It’s a new year. The celebrations areover. Thoughts of the New Year’sresolutions are in the fore thoughts

of businesses throughout the world.And what are yours?

Many businesses begin the yearwith a house-cleaning; they start theNew Year by cleaning out the clutterfrom the previous year. Maybe youplan the year with a brainstorming ses-sion to see how your business canoperate more efficiently, improve pro-ductivity, decrease costs and increaseprofits.

Your Association worked very hardover the past few years to provide youwith more tools so that you can tuneyour business to best suit the businessmodel you designed. Whether you area repair station performing mainte-nance and repair of avionics systems,an installation shop or the manufactur-er of new technology equipment, 2003was a good year.

But just like the technician who hasdone things the “old” way for decadesand is hesitant to explore those ‘new’tools, today’s businesses have to makethe decision to utilize the businesstools that have been made available.And just like the transition from theold way to the new way, training takestime but is an investment in tomor-row’s efficiency.

Like any new tool, these businesstools may improve efficiencies whenused in the right application but maybe cumbersome and time consumingin the wrong application. Each busi-ness needs to evaluate these businesstools that the Association has brought

to the table and determine which oneswill improve your efficiencies andwhich ones really don’t fit your partic-ular application.

14 CFR Part 145 is the regulationthat governs the management anddesign of a repair station. Over thepast decade or so, the regulations andguidance published by the FAA haddeteriorated to the point that the localoffice was needed to make more andmore individual determinations.These individual determinations tend-ed to be more prescriptive than theother parts of the regulations. Therevised Part 145 was published in2003 with a number of changes thatadded business tools to your tool box.

The remake of the Part 145 regula-tions resulted in updating both the reg-ulation and guidance material so thatthe instructions that guide the dailyoperations of a repair station are per-formance based and less prescriptive.In addition, while the local authoritytended to inject a certain amount ofpersonal preferences into the “older”prescriptive approach to repair stationmanuals, the “new” performancebased approach to Part 145 manualsshould minimize if not totally elimi-nate the local authority’s personalpreferences. (Remember, the newRepair Station Manual and QualityControl Manual must be acceptable tothe Administrator; they do not have tobe accepted by your local inspector.)

These changes should help therepair station better manage theiradministrative burden imposed by thelocal inspector better. Typically, it is

the prescriptive elements of an inspec-tor’s personal preference (or inspec-tor’s advice) that generate the revi-sions to the repair station manuals. Tokeep the repair station from fallingprey to these personal preferences,under the revised Part 145, the localinspectors must provide the repair sta-tion with a written description of howthe repair station manual does not con-form to the FARs. If the inspectordoes not provide the repair stationwith this written notice to correspondto any deficiencies they found, the rec-ommendation from the inspector isthat of a well-meaning associate, takeit as such and evaluate the recommen-dation as you would from any otherwell-meaning associate.

One of the more efficient tools thatPart 145 introduced to the repair sta-tion is their ability to manage technicaldata and manual requirements ratherthan the older “one-size-fits-all” “keepeverything current at all times”approach of the old 145. Previously,every manual in a repair station’s tech-nical library was required to be keptcurrent all of the time. Under the pro-visions of the new 145, technical dataneed only be current when the work isbeing performed. This allows a repairstation to manage their technicallibrary in a manner that best suits theirbusiness model; those manuals that areoften used can be kept current all ofthe time while the seldom used manu-als can be updated when needed.

The need to maintain special toolsand test equipment requirements nowtends to follow the logic of the techni-

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The View from WashingtonB Y R I C P E R IV I C E P R E S I D E N T , A E A G O V E R N M E N T & I N D U S T R Y A F FA I R S

AVIONICS NEWS • JANUARY 2004 15

cal library requirements. The repairstation needs to determine the mostefficient way to manage special toolsand test equipment then establish aprocedure to manage these tools andequipment. If it is more efficient forthe repair station to rent requiredequipment rather than purchase it out-right, the new 145 supports this deci-sion. And like the technical library, itis not a “one-size-fits-all” approach,the repair station determines how bestto manage their tools and equipment(while still complying with the tool,equipment and calibration criteria ofthe regulations), develop a manage-ment procedure, then follow the pro-cedures that they established.

The Association has worked veryhard over the past five years to ensurea repair station could develop a busi-ness plan that best suits the local busi-ness environment and that the repairstation tools would be available if theychose to use them. Over the past year,AEA has held no less than 14 individ-ual training sessions on these newtools and will continue to highlightsome of the new business tools that areavailable to AEA member repair sta-tions in the coming year.

Another area where 2003 broughtthe industry new tools was with alter-ations and equipment installations. Atno time during the recent past can Iremember a time when industry had somany tools available to use to assist inthe installation of new equipment.The FAAhas given us these options ifwe choose to use them.

The Field Approval process hasbeen streamlined, enhanced and sim-plified. Now before I get lots of e-mail questioning my logic, let me offerthat while industry has received thesenew tools (ways of performing fieldapprovals) it is a new process for notonly industry but also the field inspec-

tors. And like most of us, it is easier torely on those tools that we are mostcomfortable with rather than learninghow to use the new tools. In business,the company invests in new technolo-g y, processes and equipment andwhile some employees will gravitateto the new technology like moths to aflame, others reject it like vampires togarlic. It is the business that moveseveryone to the new technology sothat the business can reap the benefitsof their investment. Sometimes it’sthrough training and education; some-times by removing the old tools andonly providing the new tools; andsometimes it is by strict mandate.

The Field Approval process is basi-cally a new business tool both fromindustries perspective and from theFAA’s. Some field inspectors havegravitated to and embraced theimprovements in the field approvalprocess. Others have rejected it andhave insisted on following the oldway. And there is little internal over-sight of FAA inspectors to move themto the new philosophy. T h eAssociation has worked with FA AHeadquarters to provide theseimprovements, it is up to the businessto determine what is the best processto use and to bring their inspectoralong (kicking and screaming if neces-sary) to use the new tools that havebeen made available. The industry istransitioning from a re-active equip-ment-supplier industry with an anti-quated approval process to a pro-active technology marketing industrywith a dynamic and efficient approvalprocess. Don’t let your employees (orinspectors) who are comfortablylocked in the ’80s keep you and yourbusiness from utilizing these enhancedtools to install the latest technologiesin today’s cockpits.

The enhanced field approval

process provides for better evaluationsof alterations which should result inmore alterations that can use accept-able data and fewer applications forinspector’s approval of alteration data,more consistent results from interac-tion with the local FAA offices, fewerdenials of properly documentedrequests and a better overall process.Like the introduction of new tools andequipment, the business doesn’talways see immediate cost savings,but through learning how to use thetools correctly the business should seeefficiency improve and costs go downand the end result is improved prof-itability for the business.

These tools and other minor busi-ness tools that were introduced during2003 have been highlighted at AEA’sAnnual Convention and RegionalMeetings, the monthly pages ofAvionics News, and the as-neededAEA Regulatory Updates.

Over the past few years, theAssociation has been raising the baron the quality of training held duringthe annual convention and the region-al meetings. Last year’s annual con-vention provided four days of formaltraining programs that were reviewedand approved by the FA A for IArenewal and for AMT awards. Theseprograms included various 45 minuteproduct-specific training sessions,multiple one and two-hour regulatorysessions to bring the latest issuesa ffecting repair stations to light, anumber of four-hour sessions focus-ing on various regulatory and rule-making topics, and a full day of busi-ness related Maintenance ResourceManagement taught by FlightSafetyInternational.

The Association continued thefocus of the annual conventionthroughout the regional schedule with

Continued on following page

three full days of technician training.The regional meetings began withphase two of FSI’s MaintenanceResource Management, followed byproduct-specific training, a review ofthe latest regulatory issues, and twoformal regulatory programs on evalu-ating alterations and a review of theprocedures for inspecting and repair-ing wiring and concluding with afour hour technician training pro-gram for Honeywell equipment.

Avionics News has always been avaluable source of information fortechnicians, but through continuousimprovement, your Avionics Newshas been recognized by the FAA as asource of formal technician trainingand a valuable source of informationand education for the management ofrepair stations. Repair station man-agement and quality staff should ben-

VIEW FROM WASHINGTONContinued from page 15

16 AVIONICS NEWS • JANUARY 2004

efit from the latest regulatory informa-tion and notification of FAA Nationalpolicies to the Frequently A s k e dQuestions with answers and referencesto long lost regulations and policies.

In addition to the regular features onregulatory issues AEA also publishesthe latest in Legislative activity thatmay have an effect on your business,whether it’s aviation legislation thatCongress is voting on, or a small busi-ness initiative to provide additionalresources to aviation small businesses,or a change in IRS deductions whichencourages making business purchas-es, or makes your customer’s purchas-es a better value, you’ll find the infor-mation in the pages of Avionics News.

Avionics News should be circulatedto every department of a repair stationand be an active part of management’smonthly review of government rules,regulations and policies. Av i o n i c sNews should also be included as part

of the repair station’s technician train-ing program.

Your association has been workingto improve the existing repair stationtools, the alteration tools that are usedto install the latest technologies andthe information tools used by yourcustomers to make critical decisions.We have been working to develop newtools for your business to use and toensure that you have the ability to useany appropriate tool in the daily oper-ation of your business that you chooseto use.

As you review these new businesstools remember that without propertraining the best new tool in the worldis nothing more than a poorly designedhammer without proper training. AEAprovides this training.

Have a healthy and prosperous NewYear..

Regulatory Update United States

Part 145This is a reminder that the deadline

for the delayed effective date of the“new” Part 145 is rapidly approach-ing. On September 29, 2003, the FAAannounced the delay of the effectivedate of the new Part 145 until January31, 2004.

The notice extended the effectivedate of the final rule amending 14CFR Part 145 along with certain pro-visions of Parts 91, 121 and 135 origi-nally published on August 6, 2001 at66 FR 41088 until January 31, 2004,except that the training programrequired by Section 145.163 retains

the original effective date of April 6,2005.

The Association was pleased theFA A approved A E A’s petition toextend the effective date of the newPart 145. AEA encourages its mem-bers to NOT stop working on theirRepair Station and Quality Controlmanuals and to submit them to thelocal FSDO at the earliest possibility.

Repair Stations who have notordered their copy of the AEA Part145 Manual Transition GuidanceWorkbook should order their copydirectly from the AEA website atwww.aea.net

ELTsThis is a reminder that back in

December 2000, the FAA published achange to Section 91.207 whichrequires most United States-registeredcivil airplanes to have an approvedautomatic type emergency locatortransmitter and that the previousexemption for turbojet-powered air-craft expires on January 1, 2004. Afterthat date, all turbine-powered aircraftwill also be required to have anapproved automatic type ELT.

Canada

Transport Canada Civil Av i a t i o n(TCCA) held an Av i o n i c sModification Workshop with theavionics modification industryNovember 26-27, 2003. This programwas the brainstorm of Barry Aylwardof Kitchener Aero and John Carr ofNorthern Airborne Te c h n o l o g y.Without their hard work this programwould have never been a success. TheAssociation thanks both of them.

Significant progress was made onthe following outstanding issues:

Combination FDR/CVRInstallations

TCCAhas agreed in principle that itwill be acceptable to install a single“Combi” FDR/CVR unit to meet CARoperational requirements for FDR andCVR installations in smaller rotorcraftand fixed wing aircraft. The cut-offpoints for aircraft size or seatingcapacity will be identified in advisorymaterial to be published by TCCAearly in 2004.

Approved Model List STCTCCA currently accepts FAA STCs

applicable to U.S.-manufactured air-craft, and therefore will accept withoutfurther review those FAA STCs withApproved Model Lists (AMLs) onsuch aircraft. TCCAwill issue adviso-ry material to indicate that installationof complex or multi-function avionicssystems using A M L STCs wouldrequire TCCA approval of any air-craft-specific installation aspects notcovered by generic installationinstructions included with the STC.Unless the aircraft-specific aspects canbe covered using Specified Data, aLSTC would be required.

AVIONICS NEWS • JANUARY 2004 17

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Frequently Asked QuestionsT O P I C : Federal Communication

Commission License

Contact: Ric Peri, AEA Vice President, Government & Industry Affairs601 Pennsylvania Avenue | Suite 900, South Building |

Washington, DC 20004phone: 202-589-1144 | fax: 202-639-8238 | ricp@aea.net

Q U E S T I O N : Does a technician need an FCC license to work on avionics systems?

A N S W E R : According to the FCC “you need a commercial radio operator

license to repair and maintain all aircraft stations and aeronauticalground stations including hand-carried portable units which are usedto communicate with aircraft.”

14 CFR PART 87 (FCC Regulations applicable to AviationServices), Section 87.73 requires that a general radiotelephone opera-tor must directly supervise and be responsible for all transmitteradjustments or tests during installation, servicing or maintenance of aradio station. And that a general radiotelephone operator must beresponsible for the proper functioning of the station equipment.

Section 87.69 does allow the licensee (aircraft operator) to makeroutine maintenance tests on equipment other than emergency locatortransmitters if there is no interference with the communications of anyother station.

The FCC defines most radio stations used in aviation as part of theAeronautical Mobile Service, which includes both airborne and landstations. Airborne stations, or aircraft stations, are simply those radiosthat are used in flight. They may be installed on board a plane, heli-copter, blimp or even a manned hot-air balloon. Airborne stations arefurther defined in the rules as air carrier aircraft stations, used in air-craft that carry passengers or cargo for hire; private aircraft stations;and flight test stations and aviation instructional stations. All airbornestations may transmit and receive only messages necessary for safeflight operations.

Land Stations include: Aeronautical Advisory Stations (also calledunicom stations); Aeronautical Multicom Stations; AeronauticalEnroute Stations; Flight Test Stations; Aviation Support Stations;Airdrome Control Stations; Aeronautical Utility Mobile Stations; andAeronautical Search and Rescue Stations.

Note: AEA offers these Frequently Asked Questions (FAQs) in order to foster greaterunderstanding of the rules that govern our industry. AEA strives to make them as accu -rate as possible at the time they are written, but rules change so you should verify anyinformation you receive from an AEA FAQ before you rely on it. AEADISCLAIMS ANYWARRANTY FOR THE ACCURACY OF THE INFORMATION PROVIDED. This infor -mation is NOTmeant to serve as legal advice – if you have particular legal questions, youshould contact an attorney.

Use of Specified DataTCCA is revisiting policy regarding

use of Specified Data for certain sys-tem installations. The recentlyapproved NPAs to CAR 571 are pro-ceeding to promulgation, and TCCAwill be seeking industry input to definethe scope of Specified Data that maybe used for certain avionics installa-tions, e.g. IFR GPS, CVR, PFD/MFD.

IFR GPS Installation ApprovalsTCCA has agreed to implement a

streamlined approach to approval ofIFR GPS installations, to allow maxi-mum use of Specified Data, and iden-tify revised requirements for FlightManual Supplement content andTCCA approval. There will still be arequirement to conduct a flight test todemonstrate system functionality.TCCAwill be meeting with AEAearlyin 2004 to finalize details of the newpolicy, and will then issue appropriateadvisory material.

Flight Manual Supplement(FMS) Delegation

T C C A is willing to considerapproval of FMS’by delegates (DARs,DAOs), for LSTC approvals on nor-mal category aircraft, where an AMLis not used. If the modification is per-formed using Specified Data, then theLSTC would only be for approval ofthe FMS. TCCA committed to devel-opment of guidelines for delegateapproval of FMS, and to revise theexisting FMS guidance material,including templates.

EMI/EMC Testing of AvionicsModifications

TCCA will publish a summary ofapplicable regulatory and advisorymaterial pertaining to EMI/EMC test-ing of avionics modifications, to assistin standardization of procedures acrossTCCAregions.

Replacement PrecisionInstrument Bearings

TCCA agreed to harmonize theirpolicy on acceptance of replacementprecision instrument bearings withthat of the FAA, as identified in FAAHBAW 98-19. To be acceptable, areplacement bearing must have TSO-C149 approval, and there must be astatement from the bearing manufac-turer stating that the replacement bear-ing is the same part as that supplied tothe instrument manufacturer. If theinstrument manufacturer alters the partnumber from the part number identi-fied on the bearing supplied to theinstrument manufacturer, then only theinstrument manufacturer’s bearing(with altered part number) may beused.

Instructions for ContinuingAirworthiness (ICA)

TCCA agreed with AEA’s proposalthat an ICA should only conveyunique maintenance or inspectionrequirements imposed by incorpora-tion of a modification, and that theICA should not be used to convey orrepeat generic data. Also, an ICAdoc-ument should not be necessary just toindicate that there are no ICAs. TCCAwill revise TP13850, MSI53 andACPL22 to adopt the proposedchanges to ICA requirements.In-Flight Entertainment Systems

TCCA is developing specific advi-sory and guidance material forapproval of installation of in-flightentertainment systems. This will besimilar to the FAA’s Interim PolicyGuidance issued 09/18/2000, and willalso be applicable to other non-required avionics systems.

Installation of Non-RequiredEquipment

T C C A proposes to classify non-required equipment into two cate-gories:

Category 1, for equipment installed

in the cockpit or interfaced to requiredsystems, and used to operate or main-tain the aircraft; and

Category 2, for in-flight entertain-ment systems, cabin electronics, gal-ley equipment, etc.

Advisory material will be publishedto identify acceptable methods ofcompliance to applicable airworthi-ness standards, and TCCA will workwith AEA to develop this materialearly in 2004.

Further information on the AvionicsModification Workshop may be seenat www.tc.gc.ca/CivilAviation/certifi-c a t i o n / e n g i n e e r i n g / a v i o n i c s / Wo r k s h op03/menu.htm ❑

Ric Peri Vice President, AEA Government & Industry Affairs601 Pennsylvania AvenueSuite 900, South BuildingWashington, DC 20004phone: 202-589-1144fax: 202-639-8238ricp@aea.net

18 AVIONICS NEWS • JANUARY 2004

REGULATORY UPDATEContinued from page 17