Avionics News September 2017 - 11

with the broadest market; and easier purchasing decisions
by the consumer. The bottom-up approach that is
fundamental to the new paradigm does just the opposite.
While it allows for the introduction of transitional
products, those products are part of the continuum from
EAB to classes 1 and 2 of Part 23. This does not open
the market to larger and more complex aircraft. The
products are designed and approved with a specific
limited applicability, and it puts a lot of pressure on the
consumer to know, understand and accept the intended
purpose and limitations of the new products.
This is not new. In February 2014, two years before
the EAA's STC announcement at Sun 'n Fun, the FAA
published a policy mapping the approval process for
supplemental angle of attack indicators - FAA Memo No.
AIR100-14-110-PM01: Approval of Non-Required Angle
of Attack Indicator Systems. Many of the traditional
avionics manufacturers took advantage of this policy
or portions of the policy to design, certify and market
AOA indicators to the general aviation community as
supplemental "non-required" information to enhance
pilot safety by providing more and often better
information than traditional stall warning systems.
The 2014 AOA policy migrated and mutated into the
FAA's 2016 policy on the Approval of Non-Required
Safety Enhancing Equipment, or NORSEE, (Policy No.
PS-AIR-21.81602). In addition, the 2009 revision to 14
CFR Part 21 set the groundwork for the scalable riskbased approach to production certificates and quality
systems that many of this year's new product entrants are
utilizing. And finally, the rewrite of 14 CFR Part 23 was
not effective for another month after AirVenture 2017,
so not even the changes to Part 23 were the cause of
these changes. In fact, the only thing to truly change was
attitude and the willingness of the applicant to read the
regulations, defend their rights to follow the regulations,
and their willingness to produce products with limitations.
As I stated previously, this puts a huge burden on the
consumer and avionics shops to know and understand
the application and limitations of the products they buy
and sell. For the international consumer, many (if not
all) of these products are not covered under any bilateral
safety agreement, and therefore, may not be recognized
as an aviation product by their civil aviation authority.
If they are recognized and accepted by the international
authority, you may have to develop and certify the
installation without the benefit of the TSO'd data.
As has been said since the early 20th century, there
ain't no such thing as a free lunch.

Aircraft Certification Service
(AIR) Transformation
For the past three decades, the FAA's Aircraft
Certification Service has been organized into the executive
and deputy executive directors, the executive technical
support staff, the alternative fuels program staff, divisions
of four directorates and, of course, Aircraft Certification
Offices and Manufacturing Inspection District Offices.
Many of us in the industry have worked closely with the
directorates and the local ACO and MIDO.

The only thing to truly change was attitude
and the willingness of the applicant to read
the regulations, defend their rights to follow
the regulations, and their willingness to
produce products with limitations.
The transformed AIR structure will retain the executive
leadership, support staff and fuels program but will combine the
management structure of the former division and directorates
into six functional divisions: Organizational Performance
Division, AIR-300; International Division, AIR-400; Policy and
Innovation Division, AIR-600; Compliance and Airworthiness
Division, AIR-700; System Oversight Division, AIR-800; and
Enterprise Operations Division, AIR-900.
Being dismantled in the process are two divisions:
Design, Manufacturing, and Airworthiness Division (AIR100) and the Planning and Program Management Division
(AIR-500), as well as all four of the directorates: Engine
and Propeller; Rotorcraft; Small Airplane; and, Transport
Airplane.
All the functions below the level of the directorates are
structurally unchanged, or at least relatively unchanged.
The benefit will come from consistency. All the ACOs
now fall under the same single leadership umbrella
(Compliance and Airworthiness Division (AIR 700)). This
should greatly help with consistency from one ACO to
another and especially from one region to another.
Instead of arguably five different policy sources
(headquarters and four directorates), there is now a single
policy division (Policy and Innovation Division, AIR-600).
It is not clear how it will handle product-specific policies
such as rotorcraft and engines, but we remain optimistic.
Continued on page 69
avionics news

september

2017

Table of Contents for the Digital Edition of Avionics News September 2017