Avionics News May 2017 - 12
In this monthly column, Ric Peri of the AEA's Washington, D.C., office, informs members of the latest regulatory updates.
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
here do you get your questions answered for
your business? Where do you find the questions
you didn't even know you had? Where do you
get your customers' questions answered?
As the 60th annual AEA International Convention & Trade
show concluded in New Orleans last March, those were the
questions I asked myself. Where do the AEA members find
their answers? With more than 100 hours of training; four
days of regulatory sessions; leaders from the Federal Aviation
Administration on-site for three of the four days; and every
avionics manufacturer in the exhibit hall and likely giving at
least one, if not multiple, training sessions on their products, I
expect you could get any question answered on-site.
It is important that the AEA provides answers to not only
satisfy the questions but also provide the references. Many
years ago, I was debating with an FAA office manager, with
whom I worked with nearly two decades, regarding certain
actions from an AEA member company. The member was
correct in its actions, and the aviation safety inspector was
misguided. But as I was debating with the office manager, she
asked, "Who is the company's compliance officer?"
How does your staff operate when you're not there?
The corollary is what information are you receiving at the
local level that needs to be verified. I try to attend three or
four local FAA A&P inspection authorization trainings each
year to hear and understand directly what AEA members are
hearing at the field level. Generally, this information, while
not always aligned with the current message from the FAA's
headquarters, is not necessarily wrong. On the other hand,
the information quite often generates questions about the
consistency of what you know or what you thought you knew,
and what you have been told.
For example, I recently attended an IA seminar where
the inspector spoke quite eloquently and with authority
about the management of inoperable equipment. He focused
on minimum equipment list compliance and completely
missed 14 CFR 91.213 (d). When questioned, the inspector
referenced that 91.213 (d) was used where an MEL does
not exist, and then cited the policy on MMELs that include
single-engine aircraft, and therefore, 91.213 (d) wasn't
applicable. He was confusing MELs and MMELs, and his
presentation was wrong. This leads us to trust, but verify.
According to an article in the Washington Post, "trust,
but verify" entered American usage when President Ronald
Reagan's adviser on Russian affairs, Suzanne Massie, was
preparing the president for talks with Mikhail Gorbachev in
1986. Perhaps Reagan ought to learn a few Russian proverbs,
Massie suggested, and the one he liked best was "doveryai,
no proveryai" - trust, but verify. Reagan liked it so much
that Gorbachev expressed annoyance with the president for
using it at every meeting.
Monday's AEA Regulatory Rise & Shine session during the
AEA Convention answered questions about what the FAA is
focused on and what the relevant regulatory changes are that
affect your business. With the risk-based approach the world
authorities are embracing, understanding this is critical to