

speed. 

(g) Any additional testing unique to the system architecture that is necessary to 

ensure that the application software, when loaded into the target computer platform, complies 

with the applicable requirements of RTCA/DO-257A sections 2.1, 2.2 and 2.3. 

Note: Operators may use the compatibility information documented 

in the installation instructions when obtaining authorization to use the 

EFB under AC 120-76. 

(2) RTCA/DO-178B Table A-4 objective 13: You must establish detection and fault 

handling means to protect AMMD software from malfunction that could be caused by any Type 

A and B applications and the commercial-off-the-shelf (COTS) computing platform including 

the operating system. 

(3) RTCA/DO-178B software configuration index: You must include the target 

computing platform and operating system in the configuration index. However, these 

components are not included under the incomplete system TSOA described by this AC. For 

Class 2 EFBs, the FAA recognizes that these commercial off-the-shelf (COTS) products and 

changes to the product may be made by the supplier without any indication in the part number or 

version. 

b. Database. The AMMD function includes an airport map displayed from a database. 

The manufacturer must comply with section 2.2.5 of RTCA/DO-257A. One method for 

establishing compliance for the database updating process is to obtain a FAA letter of acceptance 

(LOA) as described in AC 20-153, Acceptance of Data Processes and Associated Navigation 

Databases. The data requirements must be defined, and we encourage compliance with 

RTCA/DO-272A, with at least ‘medium’ accuracy and ‘routine’ integrity. RTCA/DO-272A is 

the industry standard for data supporting AMMD. 

c. Marking. The software must provide a means to easily display the required marking 

(TSO-C165 paragraph 4) on the target computer platform as well as identification as an 

incomplete system. While it is not necessary to physically mark any component of the system 

with TSO-C165, use of electronic part marking data (per 14 CFR § 21.607(d)) must be verifiable 
4/30/07 AC 20-159 

 

6 

on the ground at any geographical location. If the software is hosted on a transferring medium 

(for example, a Secure Digital (SD) memory card), identify this transferring medium in 

accordance with the marking requirements in TSO-C165 paragraph 4. 

d. Operating instructions and equipment limitations. In addition to the requirements of 

TSO-C165 paragraph 5.a(1), add the following Note to the installation manual and/or operations 

manual: 

This EFB airport moving map display (AMMD) with own-ship position symbol is 

designed to assist flight crews in orienting themselves on the airport surface to 

improve pilot positional awareness during taxi operations. The AMMD function 

is not to be used as the basis for ground maneuvering. This application is limited 

to ground operations only. 

8. Installation instructions. In addition to the installation manual requirements specified in 

TSO-C165, include the following: 

a. Identification of each target EFB system computing platform (including hardware 

platform, operating system version, and Type A and B applications) with which this AMMD 

application was demonstrated to be compatible. 

b. Program installation instructions, as applicable, for each target EFB computer. 

c. Requirements for data provided by other installed systems, such as a GNSS sensor. This 

should include the latency of the position as provided to the EFB to support compliance with 

RTCA/DO-257A section 2.2.4 (item 20). The typical latency of installed GPS sensors is 200 ms. 

The instructions should also identify the required position update rate to support compliance 

with RTCA/DO-257A section 2.2.4 (item 21), and any limitations or configuration required to 

properly site the nose of the aircraft (depending on location of GPS antenna installed on the 

aircraft relative to the pilot’s position). 

9. EFB platform installation eligibility. Evidence of a TSOA design approval for the AMMD 

Type C application (see AC 120-76 paragraph 8.f) is an adequate indication to the FAA for use 

in an EFB system that the manufacturer has demonstrated to be compatible. 

10. Related Federal Aviation Regulations. Title 14 of the Code of Federal Regulations 

(14 CFR) parts 21, 23, 25, 27, 29, 43, 91, 121, 125, and 135.