Having spent the majority of my aviation career fixing problems on aircraft associated with systems incorporating wires and having been told on numerous occasions that I have an analytical mind and a creative thought process, I have had a recent revelation. In the eyes of the Federal Aviation Administration, I do not exist. Yeah, they know me because I have an Airframe and Powerplant (A&P) license but having a last name like Sparks seems to have prevented me from spending much time in the wheel and brake shop.
FAR Part 65 prescribes the requirements for issuing the following certificates and associated ratings and the general operating rules for the holders of those certificates and ratings: air-traffic control-tower operators, aircraft dispatchers, mechanics, repairmen, and parachute riggers.
I see no mention of avionics or electronics technician. In contrast, the European Aviation Safety Agency (EASA) has included in its Part 66 several categories describing the privilege of return to service. These include B1 and B2:
Category B1 aircraft maintenance license shall permit the holder to issue certificates of release to service following maintenance, including aircraft structure, powerplant, and mechanical and electrical systems. Replacement of avionic line replaceable units, requiring simple tests to prove their serviceability, shall also be included.
Category B2 aircraft maintenance license shall permit the holder to issue certificates of release to service following maintenance on avionic and electrical systems.
In addition to creating the ratings, EASA has also created an educational structure to ensure those rated have an understanding of what is required.
The FAA Airworthiness Inspectors Handbook Volume 2, section 235 defines the areas considered to be avionics.
Many aircraft currently under development use electronics to control everything from air conditioning to thrust reversers. In fact fly by wire is about to make its debut in a business jet within about a year. In accordance with Federal Air Regulation (FAR) Part 65:
65.81 General privileges and limitations
(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance, or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.
(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned.
Paragraph "b" content can have significant implication regarding how we dispatch future aircraft. Recently during a telephone conversation with an old friend who is planning to receive a "new generation" business jet in his fleet, the question of training came up. It seems the aircraft manufacturer has planned the maintenance course to include the basic airframe as the core of the program and will offer a five-day optional "avionics course" as a follow on. My friend wanted to know my thoughts on attending the course. I pointed out FAR 65.81 paragraph b. Avionics has taken on a whole new meaning in recent years and integration between airframe and engine systems with what used to be considered "cockpit stuff". In today's world replacing a circuit card used by an integrated system may in fact influence the operation of aircraft pressurization, wheel braking, or engine performance. In accordance with the regulations, a clear understanding of system integration and data paths is critical to safe return to service.
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