The Aircraft Electronics Association has just completed a 40-hour CASR Part 145 repair station training course in Cairns, Queensland, Australia. Taught by Ric Peri, AEA vice president of government and industry affairs, the course was attended by 25 percent of the AEA's Australian membership. While the overall feedback was positive, the attendees generated 25 regulatory questions and comments during the week-long course. The following week, Peri presented these questions and comments to the Civil Aviation Safety Authority in a two-day meeting in Canberra, where 24 of the 25 questions were resolved in a positive manner.
The questions and comments, as well as the CASA responses, will be posted on the AEA website's South Pacific regulatory page in the next few weeks. The questions and answers also will be a topic of discussion during the upcoming AEA South Pacific Regional Meeting Nov. 12-13 in Sydney.
The two most important discussion points had to do with the current need to hold both a Part 145 and a Part 30 to service both aircraft operations; and, the interpretation of MITCOM/FITCOM with regards to wiring looms.
Regarding the downward compatibility of a Part 145 to provide maintenance services to operators who have not opted to maintain their aircraft to Part 42 standards, according to CASA, the Part 145 repair stations do not need to maintain separate approvals. However, the Part 145 exposition will need to include both the maintenance and record-keeping requirements of CASR Part 42 as well as the legacy CAR Part 4 (CAR 30 processes) requirements. This will be clarified in later CASA guidance.
With regards to the application of FITCOM (fabrication in the course of maintenance) as it pertains to bundling wires into a loom -- in general, if the aircraft/equipment OEM (or approved data) has designated a wiring loom by part number, then fabricating the wiring loom would be considered the fabrication of an aeronautical product. However, if the aircraft/equipment OEM (or approved data) did not designate the wiring loom by part number, then bundling of the wires into a loom would not be considered the fabrication of an aeronautical product.
The AEA thanks the attendees of the course for their participation, as well as the open reception CASA presented in addressing and resolving the questions and comments generated during the course. The association looks forward to a strong agenda at the upcoming regional meeting.
FOR MORE INFORMATION:
Contact Ric Peri, AEA vice president of government and industry affairs, by email at email@example.com or by phone at 202-589-1144.