Avionics News January 2015 - 12

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
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

Form, fit and function
I
t was a simpler time when a simple avionics upgrade
only struggled with concerns like form, fit and
function.
It also was a simpler time when the regulating
agencies were kinder and gentler. Now this is not to
say that the kinder, gentler inspectors don't exist; they
certainly do. In fact, the vast majority of the Federal
Aviation Administration's workforce is there to better
the system through training, outreach and oversight.
Unfortunately, there also is a growing population of
"cops" interfacing with the public without adequate
oversight. To pretend this type of inspector doesn't
exist, or have an effect on the industry, would be a
disservice to both the industry and agency. What today's
cops are missing is a local sheriff to provide guidance.
As we continue to train and offer the tools for
evaluating major and minor classifications of
alterations, we cannot dismiss the ambitions of the
"cops." They are the single biggest factor in the high
cost of alterations. They only know the "letter of the
law" and believe they were hired and given a badge to
police the industry. They have no ability to evaluate an
alteration themselves and, as a result, they tend to drive
the "just in case" major alterations. The principles of
major and minor have not changed; what has changed
is that the "grey area" has grown wider - it's no longer
simple!
Generally, there are two modification terms you
must be familiar with: a change in type design and an
alteration. It is important to come to grips with this
12

avionics news

january

2015

terminology because they have different outcomes.
The challenge? The FAA's Flight Standards Service is
familiar with alterations, and its Aircraft Certification
Service is familiar with changes in type design. This was
not quite as clear before the Changed Product Rule was
published in early 2000, which highlighted a top-down
analysis of change.

The principles of major and minor have not
changed; what has changed is that the 'grey
area' has grown wider - it's no longer simple!
For modifications of most in-service aircraft, this
process usually begins at the highest certification level - a
supplemental type certificate. Then we deal with major
alterations and, finally, minor alterations. Interestingly, all
three certification levels evaluate the same six criterion.
All three levels of modifications are based on the
modification's effect on the (certificated) weight,
(certificated) balance, structural strength, reliability,
operational characteristics (alterations calls this flight
characteristics), or other characteristics affecting the
airworthiness of the product.
In 2002, the FAA defined these six characteristics and
what constitutes an appreciable change in FAA Order
8110.46. You can still find copies of this document on the
FAA's website under cancelled orders. The order did not
contain errors; rather, it was incorporated into the Field
Approval Job Aid, but with much more clarity.

Avionics News January 2015

Table of Contents for the Digital Edition of Avionics News January 2015