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June 6, 2012 

Docket Operations M-30: 

U.S. DEPARTMENT OF TRANSPORTAION 

1200 New Jersey A venue SE, 

Room Wl2-l40, West Building Ground Floor 

Washington, DC 20590-0001 

Subject: Docket No. FAA-2006-26408; Notice #12-03 

From the desk of: Art Jackson, Manager 

NEBO Aviation Services, LLC 

DBA: APG Avionics, Inc 

8000 Skylane Way 

Punta Gorda. FL 33982 

941-637-6530 

Email: ajackson@apgavionics.com 

FAA Certificate: N10R037B 

'i] \. 

RJN 2120-AJ61, Notice of Proposed Rulemaking: 14 CFR Parts 43,91 and 145 

To: Mr. Raymond Towles, Acting Director, Flight Standards Service; 

I understand and agree that a change in the regulations managing the Repair Stations within the jurisdiction of the 

Federal Aviation Administration needs clarification and some modifications. 

I was surprised to read the comments in the pre-amble, which referenced the 2006 NPRM and its rejection to the 

proposed "Avionics Rating". Considering all references in the current Part 43, 65 and ·145 regulations address 

issues from the standpoint of an engine and airframe operation; it is my position that an "Avionics" rating would 

clarify many oftoday's issues and confusions. Unfortunately a major hurdle may exist in defining the extent of the 

airframe and engine work, avionics shops perform. I cite the airframe issues associated with the installation of 

antennas and especially the engine components of the new electronic fuel and engine monitoring equipment. 

1. CAP ABILITY LISTS: 

The suggestion that a capability list will assist the inspectors in administering their responsibilities is an 

example of duplicated and unnecessary efforts. The current regulation adequately covers this issue in the 

most simple and administratively effective manner. The regulation states that to repair, overhaul and return 

to service any aircraft, accessory or appliance; one must demonstrate that he possesses the (l) Facility, (2) 

Tools and Required Test equipment, (3) Approved instaiJation documentation, repair manuals and/or 

procedures approved by the Administrator and ( 4) personnel properly trained for the procedure. THAT'S 

IT and that is all that is needed. If any installation, repair and/or overhaul is performed by any 

appropriately rated repair station and operating within its rated area of expertise can demonstrate these 

basic requirements, the inspector's job has been adequately and legally performed. 

Our repair station currently operates under the Class Ratings. There are literally thousands of part numbers 

a repair station such as ours will need to list on a capability list. The list would not only include current 

production items, but must include all items manufactured for the past 30-years. It would take months for 

an inspector to verify the authenticity of such a list. Whereas, by using the basic requirements addressed 

above, should a question be raised, the inspector would only need to verifY the basic requirements. A 

routine inspection could easily be performed by the inspector making a selection of a component, appliance 

or aircraft and asking to see all of the required documents and or evidence of recently performed repair or 

installation. 

The capability list means nothing except a device to be used in identifYing some act of suspected violation, 

which can easily be accomplished by the same proceedings as described above. A capability list does 

nothing to insure that a repair station reflects its actual capability or to control those who would wi1lingly 

repair and/or install something they were not approved to do so. 
Docket Number FAA-2006-26408 May 24,2012 

NEBO Avionics LLC/DBAAPG Avionics,# N10R037B 

If, as described in the NPRM, the FAA considers the capabilities list self-evaluation process, then Jet it be 

simply that. Don't complicate the process with more confusing regulations, which can be interpreted in so 

many different ways. Make it simple and understandable without the need of an attorney. 

2. SYSTEM OF RATING CHANGES: 

Under "System ofRatings" section the statement; 

("This proposal would not require a capability list, but would revise the capability list recording 

requirements for those repair stations who choose to use one. " ). This is vague and confusing. 

It goes on to say, (This is a potentially marked change for repair stations with class ratings that do not 

currently have a capability list of the items they maintain.). 

This needs clarification! 

3. 145.1051 (e) Denial of 145 Certificate: 

I am in full agreement with and support the new: Application for Certificate- Denia/145-1051. I would 

submit that the proper verbiage should remain to protect an otherwise innocent person or pc;:rsons from 

being penalized for action he or she could not prevent or was not directly a part of. A person guilty of 

willingly and fraudulently violating a regulation and placing other's lives in danger should not be permitted 

to re-establish another repair center. To provide a method of forgiveness to a deserving individual, a time 

limit might be considered for the applicant who demonstrates a sincere regret, change in personal direction 

and a clear understanding ofhis obligation to comply with the regulations. 

SAFETY MANAGEMENT SYSTEMS: 

While this is only mentioned in the NPRM, under the paragraph titled General Discussion of the Proposal, I 

submit such a program should be omitted from the FAA's agenda. The objectives of an SMS type system 

is already covered by several existing regulatory. We have OSHA, EPA, TSA, Workman's Comp,.Liability 

Insurance regulators, Alcohol and Drug Abatement Department, fire department inspections and our own 

internal moral and business ethics decision making, which adequately address these issues. It would be 

grossly negligent for my shop or any ·business entity to ignore employee and product safety issues. I fully 

support and encourage all employers to consider and insure the safety and welfare of employees and 

visitors; however, I strongly object to the FAA mandating control over it. Our repair shops do not need 

this additional burden to simply document what we have always done; and the FAA has not the time, 

expertise or available resources to administer this program. Just because Canada is doing it this should not 

control our policies. A cost analysis toward the FAA's budget should be seriously considered before 

implementing such a policy. 

In the same paragraph referenced above, the NPRM suggests a possible conflict between an SMS program 

and a Formal Quality System. I struggle with the intent of this statement and assume it was included to 

prepare the industry for what the Administration will be addressing very soon. If this assumption is correct, 

I trust the Administration will provide equal opportunity for the 1,838 small shops and the majority of the 

1,913 medium shops to voice their concern. A budget analysis of any ISO form of quality program will 

surely demonstrate the overwhelming impact it will have on these shops. 

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Docket Number FAA-2006-26408 May 24,2012 

NEBO Avionics LLC/DBA APG Avionics,# N10R037B 

4. COST CONSIDERATIONS IN THE NPRM: 

I submit the cost to the small shop will not vary significantly from that of the medium shop. Although the 

dollar figure might follow either type shop, the labor impact is strikingly more impacting. The smaller 

number of employees typically reflects a more concentrated area of responsibility spread to the small shop. 

The more employees available, the easier it is to spread work aroWJd and fmd available labor time to 

accomplish this type of mission. 

SUMMARY: 

My affection for aircraft spans the entire content of my memory. I am proud to state that over 30-years of 

my life has been spent in this amazing industry. I have worked hard for it and it has rewarded me in many 

ways. lt continues to break my heart to see the new arrivals into our industry giving up several years of 

their lives and over $30,000 of their educational funds to enter this industry only to find such a small 

reward for their efforts. 

Our industry serves the elite of our society. We consistently endure their efforts to shave costs from their 

billings. Typically they are successful in their monetary achievements and are accustomed to skillfully 

negotiating their positions. This is just the opposite of the small shop owner trying to make a living doing 

what he enjoys and one who has rarely achieved degrees in business management. 

The Administration needs to shift more responsibility and accoWJtability to aircraft owners and operators 

and lessen the burden on the small businesses within our industry. This can be done by more ramp 

inspections or inspections by appointment with owners of privately owned aircraft. These inspections 

should capitalize on properly documented installations and installation s performed by properly authorized 

personnel and/or shops. Civil penalties issued against aircraft owners would quickly create a new 

understanding of the owner's responsibilities. The results would guide them to more responsible shops. 

This would result in the legitimate shop's ability to charge a reasonable cost to cover the additional 

expenses of new regulatory compliances. Greater profits for the small shop would also result in a greater 

element of safety to our General Aviation fleet; by eliminating the temptation to shave some costs in order 

to make some amount of profit. 

Thank you, 

General Manager 

CC: Boris Nekrosov, President/Owner, NEBO Aviation Services LLC./DBA APG Avionics 

Ric Peri, Aircraft Electronics Association 

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