Change can be good, but in the case of the current FAA notice of proposed rulemaking NPRM) regarding FAR Part 145, Aircraft Electronics Association president Paula Derks cautions NBAA’12 attendees to watch out. “This proposal makes wholesale changes to the avionics industry with damaging and costly repercussions,” she said. “At a time when avionics and electronic systems are interfaced with every mechanical system on the aircraft, the FAA proposes to remove radio and instrument ratings and allow airframe-rated repair stations to work on electronics without adequate oversight,” she continued. In her opinion the NPRM, if it were made a rule in its current form, would roll avionics back to the 1930s.
The most onerous section of the rule is its requirement to re-certify all 4,000 currently certified avionics repair stations within a 24-month implementation period. Derks doubts that the FAA can accomplish such a task with present staffing. Beyond that, the rule reduces the number of avionics repair ratings to five from eight, and allows airframe-rated repair stations to repair and alter radios and instruments without any specific ratings or qualifications. It would also require radio repair stations to have “permanent housing” as opposed to the current rule, which requires a “fixed location.”
AEA (Booth No. 2591) is encouraging NBAA attendees to comment on the NPRM before the November 19 deadline by visiting www.regulations.gov and searching for faa-2006-26408-0211. To discuss the changes with Derks or other AEA representatives, stop by their booth (No. 2591) and while there you can pick up the organization’s 2012-13 Pilot’s Guide to Avionics.