Avionics News November 2012 - 4

NOW

Avionics Manufacturers Must Pay Attention to Part 145 Rewrite

embership in the Aircraft Electronics AsUnder the proposal, the only specific listing of radios sociation provides several benefits, and one and instruments on FAA documentation will be as an certainly is the monitoring of regulatory issues affecting accessory rating for radio and/or instruments, if, and repair stations and manufacturers. This effort is led by Ric only if, the repair station does some level of bench work Peri, AEA vice president of government and industry af- independent of the aircraft. In other words, if the repair fairs, and other AEA international regulatory consultants. station holds the aircraft, removes the radio or instruToday, we are embroiled in a critical ment and reinstalls the radio or instrument regulatory issue. The Federal Aviation back into the same aircraft, the only rating the Administration is proposing a significant repair station would hold is an airframe rating. change in the repair station rating system, The repair station would need an accessory a revision to the repair station training rating, if they accept radios and instruments program and limitations to supervisory for bench repairs without the aircraft. roles and responsibilities. Originally, the If this sounds like a repair station issue, comment period for the notice of proposed you’re right. But, how much will it cost rulemaking was due Aug. 20, but it has Chuck Freeland the AEA’s associate members to revise their been extended to Nov. 19. application and audit processes for dealerAt first glance, the AEA’s associate members, ships? While the AEA has been very open about the made up of manufacturers and distributors, might extreme cost to repair stations and the FAA’s overall look at the regulatory updates and quickly conclude dismissal of the cost to small business, the FAA has the NPRM only impacts repair stations and not the failed to consider the additional costs directly applicable associate members. However, I can assure you that to non-repair stations that rely on the current system. doing so is a very bad assumption. I’m trying to ring a bell here for a call to action, If the FAA proposal goes forward unchanged, the and the AEA’s associate members must get engaged long-held processes for establishing and assigning in this particular repair station NPRM. In these trydealerships will be turned on its ear – there will be ing economic times, the additional administrative and no radio or instrument ratings, period. For shops that financial costs that manufacturers will be burdened specialize in installations, they would be awarded an with must be accounted for. You suddenly may need to airframe shop with limitations to install radios and/or have communication with regular maintenance faciliinstruments, if appropriate. All business-aircraft repair ties that you have never dealt with previously. stations likely will have no FAA documentation to valiComments are critical at this time, and your voice date their radio and instrument capacity, thus stripping away much of the small and medium shops’ capability. Continued on page 32

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Avionics News November 2012

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