Avionics News February 2016 - 37
IT IS NOT ABOUT THE
STANDARDS, IT IS
ABOUT THE USE OF
STANDARDS IN AIRCRAFT
THAT STARTED WITH THE
AEA vice president
of government and
agency's needs and desires, all federal agencies must use technical standards developed and adopted by voluntary consensus
standards bodies. The act's specifics are compiled in OMB Circular A-119, which makes the National Institute of Standards and
Technology responsible for coordinating conformity.
Those who have been involved in the rewriting of Part 23
expect few, if any, surprises, but that won't be a fact until the
FAA publishes the Part 23 notice of proposed rulemaking. The
FAA said it would publish the NPRM by the end of 2015, Peri
said, but the congressional push for the FAA to address safety
concerns posed by the expected yuletide swarm of unmanned
aircraft systems may have contributed to the delay.
Realistically, the rewritten Part 23 will have little if any effect
on avionics installations, the primary source of business for most
shops. "Technicians will still rely on the manufacturers' installation manuals and applicable STC documentation," Peri said.
Things will change for those who seek supplemental type certificates. "The STC process will not change, but when aircraft
certificated under the new Part 23 enter the fleet, compiling an
approved model list may become more complex," he added.
In creating the AML, STC holders must ensure that the installation conforms to all of the standards used to certificate all of
the aircraft on the list, Peri explained. "As an STC holder must
do today, new STCs must show conformity to the latest standard
revision with downward compatibility, and that won't change."
This is where consensus standards come into play.
Succinctly put, before the rewrite, Part 23 established safety
requirements and embedded the prescribed method of compliance in the same rule. Because they are part of the rule, updating
methods of compliance must follow federal rulemaking guidelines of checks and balances, which is why affecting change
takes so long. Cockpit Wi-Fi systems is the example that came
immediately to mind. "It took the FAA's transport aircraft directorate more than 10 years to move from new and novel technology to publishing an advisory circular to address it," Peri said.
Consensus standards are more dynamic, according to Peri.
Depending on the complexity of the objective it must meet, "the
consensus organization can develop a clean-sheet standard in 18
months; add another six months or so for the FAA to acknowledge the new consensus standard as an acceptable method of
The misunderstood relationship between FAA safety standards or objectives and the consensus standards that describe
their AMOCs may be a primary cause of Part 23 rewrite anxiety. For many, consensus standards became part of their professional consciousness with the introduction of light-sport aircraft
in 2004. This is not an accurate template for the new Part 23 because the FAA took a hands-off approach with LSA, according to
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