Avionics News May 2022 - 14

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 E A V I C E P R E S I D E N T O F G O V E R N M E N T & I N D U S T R Y A F F A I R S
'We are made
by history'
M
artin Luther King Jr. once said, " We are not
makers of history. We are made by history. "
While he, of course, was addressing society, I
suggest this is an appropriate quote for the work being done by
the FAA Aviation Rulemaking Advisory Committee, Part 145
Working Group. The repair station regulations worldwide do not
make history, but rather are built by the history of aviation.
The ARAC working group was tasked with reviewing all laws,
regulations and advisory material applicable to repair stations,
including a historical review. For those who have sat through the
regulatory classes at AEA events over the years, you know we
don't look at the regulations without reviewing the preambles to
the notice of proposed rulemaking and subsequently the final rule
to get the whole picture. The preambles will generally tell the
readers what the intent of a particular passage is. Should someone
ask important questions during the notice and comment process,
the preamble will answer those questions that often helps
focus the regulation's scope or intent.
It became apparent early in the review process that as the
Federal Aviation Administration has progressed from generation
to generation of staffing, the history and intent of the regulations
have been progressively lost as each new generation made its
mark on the regulations.
In preliminary report findings, the working group specifically
found that the agency's guidance for Part 145 applicants, certificate
holders and its workforce is contained in the following:
The origin of content of the repair station regulations dates to
14 avionics news * may 2022
the Aero Bulletins of the 1920s.
History of Part 145
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*
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1920s to 1930s - Airmail Act/Air Commerce Act (Aero
Bulletins) initial control of civil aviation design, production,
operations and maintenance.
1930s to 1960s - Production and maintenance regulations
increase with repair station regulations introduced as
CAR Part 52 (20 Aug. 1938).
1962 - CAR to FAR recodification (13 July 1962)
reportedly did not make any " substantive " changes to the
meaning and application of aviation safety regulations;
research does not support that assumption. (14 CFR Part
145, amendment 1).
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2001 - Major reorganization of 14 CFR Part 145 (6 Aug.
2001) (14 CFR Part 145; amendment 27).
2015 - Flight Standards transition to Safety Assurance
System and the use of the data collection tools that have
led to a focused surveillance of repair stations and the
loss of the historical performance-based intent of the regulations.
2022
- Current 14 CFR Part 145 is at amendment 31.
The 1962 transition from the Civil Air Regulations to Federal
*
Aviation Regulations (13 July 1962) included several substantial
effects on the implementation of the repair station regulations.
One of the most significant effects was the change from the
overall repair station guidance of Civil Aeronautics Manual 52,
which thoroughly defined the intent of CAR 52, including legal

Avionics News May 2022

Table of Contents for the Digital Edition of Avionics News May 2022