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AOPA backs revised retrofit-avionics test standards

AOPA is urging the FAA to adopt two draft policies that would help avionics producers bring innovative products to the certified-aircraft retrofit market at more affordable prices.

In a letter to the FAA’s Small Airplane Directorate, AOPA said the draft policy statement HIRF/Lightning Test Levels and Compliance Methods for 14 CFR Part 23 Class I, II, and III Airplanes outlines an appropriate means of demonstrating compliance with the requirements for protecting electrical and electronic systems in smaller airplanes from failures due to exposure to lightning and high-intensity radiated fields (HIRF). Existing FAA policy has led to unnecessary costs for manufacturers pursuing certification.

 “AOPA strongly recommends the FAA finalize and adopt the Policy, which will enable more companies to enter the market for retrofitting type-certificated aircraft in a cost-effective and safe manner,” wrote AOPA Director of Regulatory Affairs Justin Barkowski.

By allowing an applicant for a supplemental type certificate to conduct bench testing of electronic systems—instead of full aircraft testing—to satisfy the HIRF and lightning protection standards, the policy represents “an important change” without reducing safety, he wrote.

AOPA added that the policy, which the association requested, advances the FAA’s “safety continuum philosophy, the concept that one level of safety may not be appropriate for all certification levels.”

According to the General Aviation Manufacturer’s Association’s 2016 General Aviation Statistical Databook, the average age of all single-engine piston airplanes in the United States is about 45 years.

Owners want new technology to modernize and improve the safety of those aircraft. However, the typical products available to retrofit these airplanes have been too expensive relative to the airplane’s cost—an issue not faced in the experimental aircraft sector.

AOPA has made it a priority to overcome the certification barriers that drive up retrofit costs.

To supplement the draft compliance policy, AOPA also urged the FAA to finalize an additional policy that creates a more appropriate means of complying with the FAA’s standards for verification of electronic avionics software.

As AOPA had requested in a December 2016 letter to the FAA, the association recommended that the agency permit “a clear pathway” for avionics manufacturers to use a verification standard produced by ASTM International for certain projects as an alternative to the existing policy that applies similar standards to all avionics software, “regardless of whether the equipment is installed in a transport or normal category airplane.”

“These efforts lay the foundation for more and more companies to bring their innovative products to the certified market at a more affordable price,” Barkowski said.

Dan Namowitz

Dan Namowitz

Dan Namowitz has been writing for AOPA in a variety of capacities since 1991. He has been a flight instructor since 1990 and is a 35-year AOPA member.
Topics: Aircraft Regulation, Aircraft, Avionics

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