Avionics News July 2012 - 14

In this monthly column, Ric Peri of the AEA’s Washington, D.C., office, informs members of the latest regulatory updates.

B Y

R I C

P E R I A EA V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS

‘If at First You Don’t Succeed, Try, Try, Try Again’
accessories. So, for an aircraft shop to be able to offer “full service” he author of this quote, William Hickson, was a 19th to its customers, it must have airframe, powerplant, propeller, accescentury British educational writer. Yet, living in the sory, radio and instrument ratings just to provide full service, on-wing present, perhaps the famous quote from W.C. Fields is maintenance for the entire aircraft. more appropriate – “If at first you don’t succeed, try, try again. Then quit. There’s no use being a damn fool about it.” The breakdown of ratings does help allow the FAA to manage its After 20 years of trying and three changes in 10 years, the Federal resources; it can align staffing to the number of certificates and ratAviation Administration’s latest proposal for Part 145 repair station ings held by its constituents. But, it adds little value to the repair staratings, while well intended, is simply ill-timed, too costly, and takes tion, and making the shift from airframe to aircraft makes sense for dead aim at the avionics industry. But, the FAA keeps trying – some these types of businesses. The FAA defines aircraft as “a device that of it is good, some bad and some simply is a cheap shell game. After 20 years of trying and three changes in 10 years, the The FAA states that “this action is necessary because many portions of the existing repair Federal Aviation Administration’s latest proposal for Part 145 station regulations do not reflect current repair repair station ratings, while well intended, is simply ill-timed, station aircraft maintenance and business practoo costly, and takes dead aim at the avionics industry. tices, or advances in aircraft technology.” Here’s a good question: Is the agency amending the regulations to better reflect current business practices, is used or intended to be used for flight in the air.” So, without restricor is it amending the regulations to control the businesses? It appears tion, a full-service aircraft-rated repair station could maintain specific to be a little of both, but leaning toward the latter. aircraft types including all installed systems, provided, of course, that Does it make sense to change the airframe rating to an aircraft ratthe facility has (and documented evidence of) the housing, facilities, ing? Now, the agency is not directly proposing this, but it is talking equipment, material, technical data, processes and trained personnel around it. In reality, it is simply proposing to change the airframe ratin place to perform the work on the article. The six ratings a fulling to an aircraft rating, while retaining the “airframe” title. service facility currently needs would be reduced to one rating with The FAA defines an airframe as “the fuselage, booms, nacelles, the five additional capabilities being listed on the operation specicowlings, fairings, airfoil surfaces (including rotors but excluding fications. The Aircraft Electronics Association supported this logic propellers and rotating airfoils of engines), and landing gear of an airas a member of the Aviation Rulemaking Advisory Committee, and craft and their accessories and controls.” So, an airframe-rated repair we are disappointed the agency didn’t propose this clear, logical and station would be limited to maintenance on these specific systems and business-friendly improvement. subsystems. Part 145 Appendix A (removed in 2001, but still valid) On the other hand, the FAA is proposing to make drastic changes supports that an airframe shop is limited to physical fuselage, and inthat have a direct and detrimental effect on the avionics industry. I cludes electric wiring systems and the installation of instruments and believe this is a case of either ignorance of the industry or simply
14
avionics news

•

july

2012

Avionics News July 2012

Table of Contents for the Digital Edition of Avionics News July 2012