FAA Proposes a Significant and Potentially Damaging Rewrite of Part 145

SUMMARY: 
This proposal makes wholesale changes to the avionics industry with damaging and costly repercussions. The Federal Aviation Administration proposes to remove radio and instrument ratings and allow airframe-rated repair stations to work on radio and instrument components without qualifications or ratings. In addition, the proposal eliminates many of the currently utilized opportunities for mobile maintenance operations. (Repair Station NPRM)

MAJOR HIGHLIGHTS:

Under this proposal, the system of ratings would be reduced from eight ratings to five ratings. The ratings definitions would be revised to clearly indicate the type of work that a repair station is authorized to perform. A comparison of the proposed ratings with the current ratings follows:

 

Current
Proposed
Airframe Class:

1. Composite small.
2. Composite large.
3. All-Metal small.
4. All-Metal large.
Airframe Category:

1. Aircraft certificated under Part 23 or 27.
2. Aircraft certificated under Part 25 or 29.
3. All other aircraft.
Powerplant Class:

1. Reciprocating engines of 400 HP or less.
2. Reciprocating engines of more than 400 HP.
3. Turbine engines.
Powerplant Category:

1. Reciprocating engines.
2. Turbine engines.
3. Auxiliary power units.
4. All other powerplants.
Propeller Class:

1. All fixed & ground-adjustable.
2. All other propellers.
Propeller Category:

1. Fixed-pitch & ground-adjustable propellers.
2. Variable-pitch propellers.
3. All other propellers.
Radio Class:

1. Communication.
2. Navigation.
3. Radar.
Component.
Instrument Class

1. Mechanical.
2. Electrical.
3. Gyroscopic.
4. Electronic.
Component.
Accessory Class:

1. Mechanical.
2. Electrical.
3. Electronic.
Component.
Limited rating specialized service. Specialized service.

 

This proposal would not require a capability list, but would revise the capability list recording requirements for those repair stations that choose to use one. This is a potentially marked change for repair stations with class ratings that do not currently have a capability list of the items they maintain.

A certificated repair station with an airframe rating is not required to obtain a separate component rating to maintain articles associated with its rating and capabilities. This provision would allow airframe-rated repair stations to repair and alter radios and instruments without any specific ratings or obvious qualifications.

Each certificated repair station must provide and maintain suitable permanent housing for the facilities, equipment, materials and personnel consistent with its ratings. It appears this provision would prohibit mobile operations. Currently, the regulations allow for a permanent "fixed location" but not permanent housing.

Comments are due no later than Aug. 20, 2012.

AEA COMMENTARY:

The Aircraft Electronics Association is thoroughly investigating the NPRM and will respond to all members with our commentary within the next two weeks. Since comments are due before the start of the AEA domestic Regional Meetings, the Association will be leveraging our normal communication mediums, as well as Web-based sessions. The membership should watch the AEA Wired e-newsletter and the AEA website for more communications and upcoming schedules.

FOR MORE INFORMATION:
Contact Ric Peri, vice president of government & industry affairs for AEA, by email at ricp@aea.net or by phone at 202-589-1144.

Regulatory