Avionics News May 2018 - 13

These products - all of these products - ARE NOT "non-certified!" If they
are approved via a supplemental type certificate, they are certified; if
they are approved via parts manufacturing approval, they are certified;
if they are approved via the aircraft type certificate, they are certified.
Just because these new products are not approved via technical standard
order does not make them non-certified. They are certified; they are
simply certified using an alternative means.

representatives as well as the regulators. This was a passionate
group, working hard to push the envelope; to change the status
quo; to promote the installation of safety-enhancing equipment. The working group contained familiar names such as the
Aircraft Electronics Association, the Aircraft Owners and Pilots
Association, and the Experimental Aircraft Association, along
with the industry represented by aircraft, component and avionics manufacturers, and a couple of noteworthy general aviation
advocates from the FAA's Small Airplane Directorate and the
Chicago ACO.
The early meetings were challenging. All options were on
the table - some form of experimental designation for the
legacy fleet; and a new certification standard called "noncommercial aircraft" (similar to the Canadian Owner Maintenance
classification). But throughout the discussions, the solution kept
coming back to some grandiose change in philosophy where
the FAA would either be completely hands off recreational
aircraft or a completely new category of aircraft. Both options
would require extensive rulemaking. While the solution seemed
to be quite complex, the desire was actually quite simple: The
FAA wanted to enhance safety for the legacy - primarily recreational - aircraft fleet; the owner/operator groups wanted a
pathway to bring the exciting new technologies visible in the
experimental, amateur-built aircraft community into their certified aircraft; and OEMs were frustrated that they were not able
to satisfy their customers who were filling their information
needs with handhelds, iPads, and portable avionics.
Throughout the discussion, I kept reminding people that the
current regulations allowed them to achieve their goal. After a
few months of these discussions and then vetting and rejecting
every proposed option, I started presenting the current regulation - the broad spectrum of options currently contained within
the regulations that, in many cases, provided the solution to
everyone's desire for modernization of the legacy fleet. It only

required the applicant to use the regulations and the agency to
accept the regulations.
Now that this market is starting to take off and manufacturers are embracing this "new market," it's time for me to emerge
from the shadows. No, I don't produce parts nor do I certify
new products; I simply do what I do for all AEA member companies: I read the regulations, I promote the regulations, and I
encouraged both the regulators and the manufacturers to use
the regulatory tools that were already in the tool box but were
underutilized thus far. After years of debate, the regulations
finally prevailed.
My part in this progression? I'm simply the geek who read
the regulations. The consumers already had the demand; the
manufacturers already had the desire; all I did was find the regulatory path to bridge the two. Nonetheless, I've been promoting and encouraging the use of the regulations and the options
they provide since the beginning, and it's great to see this new
market grow.
Let's be clear: There are no new regulations that allowed for
this cosmic shift. It did take a cosmic attitude shift; however,
most of the regulations that support these new products have
existed for decades and have supported thousands of modification and replacement parts - they just were not used in the
avionics sector. Contrary to some heated discussions, there are
not any new "lesser" certification standards. The standards are
exactly the same, it is only that the methods of compliance
have been re-evaluated to better reflect their intended use.
In our understanding of these new products, we should start
with a bit of "fake news" - that these new products are noncertified. These new products, are, in fact, certified; they are just
certified differently. They are certified using more appropriate
(for the intended application) alternate methods. In most cases,
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avionics news

may

2018

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