From Ric Peri
Vice President of government and industry affairs for AEA
For the past seven years, I have received calls regarding the challenges of installing wireless technology in business aircraft. In January, the AEA hosted a Wi-Fi Summit at its headquarters in Lee’s Summit, Mo., with the FAA, EASA, TCCA and industry. AEA members requested the meeting to convince the FAA it was being overly restrictive regarding the guidance and policy for installing wireless technologies in business aircraft.
A review of the issues and an update of the action items discussed during the Wi-Fi Summit will be presented on Wednesday, April 7, during the AEA International Convention & Trade Show at the Gaylord Palms Resort in Orlando, Fla. For more information, visit www.aea.net/convention.
The Wi-Fi Summit began on a typical note of “us versus them.” However, as with all AEA meetings, everyone was treated with respect even though we have differing opinions. Industry was reasonably certain the FAA was treating general aviation and business aircraft with the same scrutiny it uses for large commercial aircraft with fully integrated computer-based aircraft systems.
The agencies presented their concerns and explained why the policy was written as it is, as well as why the policy requires the installer to go through so many steps to install what appears to be a relatively benign “radio.” In general, and seriously minimized, the FAA is not as concerned about the “radio” of a Wi-Fi system as it is about the effect of the transmitting portable electronic devices (T-PED) on the aircraft when used as intended. While the Federal Communications Commission regulates T-PEDs, the high end of the allowable powerband could negatively impact the performance of critical and required installed avionics systems. Therefore, the FAA is more concerned about the hundreds of different T-PEDs we carry around with us rather than the dozen or so fixed systems.
14 CFR 91.21 does empower an operator to make decisions regarding portable electronics devices, but have you actually looked at the rule? The regulation, §91.21(a), states, “No person may operate, nor may any operator or pilot in command of an aircraft allow the operation of any portable electronic device on any aircraft while it is operated under IFR.” The rule does allow for exception: Paragraph 91.21(b) (5) allows for the use of “any other portable electronic device that the operator of the aircraft has determined will not cause interference with the navigation or communications system of the aircraft on which it is to be used.”
FAA advisory circular AC 91.21-1B provides information regarding the validation and acceptance of T-PEDS. According to the AC, “The current edition of RTCA/DO-294 identifies a process for airlines to make a determination of acceptable use of T-PEDs. The determination of an interfering effect caused by a particular device on the navigation and communications system of the aircraft on which it is to be used or operated must, in case of an aircraft operated by the holder of an air carrier certificate or other operating certificate, be made by that operator (such as the certificate holder).” The AC continues with guidance to non-airline operators: “In all other cases, a determination must be made by the operator and/or by the pilot-in-command. In some cases, the determination may be based on operational tests conducted by the operator without the need for sophisticated testing equipment.”
Once we understood why the FAA was concerned about wireless technologies, we could come together to develop strategies to modernize the policy and recommend specific guidance materials.
The presentation from the Wi-Fi Summit can be viewed at www.aea.net/governmentaffairs.
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Founded in 1957, the Aircraft Electronics Association represents nearly 1,300 member companies in more than 40 countries, including approved maintenance organizations specializing in maintenance, repair and installation of aircraft electronics systems in general aviation aircraft. The AEA membership also includes manufacturers of aircraft electronics equipment, instrument repair facilities, instrument manufacturers, airframe manufacturers, test equipment manufacturers, major distributors, engineers and educational institutions.