Suggests FAA Should Treat All Regulated Mechanics The Same

ANN has learned the Aircraft Electronics Association (AEA) -- which represents more than 1,300 aviation businesses worldwide, including repair stations -- has responded to the FAA's request for public comment regarding the air agency's proposal to increase the Inspection Authorization (IA) renewal period to two years. Although AEA agrees with the FAA's proposal, it nonetheless offered comments to the FAA... just not about the IA renewal period.

AEA's Ric Peri told ANN, "Because the FAA opened Part 65 up for comment, it gave us the opportunity to make recommendations we feel are important."

At the heart of AEA's comments to the FAA is the association's fundamental disagreement with differences in the way the FAA regulates maintainers working under Parts 65 and 145 of the Federal Aviation Regulations.

There are literally thousands of one-man shops around the country with individuals certificated as A&P mechanics under FAR Part 65. These individuals are required to obtain an IA to perform an annual inspection. But as the name of the certificate implies, there are only two ratings required: airframe and powerplant.

Organizations certificated under Part 145 are designated as repair stations, and the certification requirements they must meet are much more stringent. In fact, there are several ratings and sub-ratings, and a repair station must meet all requirements for a rating in order to perform maintenance on aircraft, powerplants or appliances to which the rating applies.

Yet, according to the FARs, the ordinary, run-of-the-mill, one-man repair shop can perform the same maintenance as repair stations. AEA asks why the disparity in certification requirements?

In its comments the FAA AEA states, "Currently, the FAA allows an A&P with Inspection Authorization -- which was issued based on documented experience on single-engine piston-driven airplane -- to approve for return-to-service a turbine-powered helicopter following the installation of the latest technology electronics system with little or no regulatory oversight."

AEA calls the FAA's current approach to return-to-service authority unacceptable in light of new airframe, powerplant and electronics technologies -- especially those those aircraft utilizing integrated electronics systems.

Conversely, says AEA, "As the next generation of A&P mechanics emerges without the skills to maintain legacy technologies, their knowledge, skills and abilities to approve for return-to-service older aircraft with wood structure or fabric skins will be greatly reduced."

Specifically, AEA proposes the FAA change Part 65 rules regarding certification of those holding inspection authorization to read the same as rules under Part 145. It would establish a rating system identical to that under which repair stations operate, and a mechanism allowing for part certification. In other words, an A&P may be certified to work on only those aircraft, powerplants, propellers, parts or appliances for which he or she is rated -- just like a repair station.

AEA recommends the FAA divide Part 65 airframe ratings to four classes:

• Class 1: Composite construction of small aircraft
• Class 2: Composite construction of large aircraft
• Class 3: All-metal construction of small aircraft
• Class 4: All-metal construction of large aircraft

Powerplant ratings to three classes:

• Class 1: Reciprocating engines of 400 horsepower or less
• Class 2: Reciprocating engines of more than 400 horsepower
• Class 3: Turbine engines

Propellers ratings two classes:

• Class 1: Fixed-pitch and ground-adjustable propellers of wood, metal, or composite construction
• Class 2: Other propellers, by make

The changes as proposed, says AEA, will serve to closer align US regulation with that of the International Civil Aviation Organization.

As justification for its suggestions, AEA's posed the following question to the FAA: "Why should a business with a quality system, a reviewed and accepted business plan and an approved employee training program be regulated when 60,000 individuals without a quality system, a business plan or a training program have unlimited authority for return to service of aircraft, engines, and accessories?"

ANN asked Ric Peri how AEA would respond to the individual A&P who might feel AEA is attempting to limit his or her business. Peri said, "No more than the FAA limits the business of repair stations.

"We only ask that the FAA apply existing rules governing repair station certification across the board. If the FAA can make a set of sound safety arguments that apply to one [group], they should apply to both."

FMI: www.aea.net, www.faa.gov