The Federal Aviation Administration proposes to amend the maintenance regulations by removing from the preventive maintenance category the task of updating databases used in self-contained, front-panel or pedestal-mounted navigation equipment. This change would allow pilots who operate certificated aircraft to update the specified databases and eliminate the requirement for certificated mechanics or repair stations to perform the update. (NPRM)
The Aircraft Electronics Association appreciates the opportunity to comment on the recent Notice of Proposed Rulemaking on Pilot Loading of Navigation and Terrain Awareness Database Updates.
In general, the AEA supports the concept that commercial pilots should be able to load navigation and terrain awareness database updates. However, the AEA does not agree with the Federal Aviation Administration's proposed rule change. According to the AEA, the proposal does not reach its intended audience and compromises the maintenance regulations in the process.
The AEA suggests two additional alternatives that the agency should consider. First, § 43.3 could be amended similar to § 43.3(h) or (i) which could provide pilots operating under Parts 121, 129 or 135 the authority to perform preventive maintenance limited to Part 43 Appendix A, paragraph (c)(32).
The other option not considered is removal of Part 43 Appendix A paragraph (c)(32) and move the database updating responsibility to Part 91 under the general operating and flight rules. Should the responsibility and authority be moved to Part 91, the instructions and limitation could, therefore, be included in the aeronautical information manual.
So, to fully support aircraft operations regardless of the type of operations, the AEA suggests the agency adopt the latter option and expand the authority to include all air traffic control navigational software databases, regardless of the location of the portal, provided:
- No disassembly of the unit is required.
- The pilot has written procedures available to perform and evaluate the accomplishment of the task.
- The database is contained in a field-loadable configuration and imaged on a medium, such as a compact disc read-only memory, synchronous dynamic random-access memory, or other nonvolatile memory that contains database files which are non-corruptible upon loading, and where integrity of the load can be assured and verified by the pilot upon completing the loading sequences.
The agency needs to define what it means by air traffic control navigational software databases. When the original regulations were written, the navigation databases were limited to charts and frequency databases; however, today many databases include active terrain and obstacle information.
The AEA supports the agency's proposal that the data to be uploaded must not contain system operating software revisions.
In closing, the AEA generally supports the intent to allow pilots to install air traffic control navigational software databases, regardless of the type of aircraft operations. However, the AEA does not support this proposed regulation as written.
To read AEA's complete comments, click here.
FOR MORE INFORMATION:
Contact Ric Peri, vice president of government & industry affairs for AEA, by email at firstname.lastname@example.org or by phone at 202-589-1144.