The Aircraft Electronics Association (AEA) has taken issue with the new Advisory Circular 66-1 proposed by the Civil Aviation Authority of New Zealand. The draft AC describes an acceptable means of compliance to enable issuing aircraft maintenance licenses, certificates, and ratings, but in comments to the CAA, the AEA said it disagrees with the way it is written and wants it withdrawn.
In a letter submitted to the CAA, the AEA said that the AC establishes “regulatory limitations not intended in the regulation.” For example, “The broad-based definition of avionics used is far beyond the intent to support a classification of complex avionics. The AC randomly combines all types of Electrical, Instrument, and Radio (EIR) [components] into a broad definition of avionics.” Leveraging this definition to define complex avionics as any integration of EIR systems as viewed in the eye of the CAA at the time of type acceptance is “not a regulatory basis for type training.”
The aviation electronics industry and the CAA have always relied upon the existing “qualifications” requirements to assure that the technician responsible for maintenance and return to service was properly trained, qualified, and authorized to perform the specific task, AEA said. “Unfortunately, without the benefit of close coordination with the current industry, many of the apparent assumptions used in the development of this advisory circular are based on false logic,” and it “is simply not acceptable.”