Avionics News May 2013 - 15

tions that were implemented in Europe. The proposal likely
The FAA Order 9800.1 Volume 4, Chapter 9, Section
will affect all EASA 145 facilities, including both domestic and
1: Perform Field Approval of Major Repairs and Major
foreign approved maintenance organizations throughout the
Alterations, identified some key factors to consider (the same
world. The effect on the 1,000 or so U.S. -based repair stations
factors that the AEA has been teaching for more than a decade).
covered by the U.S.-EU Bilateral Safety Agreement is yet to be
There are essentially three factors to condetermined. But since it is a European requirement that does not
sider in the performance of alterations or repairs.
currently have an FAA equivalent, it is expected to be included
These definitions are provided in Title 14 of the
in a future maintenance annex requirement. The comments are
Code of Federal Regulations (14 CFR) part 1, § 1.1.
due May 22; if you are affected and have not submitted com• Is the alteration or repair major or minor, per
ments, I encourage you to comment as soon as possible.
14 CFR part 43, appendix A? If determined to
While on the topic of international operations, on Wednesday,
be a major repair or alteration, a field approval
March 27, the AEA Leadership & Regulatory Forum highlightmay be granted.
ed trends and forecasts for the global economy – an excellent
• If the alteration or repair is determined to be a
program that was well received by the audience. The forum
major change to type design, a field approval
also featured discussions on bilateral agreements throughout
will not be granted.
the world supported by Transport Canada and the Australian
• Minor alterations or repairs do not require FAA
Civil Aviation Safety Agency; and finally, a focus on NextGen
approval.
beyond ADS-B.
The order further defines a field approval as “a method by
The panel discussion on bilateral agreements focused on
which the FAA approves technical data used to accomplish a
agreements from three major demographics: the U.S. (FAA);
major repair or a major alteration on a single aircraft, providCanada (TCCA); and Australia (CASA). The session was
ed the repair or alteration is not classified as a major change
not U.S.-centric, as the international audience heard about
in type design.” A major change in type design requires an
the 19 (plus EASA) agreements the U.S. has with countries
around the globe, as well as Canadian
agreements outside North America and
Were you there? As advertised, ‘The AEA Convention is
the Australian agreements throughout
the Pacific Rim countries.
the only wholesale avionics show representing nearly
A bilateral airworthiness agreement
is an “executive agreement” concluded
90 percent of the international government-certified
at the government-to-government level
avionics shops.’ How could you not be there?
by an exchange of diplomatic notes,
with an appropriate Department of State
official signing for the U.S. There are
STC. An FAA inspector’s signature in block 3 of FAA Form
no U.S. statutes, FAA regulations or international agree337 approves the data provided on the form.
ments or conventions that require a BAA to exist with the
As a reminder, the FAA inspector’s signature in block
importing country for export of U.S.-manufactured aero3 is one of 23 different sources of approved data. If your
nautical products. Countries do not usually seek, nor does
alteration is not a major change in type design, or an
the U.S. encourage, BAAs unless the other country has an
alteration that by policy the administrator requires an STC,
aeronautical product manufacturing industry and desires to
then should the alteration be outside the scope of your
export such products to the U.S.
inspector’s authority, pursue one of the other 21 sources of
A complete list of U.S. FAA bilateral agreements can be
approved data.
found online at www.faa.gov/aircraft/air_cert/international/
On Tuesday, March 26, at the Rise and Shine session, we
bilateral_agreements/baa_basa_listing/.
discussed one of the more controversial proposals we have
While we’re talking about links to tools on the FAA’s webhad in a number of years. If you remember, the Federal
site, have you used the field approval job aid? Following up on
Communications Commission has proposed to ban 121.5
the FAA presentation at the 2012 convention in Washington,
MHz emergency locator transmitters. As reported in AEA’s
D.C., the FAA has finalized its field approval job aid. It is
regulatory updates, in the FCC’s Third Report and Order for
a reasonably simple online tool that helps identify what the
2010, adopted June 1, 2010, and published June 15, 2010,
FAA inspectors can and cannot approve alteration and repair
the FCC prohibited further certification, manufacture,
data for. Yes, while it tells the FAA Flight Standards employee
what data they can and cannot approve; it does not overrule
the regulations defining major alterations.
Continued on page 59
avionics news

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may

2013

http://www.faa.gov/aircraft/air_cert/international/bilateral_agreements/baa_basa_listing/ http://www.faa.gov/aircraft/air_cert/international/bilateral_agreements/baa_basa_listing/

Avionics News May 2013

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