Avionics News December 2011 - (Page 14)

In this monthly column, Ric Peri of the AEA’s Washington, D.C., office, informs members of the latest regulatory updates. b y R I C P E R I V I C E P R ES I D E N T o F G oV E R N M E N T & I N D U ST Ry A F FA I RS Fo R A EA It’s Déjà Vu All Over Again s the end of the year approaches and we take a few minutes to reflect on the past 12 months, the words of Yogi Berra come to mind. Beyond all of the growth and accomplishments made during the past few years, this year in particular seems like, “It’s déjà vu all over again.” The economy continues to plague the industry. Politics, jobs, availability of finances: they all affect the demand for new avionics and the customer’s ability to invest in the upgrades. When you consider the three large general aviation states: California, Texas and Florida, the unemployment and home foreclosure rates in these states continue to show an undesirable environment for discretionary expenditures, which are typically used for recreational flying. As trying as the economy is, that is not what concerns me at the end of this year. What bothers me is the negative effect the Federal Aviation Administration is having on aviation’s economy. For example, in June, the FAA revised FAA order 8900.1 regarding field approvals. I spoke with the author of this policy when it was published. He made two important comments: This is temporary (and a dynamic guidance) and it only applies to field approvals. His position was acceptable, realizing that any restriction on field approvals will cost industry. The fact that technology is rapidly exceeding the capability for simple field inspector’s review of the data and subsequent approval does justify at least some restrictions on the local approvals. However, once this policy was used and tested in the field, it became clear that this well-intended policy reclassified many main stream avionics retrofits as a major change in type design requiring an STC. This is not the purpose of Flight Standards Information Management System policy – this policy is to tell FAA employees how the administrator expects his employees to oversee the public’s conformity to the regulations. This policy exceeded this intent and is a change in regulatory interpretation; one with a significant financial impact on the industry as well as the aircraft owners and operators, but also one with a direct negative impact on the voluntary equipage needed for NextGen. 14 avionics news A How many more aircraft are being parked because some bureaucrat in Washington signed onto an ill-conceived policy that increases the cost of aircraft ownership without enhancing safety? I find this to be frustrating and aggravating at the same time. Where are the principles of system safety, SMS and basic ISO 9000 in this process? You know, those basic management tenants that the agency touts at any and all public venues. These are not just slogans to pin to the cafeteria wall; they are century-old management tools to eliminate error, reduce redundancy and improve efficiency. To help you understand, let’s apply some of the same basic management principles that we apply to changes in our repair station manuals. Is the proposed change “acceptable to the administrator?” Remember, this is defined as conforming to the regulations. Does this policy conform to the regulations? Let’s look at one element of the policy: the sudden addition that the installation of multifunction displays requires an STC. § 21.113 Requirement for supplemental type certificate. (b) If a person does not hold the TC (Type Certificate) for a product and alters that product by introducing a major change in type design that does not require an application for a new TC under § 21.19, that person must apply to the appropriate aircraft certification office for an STC. From a regulatory perspective, do all MFD installations “introduce” a major change in type design? Section 21.93 provides the classification of changes in type design. According to the regulations, a “minor change” is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are “major changes.” Remember, this is the effect of the change on the type certificated product and based on earlier FAA guidance on what to consider when evaluating these six items. Since there is nothing in the regulations that support general MFD installations as a major change in type design, could it be that it is • december 2011

Table of Contents for the Digital Edition of Avionics News December 2011

Point of Communication
AEA Now
Before & After
The View From Washington
International News and Regulatory Updates
EFB Solutions
Member Profile
Homebuilders
The Top Avionics Sellers for 2011
A Conversation With...
Alphabets Advocating for Aviation
Meet the AEA Board
Member Profile
Business Basics
Theory & Practice
Meet the AEA Staff
Advertisers Index
AEA Members Make Headlines at NBAA Convention
What's New
Marketplace Classifieds

Avionics News December 2011