Avionics News June 2016 - 18

INTERNATIONAL NEWS
Continued from page 17

FREQUENTLY ASKED QUESTIONS
United States
Repair station ratings
The following information is from the Federal Aviation
Administration legal interpretations.

Question:

Which ratings must an FAA-certificated repair station
hold in order to perform the altimeter-related tests and
inspections required by § 91.411(a)?

Answer:

In a March 22, 2012, answer to a response to a
request for a legal interpretation on which ratings
an FAA-certificated repair station must hold in
order to perform the altimeter-related tests and
inspections required by § 91.411(a).
Section 91.411 (b) The tests required
by paragraph (a) of this section must be
conducted by*****
(2) A certificated repair station properly
equipped to perform those functions and
holding(i) An instrument rating, Class 1.
(ii) A limited instrument rating
appropriate to the make and
model of appliance to be tested.
(iii) A limited rating appropriate
to the test to be performed.
(iv) An airframe rating
appropriate to the airplane, or
helicopter, to be tested.
According to the FAA's answer:
Under the current regulations, a repair
station with an appropriate instrument
rating does not need an associated
airframe rating to install, inspect or test
the instrument worked on when it is
installed in an aircraft.
While those privileges are not clearly
set forth in current 14 CFR § 145.59(e)

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2016

describing the instrument ratings for FAAcertificated repair stations, they were
privileges associated with those same
ratings via appendix A before the repair
station rules (14 CFR Part 145) were
amended in 2001. For example, among the
job functions authorized by that appendix
for a Class 1 instrument-rated repair
station were:
(ii) Maintain and alter instruments,
including installation and replacement of
parts;
*****
The function of installation includes
fabrication of instrument panels and other
installation structural components.
*****
(iii) Inspect, test and calibrate instruments:
Perform these functions on instruments listed
under paragraph (e)(1)(i) of this appendix, on
and off the aircraft, when appropriate.
When the FAA amended Part 145 in 2001
(66 FR 41088, Aug. 6, 2001), appendix
A was withdrawn because of comments
pointing out the difficulty of keeping
current an appendix that lists job functions
and associated equipment requirements.
The 2001 rule also retained the previous
rating system with no changes. (See 66 FR
41088,41097, Aug. 6,2001.)
Accordingly, the FAA did not intend to,
nor did, make any substantive changes
to the job functions/privileges afforded
repair stations by the previous appendix
A. Indeed, the job functions set forth in
appendix A had been in place since at
least 1962, with only two amendments to
the appendix over the years, the last one
occurring in 1982, more than 30 years ago.
While the issues you raise may not be
definitively clear from reading the current
ratings regulations in isolation, the
agency cannot unilaterally, by guidance
or otherwise, make substantive changes to
repair station job functions/privileges that
have been long-standing without notice
and comment rulemaking. q
Table of Contents for the Digital Edition of Avionics News June 2016
