Avionics News May 2023 - 18

F R O M R I C
P E R I
AE A VICE PRE SIDEN T OF GOVERNMEN T & INDUS TR Y AFFAIR S
The Aircraft Electronics Association's international membership continues to grow. Currently, the AEA represents
avionics businesses in more than 40 countries throughout the world. To better serve the needs of the AEA's international
membership, the " International News and Regulatory Updates " section of Avionics News offers a greater focus on
international regulatory activity, international industry news and an international " Frequently Asked Questions " column
to help promote standardization. If you have comments about this section, send emails to avionicsnews@aea.net.
UNITED STATES
News & Regulatory Updates
AEA comments on SMS proposal
On April 11, 2023, the Aircraft Electronics
Association submitted comments on the Federal
Aviation Administration's notice of proposed
rulemaking to expand the applicability of safety
management systems. Technically, the NPRM is
proposing the expansion of 14 CFR Part 5.
As previously reported, on Jan. 11, 2023, the FAA
proposed to update and expand the requirements for
safety management systems and require certain certificate
holders and commercial air tour operators to develop and
implement an SMS program. Noticeably absent from the
NPRM was the inclusion of certified repair stations.
While absent from the direct effects of the NPRM,
the FAA did request comments and information
regarding a future rulemaking project to expand
the applicability of Part 5 to include repair stations
certificated under Part 145. Here are the AEA's
comments in their entirety.
The Aircraft Electronics Association (AEA)
as well as the Aeronautical Repair Station
Association (ARSA) jointly do not support the
FAA's proposed expansion of 14 CFR part 5 to
repair stations certificated under 14 CFR part
145. Together, the AEA and ARSA represent over
one-third of all FAA certificated repair stations.
While the membership of both associations is
18 avionics news * may 2023
passionate about safety, the addition of part 5 to the
extensive safety standards already governing repair
stations is redundant, expensive, and unnecessary.
The regulations governing repair stations already
require the highest level of safety. They require
every product worked on to be returned to a safe
condition. In addition, the regulations also require
continuous improvement. With respect to repair
stations, this notice of proposed rulemaking is a
solution looking for a problem.
The repair station industry represents
approximately 4,900 certificated Air Agencies,
roughly 10% of the repair stations are rated to
perform aircraft maintenance on transport category
aircraft, while approximately 20% additional
repair stations perform work on aircraft utilized
for commuter and on-demand operations. More
than half of the certificated repair stations are
small businesses with little to no direct impact on
commercial or international commerce.
The implementation of 14 CFR part 5 in 2015
was estimated to cost $135.1 million. According
to the FAA, " as of Jan. 6, 2012, there were 90
part 121 certificate holders. " This equates to an
implementation cost on average of $1.5 million
per air carrier. The FAA offset this excessive
implementation cost with perceived benefits from
provisions of the rule and any consequent safety
mitigation actions at $1.1 to $2.7 million.
While 90 part 121 certificate holders represents
less than 2% of the total repair station population,
extrapolating the FAA's implementation cost to
4,900 certificate holders, the cost would exceed

Avionics News May 2023

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