Avionics News March 2023 - 15

The employee qualification language of the federal
aviation regulations is consistent across all of the
regulatory authorities (as well as a fundamental business
practice).
" Each certificated repair station must provide qualified
personnel to plan, supervise, perform, and approve
for return to service the maintenance, preventive
maintenance, or alterations performed under the repair
station certificate and operations specifications. " (14
CFR 145.151 (b))
And it further states that the repair station's " training
program must ensure each employee assigned to perform
maintenance, preventive maintenance, or alterations,
and inspection functions is capable of performing the
assigned task. " (14 CFR 145.163 (b))
Basic business practice assumes that an employer
will evaluate their employee's training, knowledge, or
experience based on job positions, duties, and previous
tasks before assigning the person a task to accomplish
on behalf of the company. And yes, the " qualification "
standards are performance based.
On the other hand, the certification standards tend to
be prescriptive, well-defined, embedded in history and
not very flexible - and a constant point of discussion
from the regulatory perspective. Industry professionals
are looking for a certification that covers their basic
needs, while the authorities certificate to a defined
standard. The technicians, and often their families,
want a defined, appealing and successful career path.
Balancing these three demands can be challenging
anywhere, especially in the European Part 66 aircraft
maintenance license structure. For the past couple of
years, industry has presented to the Engineering and
Maintenance Technical Committee a request for a U.S.style,
task-based, repairman capability. At the same time,
the U.S. industry for the past couple of decades has
asked for a European-style aircraft maintenance license.
Now that Australia has adopted the European model for
licensing, it is developing a general aviation licensing
system like the Federal Aviation Administration system.
As the old adage goes: The grass is always greener on
the other side.
But when it comes to the authorities trying to support
what industry professionals think they want, industry
plays " bring me a rock " behavior, never trying the
solution that was presented. This is evident most recently
with the discussion in Europe regarding a general
aviation " maintenance " license.
The employee qualification language
of the federal aviation regulations
is consistent across all of the
regulatory authorities (as well as a
fundamental business practice).
The European Union Aviation Safety Agency, from
its inception, knew the regulations chosen to start the
pan-European aviation regulatory standards with the
joint aviation recommendations were air carrier centric.
As a result of the delayed applicability of EASA basic
regulations to general aviation, EASA has worked
continuously to better support maintenance of general
aviation aircraft.
Beginning in 2006, EASA published MDM.032
(multidisciplinary measures) titled, Regulation of
aircraft other than complex motor-powered aircraft,
used in non-commercial activities. Later that year,
EASA published A-NPA (advanced notice of proposed
amendment) 14-2006, a concept for better regulation
in general aviation (aircraft other than complex motorpowered
aircraft, used in non-commercial activities).
This NPA was the result of a multiyear, industry-led
working group to propose and implement a coherent
system adapted to the needs of the smaller end of civil
aviation. Revisions to Part 66 were a real part of this
activity. One of the questions asked during the A-NPA
process was the creation of a new level of license for
maintenance engineers in charge with general aviation
aircraft: a " light " Part 66 license.
EASA published Opinion 04/2009 on Dec. 11,
2009, which introduced the B3 license. The new B3
license is similar to the B1.2 but with simplified
requirements adapted to the lower complexity of
light general aviation piston-engine non-pressurized
airplanes of 2,000 kilogram MTOW and below. One
recommendation that accompanied the proposal for the
B3 license was a general aviation license for avionics
technicians. Originally labeled as a B4 license following
the same B1.2 to B3 format, B4 would be a general
aviation version of the B2 license.
An industry working group, led by the AEA, was tasked
with evaluating and developing a general aviation avionics/
Continued on page 46
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Avionics News March 2023

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