The Aircraft Electronics Association is warning FAA-certified repair stations that they may be blindsided by a major revision of Part 145. In a podcast interview with AVweb, AEA spokesman Ric Peri said there seems to be widespread belief that the proposed rule (PDF) affects only repair stations that work on Part 121 air carrier aircraft. In fact, the rule applies to all Part 145 repair stations and would impose some major changes and expenses on the more than 4,000 shops it covers. "This proposal applies to all repair stations regardless of its customer bases," Peri said. AEA staff will man a booth at NBAA in Orlando starting Tuesday to try to correct the apparent misconception that is so prevalent that some FAA inspectors also have the wrong impression of the rule's breadth. Public comments on the Notice of Proposed Rulemaking (NPRM) close Nov. 19.
AEA has some major beefs with the proposed rule itself. AEA President Paula Derks said the revisions virtually eliminate the avionics trade and will allow airframe mechanics to work on and sign off on radio and instrument installations and repairs. "At a time when avionics and electronic systems are interfaced with every mechanical system on the aircraft, the FAA proposes to remove radio and instrument ratings and allow airframe-rated repair stations to work on electronics without adequate oversight," she said. The rule also requires repair stations to rewrite their repair station manuals and gives a 24-month window for companies to be recertified under the new regime, although the FAA hasn't said how it expects to review and inspect 4,000 shops in that time, given the already critical shortage of FAA certification staff. "With the current lack of FAA workforce and sequestration initiatives, how will the agency approve and reissue certifications to 4,000 repair stations in a 24-month period?" Derks said. "Without the FAA's ability to service an application in a timely manner, businesses will close."