Avionics News February 2015 - 12

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

Cassandra
A

s the Aircraft Electronics Association plays
host to Part 23 and Part 25 ADS-B installation
forums with industry and the Federal Aviation
Administration this year, I am reminded of the age-old
Washington, D.C., phenomenon known as Cassandra.
Dating back to 16th century Greek mythology, Cassandra is "the one who predicts misfortune or disaster."
With more than 20 years in Washington, D.C., dealing with aviation regulations and rulemaking, I cannot
remember a major rulemaking effort when someone
hasn't evoked Cassandra as the basis of opposing the
proposed rulemaking.
In 1994, the U.S. Environmental Protection Agency
proposed regulations to restrict and limit the use of
hazardous air pollutants used in aircraft maintenance.
The industry took up arms and declared the end of
aviation. Two decades later, you hardly know the difference. And if you weren't part of the industry-led coalition, you likely don't have the history of why we are
using the processes (or the high-solid paints) that we use
today for painting and de-painting aircraft.
Do you remember 1,1,1-trichloroethane or carbon
tetrachloride? Oh, how those solvents were used. When
the proposed ban was introduced on these substances in
the 1980s, Cassandra emerged and forecasted the end of
the industry as we know it. Today, three decades later,
the graduates of any electronics school have likely never
seen nor used any of these substances or have a need
to know about ozone-depleting chemicals or chlorofluorocarbons; they simply are not used and have been
12

avionics news

february

2015

replaced with safer, cleaner, healthier alternatives.
In more recent history, how about the 1999 repair
station notice of proposed rulemaking? There certainly
were the broad-based statements about how the FAA was
proposing the demise of general aviation repair stations.
But after addressing the specifics of the rulemaking,
challenging what fit and what didn't, and recommending
improvements in the rules, industry found ways to make
it work. And in many cases, work better.
...If the aircraft owners and operators choose
(yes, choose) to delay ADS-B Out compliance until the
last minute, there are no guarantees they can get the
job done where and when it is convenient for them.

ADS-B is no different. You cannot have a discussion about the mandate without someone bringing up
Cassandra's dire predictions.
As 2015 begins, the focus is on ADS-B Out and how
industry can support the mandated 2020 implementation
date. First, recognize that Cassandra is here, and she will
be with us for the next five years as we move closer to
the Jan. 1, 2020, deadline. It's natural and normal that
she forecasts the demise of the industry; she always has
and always will.
Then you have decades of FAA history where it has
not been, shall we say, less than stellar in implementing
a rule when the agency said it would. It wouldn't be fair
to say this is wrong, because industry also has petitioned

Avionics News February 2015

Table of Contents for the Digital Edition of Avionics News February 2015