Industry Organization Says Changes Compromise Maintenance
The AEA has offered several comments in response to the FAA
proposal to amend the maintenance regulations by removing from the
preventive maintenance category the task of updating databases used
in self-contained, front-panel or pedestal-mounted navigation
equipment. This change would allow pilots who operate certificated
aircraft to update the specified databases and eliminate the
requirement for certificated mechanics or repair stations to
perform the update.
In general, the AEA supports the concept that commercial pilots
should be able to load navigation and terrain awareness database
updates. However, the AEA does not agree with the FAA's proposed
rule change. According to the AEA, the proposal does not reach its
intended audience and compromises the maintenance regulations in
The AEA suggests two additional alternatives that the agency
should consider. First, § 43.3 could be amended similar to
§ 43.3(h) or (i) which could provide pilots operating under
Parts 121, 129 or 135 the authority to perform preventive
maintenance limited to Part 43 Appendix A, paragraph (c)(32).
The other option not considered is removal of Part 43 Appendix A
paragraph (c)(32) and move the database updating responsibility to
Part 91 under the general operating and flight rules. Should the
responsibility and authority be moved to Part 91, the instructions
and limitation could, therefore, be included in the aeronautical
So, to fully support aircraft operations regardless of the type
of operations, the AEA suggests the agency adopt the latter option
and expand the authority to include all air traffic control
navigational software databases, regardless of the location of the
- No disassembly of the unit is required.
- The pilot has written procedures available to perform and
evaluate the accomplishment of the task.
- The database is contained in a field-loadable configuration and
imaged on a medium, such as a compact disc read-only memory,
synchronous dynamic random-access memory, or other nonvolatile
memory that contains database files which are non-corruptible upon
loading, and where integrity of the load can be assured and
verified by the pilot upon completing the loading sequences.
The agency needs to define what it means by air traffic control
navigational software databases. When the original regulations were
written, the navigation databases were limited to charts and
frequency databases; however, today many databases include active
terrain and obstacle information.
The AEA supports the agency's proposal that the data to be
uploaded must not contain system operating software revisions.
AEA generally supports the intent to allow pilots to install air
traffic control navigational software databases, regardless of the
type of aircraft operations. However, the AEA does not support this
proposed regulation as written.