AEA Submits Comments on FAA's Part 145 Rewrite

The Aircraft Electronics Association recently objected to the Federal Aviation Administration's notice of proposed rulemaking (NPRM) for Part 145 repair stations in comments submitted to the FAA by the Nov. 19 deadline.

To read the AEA's comments, click here. To read the AEA's section-by-section analysis submitted as an attachment with its comments, click here.

On May 21, the FAA proposed a significant rewrite of the repair station regulations. The proposal called for wholesale changes to the avionics industry with damaging and costly repercussions.

After the NPRM was issued last spring, the AEA immediately developed a written comparative analysis of the proposed rule and conducted three informational webinars designed to educate AEA member businesses on the potential changes coming to their Part 145 operations. The webinars also helped members prepare and submit comments.
In addition, the AEA provided continuous educational updates on the issue to its members and gave briefings at each of the AEA Regional Meetings conducted in the U.S. in September and October. The association also established an online educational resource on the NPRM at As a result of these combined efforts, several hundred comments were submitted to the FAA from the general aviation industry, including comments from many AEA members echoing the association's overall concerns with the proposed rule.

"I want to personally thank each of the AEA members who took the time to submit comments to the FAA on this NPRM," said Paula Derks, AEA president. "It is important for the AEA and its members to be heard on issues with direct consequences to our businesses and our industry. Many AEA members voiced serious concerns with a proposal that would remove radio and instrument ratings and allow airframe-rated repair stations to work on electronics without adequate oversight. The message sent by the industry to the FAA was loud and clear: This proposal did not reflect current repair station aircraft maintenance and business practices, or advances in aircraft technology. We look forward to following up and working with the FAA on this issue."

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.