Avionics News June 2013 - 14

In this monthly column, Ric Peri of the AEA’s Washington, D.C., office, informs members of the latest regulatory updates.

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A EA 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

Regulations Need a Diet!

K, so this seems a bit obvious. But this is exactly
what most, if not all, of the discussion about the
Part 23 Aviation Rulemaking Committee has
included. How do we get rid of the flab, tone the muscle
and increase its endurance?
There have been three primary areas of focus on the ARC’s
activity. While I do not wish to comment on the ARC report,
there has been a significant amount of outreach with this effort.
And based on the comments I have received from Aircraft
Electronics Association members, some level of explanation
may be in order.
The first area of focus is the regulation itself: Title 14 of the
Code of Federal Regulations Part 23. As a founding member
of the regulations, Part 23, through its many varied iterations,
can trace its lineage to the Air Commerce Act of 1926. If you
do some quick math, you realize the regulations that we design,
build, modify and maintain general aviation aircraft to are built
upon a nearly 90-year-old foundation. Age, in and of itself, is
not a negative. But like most of us, as the regulations passed 40,
they started to get a little pudgy around the middle.
For the first 40 years, the Civil Aviation Regulations were
trim, performance-based regulations that served the birth and
growth of general aviation well. On Dec. 31, 1964, the Federal
Aviation Administration completed its codification of previous
aviation regulatory issuances into a single body of rules, the
Federal Aviation Regulations. This consolidated and simplified
the former Civil Air Regulations, Civil Aeronautics Manuals
and Regulations of the Administrator. This effort reorganized
and streamlined the regulations to eliminate duplicate, obsolete
and unnecessary provisions of multiple regulatory systems
inherited from the earlier Civil Aeronautics Board and the Civil
Aeronautics Administration. That last major reorganization of
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the regulations was 50 years ago, or a half-century.
During the past 50 years, the agency has added 62 amendments to the regulations. Some amendments dealt with safety
gaps from the original standards, while other amendments dealt
with new technologies that simply were not available in the first
40 years. To put 1964 into perspective:
• The FAA certificated the first civil helicopters for instrument flight rules operations.
• The first U.S. light twin-engine turboprop business aircraft to be type-certificated received type certification.
• The FAA published a report that crash locator beacons
could effectively aid in the location of downed aircraft.
• The FAA issued a rule requiring cockpit voice recorders
to be installed in certain aircraft used by air carriers or
commercial operators.
• Pan American World Airways announced that inertial
navigation systems would be installed on most of its jet
aircraft.
A manpower study conducted by the FAA revealed an
approaching shortage of aircraft maintenance personnel. The
survey, “Report of 1962 Survey of Maintenance Airmen,”
revealed that only 3 percent of the total aviation mechanic
workforce was between 18 and 24 years of age, and relatively
few members of this age group were entering the aviation
mechanic career field. The survey found that many aviation
mechanics were discovering lucrative job opportunities in the
missile and space fields.
Imbedded in the 62 amendments to Part 23 are not only
regulatory safety standards, but also methods of compliance
and, in some cases, simple commentary. However, because
all of these are included on the pages of the regulations, they
have become mandatory, resulting in an inflexible, prescriptive

Avionics News June 2013

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