Avionics News April 2012 - 17

the AEA provides more than 100 hours of training each year: technical, regulatory and business, with both live and online training options. the avionics inspectors need the training. the FAA inspectors are welcome to attend any and all of the training offered by the AEA.

no two identical repair stations. But, there is room for improvement. One of the best ways to promote consistency is to promote communications. When a repair station asks “why,” it is not an affront to the authority of the ASI. Rather, it is exactly what is asked: simply a why? Shops shouldn’t have to “pick their battles” to challenge and understand their inspectors. I mitigate a lot of disputes between shops and inspectors. Usually, it is a breakdown in communication resulting in inconsistencies. By the time an AEA member calls me, both the shop and its inspector have reached the breaking point, and almost always, it’s about communications. The shop believes it is operating correctly; it has been operating like this for years, and the inspector wants it to change its manuals to reflect “new guidance” of the regulations. A common issue is the new inspector doesn’t like what the old inspector approved in the repair station manuals and “requires” changes to be made. I thought we had this resolved 10 years ago, but it is rapidly digressing to where we were in 2001. Generally, it has been my experience that the new inspector is more correct than the old inspector. But, right or wrong, it is the small business that

must pay the price. The constant editing of manuals is counterproductive, harmful to morale and a detriment to safety. The AEA recommended a supervisor review and provide oversight before a new inspector causes an administrative burden to an existing repair station. In addition, we asked non-regulatory edits be accomplished no more often than semiannually, while acknowledging that regulatory edits should be accomplished as soon as practical.

Field Approvals

The avionics industry still relies on field approvals. While the volume of field approvals has been reduced through the expanded use of approved model list supplemental type certificates, we still have not eliminated the need. With the beginning of NextGen approaching, the need shows no sign of diminishing. For the record, the AML STC policy was designed to leverage an existing tool to provide consistency to avionics installations previously approved via field approvals. Those installations are still technically no more complex than a major alteration and do not require an STC, as some FSDOs have suggested. Therefore, these installations should be eligible for a field approval. Again, a program that is better, but

not perfect, with room to improve. The recent change in FAA order 8900.1 regarding field approvals is a classic example of how we could do better. The change was well intended and well thought. However, it quickly became clear there were unintended consequences, which have cost our small businesses thousands of dollars. There are three issues worth discussing. First, what to do when we have unintended consequences; second, the value of the ability to challenge a decision to region or headquarters; and third, a realistic implementation time for policies, which result in changes. The concept that unintended consequences can be mitigated by administratively burdensome challenges is not realistic. In addition, when the challenges are not supported by the inspector, the shop is on its own, paying the price and taking valuable time away for revenue generating activities. When we have an unintended consequence to a policy, a procedure should be in place to rescind the order as soon as possible, so the unintended consequence can be resolved without causing undue financial hardships. While I appreciate the ability to raise issues to FAA headquarters, there is a
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Avionics News April 2012

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