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June 6, 2012 DocketOperationsM-30: U.S.DEPARTMENT OF TRANSPORTAION 1200NewJerseyAvenue SE, Room Wl2-l40, WestBuildingGround Floor Washington,DC 20590-0001 Subject: DocketNo. FAA-2006-26408; Notice #12-03 From the desk of: ArtJackson, Manager NEBO Aviation Services, LLC DBA: APG Avionics, Inc 8000 SkylaneWay PuntaGorda. FL 33982 941-637-6530 Email: ajackson@apgavionics.com FAACertificate: N10R037B

'i] \. RJN 2120-AJ61, Notice ofProposed Rulemaking: 14 CFRParts43,91 and 145 To: Mr. Raymond Towles, ActingDirector, FlightStandards Service; I understand and agree that a change in the regulations managing the Repair Stations within thejurisdiction ofthe Federal Aviation Administrationneeds clarification and some modifications. I was surprised to read the comments in the pre-amble, which referenced the 2006 NPRM and itsrejection to the proposed "Avionics Rating". Considering all references in the current Part 43, 65 and ·145 regulations address issues from the standpoint ofan engine and airframe operation; it is my position that an "Avionics" rating would clarify many oftoday's issues and confusions. Unfortunately a majorhurdle may exist in defining the extent ofthe airframe and engine work, avionics shops perform. I cite the airframe issues associated with the installation of antennas and especiallythe engine components ofthe new electronic fuel and engine monitoring equipment. 1. CAPABILITY LISTS: The suggestion that a capability list will assist the inspectors 

### in administering their responsibilities is an example ofduplicated and unnecessary efforts. The current regulation adequately covers this issue in the most simple and administratively effectivemanner. The regulation statesthatto 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 ofexpertise can demonstrate these basic requirements, the inspector'sjobhas been adequately and legallyperformed. Ourrepair station currently operates under the Class Ratings. There are literallythousands ofpartnumbers 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. Itwould take months for an inspector to verify the authenticity ofsuch 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 bythe inspectormaking a selection ofa component, appliance or aircraft and asking to see all ofthe required documents and orevidence ofrecently performed repair or installation. The capability list means nothing except a device to be used in identifYing some act ofsuspected 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 orto control those who would wi1lingly repair and/orinstall somethingthey werenot approvedto 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'tcomplicate the process with more confusing regulations, which can be interpreted in so many different ways. Make it simple and understandable withoutthe need ofan attorney. 2. SYSTEMOFRATING 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 repairstations who choose to use one. "). This isvague and confusing. It goes on to say, 

### (This is apotentially marked changefor repair stations with class ratings that do not currentlyhave acapabilitylistof the items they maintain.). This needs clarification! 3. 145.1051 (e) Denialof145Certificate: I am in full agreement with and support the new: 

### Applicationfor 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 placingother's lives in danger should not be permitted to re-establish another repair center. To provide a method offorgiveness to a deserving individual, a time limit might be considered for the applicant who demonstrates a sincere regret, change in personal direction and a clearunderstanding ofhisobligationto complywiththe regulations. SAFETYMANAGEMENT SYSTEMS: While this is only mentioned in the NPRM, underthe paragraphtitled General Discussion ofthe Proposal,I submit such a program should be omitted from the FAA's agenda. The objectives ofan 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 administerthis program. Just because Canadais doing it this should not control our policies. A cost analysis toward the FAA's budget should be seriously considered before implementing such apolicy. In the same paragraphreferenced above, the NPRM suggests a possible conflict between an SMS program and a Formal Quality System. I struggle with the intent ofthis statement and assume it was included to prepare the industry for whatthe Administration will be addressing very soon. Ifthis assumption is correct, I trust the Administration will provide equal opportunity for the 1,838 small shops and the majority ofthe 1,913 medium shops to voice their concern. A budget analysis ofany ISO form ofquality program will surely demonstratethe overwhelming impact it will have on these shops.

2Docket Number FAA-2006-26408 

### May 24,2012 NEBO Avionics LLC/DBA APG Avionics,# N10R037B

4. COSTCONSIDERATIONSINTHENPRM: I submitthe costto the small shop will not vary significantly from that ofthe medium shop. Although the dollar figure might follow either type shop, the labor impact is strikingly more impacting. The smaller number ofemployees typically reflects a more concentrated area ofresponsibility spread tothe small shop. The more employees available, the easier it is to spread work aroWJd and fmd available labor time to accomplishthis type ofmission. SUMMARY: My affection for aircraft spans the entire content ofmy 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 severalyears of their lives and over $30,000 oftheir educational funds to enter this industry only to find such a small reward for theirefforts. Our industry serves the elite ofour 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 negotiatingtheir positions. This isjustthe opposite ofthe small shop ownertrying to make a living doing whathe enjoys and one who has rarely achieved degrees in businessmanagement. 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 ofthe 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 ofnew regulatory compliances. Greater profits for the small shop would also result in a greater element ofsafety to our General Aviation fleet; by eliminating the temptationto shave some costs in order to make some amount ofprofit. Thankyou,

General Manager CC: BorisNekrosov, President/Owner,NEBOAviation Services LLC./DBA APG Avionics Ric Peri, AircraftElectronics Association

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