Avionics Technicians /repairmen

Tom-D

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Tom-D
65.101 Eligibility requirements: General.
(a) To be eligible for a repairman certificate a person must—

(1) Be at least 18 years of age;

(2) Be specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which he is employed;

(3) Be employed for a specific job requiring those special qualifications by a certificated repair station, or by a certificated commercial operator or certificated air carrier, that is required by its operating certificate or approved operations specifications to provide a continuous airworthiness maintenance program according to its maintenance manuals;

(4) Be recommended for certification by his employer, to the satisfaction of the Administrator, as able to satisfactorily maintain aircraft or components, appropriate to the job for which he is employed;

(5) Have either—

(i) At least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job for which the person is to be employed and certificated; or

(ii) Completed formal training that is acceptable to the Administrator and is specifically designed to qualify the applicant for the job on which the applicant is to be employed; and

(6) Be able to read, write, speak, and understand the English language, or, in the case of an applicant who does not meet this requirement and who is employed outside the United States by a certificated repair station, a certificated U.S. commercial operator, or a certificated U.S. air carrier, described in paragraph (a)(3) of this section, have this certificate endorsed “Valid only outside the United States.”

(b) This section does not apply to the issuance of a repairman certificate (experimental aircraft builder) under §65.104 or to a repairman certificate (light-sport aircraft) under §65.107.

Why must any repairmen be employed by a CRS to get a repairman's certificate?
there are several freelanced avionic techs that come to me for return to service sign offs.

Wouldn't it make sense to allow them to work on what they are qualified, and return it to service, and if what they did needed a 337 to then come to the IA for block #8

Just seems to me that the FAA is over restrictive on many talented people.

Your thoughts?
 
65.101 Eligibility requirements: General.
(a) To be eligible for a repairman certificate a person must—

(1) Be at least 18 years of age;

(2) Be specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which he is employed;

(3) Be employed for a specific job requiring those special qualifications by a certificated repair station, or by a certificated commercial operator or certificated air carrier, that is required by its operating certificate or approved operations specifications to provide a continuous airworthiness maintenance program according to its maintenance manuals;

(4) Be recommended for certification by his employer, to the satisfaction of the Administrator, as able to satisfactorily maintain aircraft or components, appropriate to the job for which he is employed;

(5) Have either—

(i) At least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job for which the person is to be employed and certificated; or

(ii) Completed formal training that is acceptable to the Administrator and is specifically designed to qualify the applicant for the job on which the applicant is to be employed; and

(6) Be able to read, write, speak, and understand the English language, or, in the case of an applicant who does not meet this requirement and who is employed outside the United States by a certificated repair station, a certificated U.S. commercial operator, or a certificated U.S. air carrier, described in paragraph (a)(3) of this section, have this certificate endorsed “Valid only outside the United States.”

(b) This section does not apply to the issuance of a repairman certificate (experimental aircraft builder) under §65.104 or to a repairman certificate (light-sport aircraft) under §65.107.

Why must any repairmen be employed by a CRS to get a repairman's certificate?
there are several freelanced avionic techs that come to me for return to service sign offs.

Wouldn't it make sense to allow them to work on what they are qualified, and return it to service, and if what they did needed a 337 to then come to the IA for block #8

Just seems to me that the FAA is over restrictive on many talented people.

Your thoughts?


From what I remember, the reason a repairman certificate is tied to a certified entity (station or operator) is the entity is held accountable for the work and the QA system it provides. Nothing more. Plus the purpose of a repairman’s certificate was to help the operator not the individual.

What’s even worse the feds are very limited in applying experience credit as a certified repairman toward an A&P.

I think it is a bit antiquated and there should be a mechanism for them to approve their own highly specialized work for RTS. Kind of like the Special Services CRSs the feds used to allow. And since they exempt single pilot 135 ops from a number of the 135 requirements, you would think a single 10 year repairman shop would be offered the same type of exemptions.

If a person is able to legally obtain just the A (which is the answer the feds give to avionics guys) or P of an A&P, how hard would it be to add a third specialty certificate for spark chasing? Or rivet banging?
 
If a person is able to legally obtain just the A (which is the answer the feds give to avionics guys) or P of an A&P, how hard would it be to add a third specialty certificate for spark chasing? Or rivet banging?

this was kind of a rant for me, but I agree we need to update the regs, there are a bunch of one man shops doing special things.
I know one who does nothing but cylinders, he has no ratings, and relies on the installer to declare airworthiness.
It would be a great savings to the GA public if the FAA had a method of getting a repairman certificate with out the CRS requirement.
Then a one man shop could come to your hangar and do your avionics stuff.
Advantages
Much cheaper
you don'y have to leave your aircraft for weeks at the avionics shop.
 
Then a one man shop could come to your hangar and do your avionics stuff.

There is NOTHING preventing this from happening under the current CRS structured system, it happens every day. It sucks tho because how many are really interesed in dragging expensive gear all around, being away from home, and working in an unfarmiliar airport with unknown facilities etc? Not only that but say you have an avionics installer go to your primary general mechanic's place, there's not enough room for two & three people to work on these things.
 
There is NOTHING preventing this from happening under the current CRS structured system, it happens every day..
This is true, but all they do is grab your radio and run back to their bench at the CRS.
then you get to pay for travel time both ways at the CRS rate.

then when they find the radio bench checks good the want you to bring the aircraft in for rewire.
 
This is true, but all they do is grab your radio and run back to their bench at the CRS.
then you get to pay for travel time both ways at the CRS rate.

What CRS is gonna drag throusands of dollars worth of bench equipment from airport to airport? There is a reason bench is basically a lab.

Installs involve more sheet metal and wiring than bench work (repairs).
 
What CRS is gonna drag throusands of dollars worth of bench equipment from airport to airport? There is a reason bench is basically a lab.

Installs involve more sheet metal and wiring than bench work (repairs).
Not many, but now we have portable equipment that will do the same thing. all can be carried in a small van.
 
See post #4. I'm out at this point because its gonna be a thread going in circles.
Maybe, but before you go, show us why the requirement for a CRS can't be dropped to our advantage.
 
Maybe, but before you go, show us why the requirement for a CRS can't be dropped to our advantage.


You're looking at a very small piece of the picture and haven't even considered that most of the equipment debated about on this forum cannot be sold over the counter (for certified aircraft per dealer policy) and must be installed by an authorized dealer. To be competitive you'll need the dealer pricing. The OEM determines what dealership requirements are not the FAA.
 
You're looking at a very small piece of the picture and haven't even considered that most of the equipment debated about on this forum cannot be sold over the counter and must be installed by an authorized dealer. To be competitive you'll need the dealer pricing. The OEM determines what dealership requirements are not the FAA.
No I had not considered that. Why couldn't a 1 man shop operating on a Repairman's certificate be a dealer? most of the new era equipment I see like dynon, VAL-COM and others comes with a prewired harness.
Aircraft spruce and specialities sell to any one and they stock a great many items in this field.
 
Tom, are you ranting more about restrictions to individuals performing repairs on said equipment or new installations?

If you're mainly referring to repairs, the landscape will be changing rapidly in the next decade or so. In the era of custom displays and ICs, surface mount components, and firmware the old time avionics technicians will be a thing of the past. They may be able to replace an entire circuit board or display in a unit but likely won't be troubleshooting anything down to the component level, since they simply don't have the tools, knowledge, and replacement parts to do so. Garmin has already been reinforcing this concept since more often than not a failure of a GNS430 or similar unit will require a trip back to the Garmin facility to repair/refurbish rather than just fixing it at the local avionics shop. Older radios like the KX155, 170, etc. will continue to be repaired locally but as these units age more and more of them will be removed from service and replaced with the more modern equipment.

For initial installations, I could see a transient avionics tech making house calls. The main problem with doing that though is that the number of visits to complete the job might get to be excessive unless the job was fairly simple. How many hours does an average installation take?
 
The problem is that unlike A&Ps, there is no real FAA certification for avionics technicians. The only PERSONNEL qualification is the FCC General Radio Telephone License (I've had one for decades going back to when it was called the second class radiotelephone operator's license). The FAA puts all the controls on the REPAIR STATION to identify that they have both the proper facilities and personnel to get the job done.

The GROL is by and large a joke. It used to be pretty grounded in vacuum tube technology which only had passing application to avionics. Now it even less relevant.
 
Tom, are you ranting more about restrictions to individuals performing repairs on said equipment or new installations?

If you're mainly referring to repairs, the landscape will be changing rapidly in the next decade or so. In the era of custom displays and ICs, surface mount components, and firmware the old time avionics technicians will be a thing of the past. They may be able to replace an entire circuit board or display in a unit but likely won't be troubleshooting anything down to the component level, since they simply don't have the tools, knowledge, and replacement parts to do so. Garmin has already been reinforcing this concept since more often than not a failure of a GNS430 or similar unit will require a trip back to the Garmin facility to repair/refurbish rather than just fixing it at the local avionics shop. Older radios like the KX155, 170, etc. will continue to be repaired locally but as these units age more and more of them will be removed from service and replaced with the more modern equipment.

For initial installations, I could see a transient avionics tech making house calls. The main problem with doing that though is that the number of visits to complete the job might get to be excessive unless the job was fairly simple. How many hours does an average installation take?
What I'm reading from your post makes it more attractive to have a certification for an avionic tech. They won't be able to do any thing in side the new boxes. Why not allow the service tech sign off their own work.
a simple application for a test, pass with a 70 or better and get a license/certificate.
 
this was kind of a rant for me, but I agree we need to update the regs, there are a bunch of one man shops doing special things.
I know one who does nothing but cylinders, he has no ratings, and relies on the installer to declare airworthiness.
It would be a great savings to the GA public if the FAA had a method of getting a repairman certificate with out the CRS requirement.
Then a one man shop could come to your hangar and do your avionics stuff.
Advantages
Much cheaper
you don'y have to leave your aircraft for weeks at the avionics shop.
There is NOTHING preventing this from happening under the current CRS structured system, it happens every day. It sucks tho because how many are really interesed in dragging expensive gear all around, being away from home, and working in an unfarmiliar airport with unknown facilities etc? Not only that but say you have an avionics installer go to your primary general mechanic's place, there's not enough room for two & three people to work on these things.

Tom-D/bnt83:
I think you both bring up valid points. The avionics OEMs do control most of the latest and greatest equipment out there and how it is installed, warrantied, and repaired. On the other hand, there are a lot of uniquely skilled individuals that are prevented from offering any mobile services due to the archaic and overbearing regulations of Part 145. And it’s only gotten worse.

Bottom-line it’s the FAA, and subsequent OEM requirements to a point, that prevent this flexibility. However, in my experience, the majority of the avionics type work in GA is on older equipment outside the OEM requirements. Problem is a crack avionics guy has only one route to ply his trade, through a CRS since most spark chasers don't have the ability to gain all the requirements for an Airframe certificate.

For example, why can’t a person with extensive avionics experience obtain FAA certification to perform only transponder checks per 43, or certified to perform minor field based radio repair/install without having to obtain a full blown CRS with a permanent location or an A cert? There's existing FAA guidance that could be applied to this type of certification which could include annual training or re-certification like an IA. There’s also a multitude of portable test equipment out there along with various vendors that do sell new/reconditioned equipment that fits right into the GA market.

If you want a Garmin stack sure you need to see a CRS dealer. But what if your old Cessna radio went dead. Wouldn’t it be nice to have the local sparky order a new ICOM from Sarasota or Coast to Coast, wire it up in your hangar, and have it signed off ready to go for your next breakfast fly-in?

I think there’s room for both.
 
Tom-D/bnt83:
I think you both bring up valid points. The avionics OEMs do control most of the latest and greatest equipment out there and how it is installed, warrantied, and repaired. On the other hand, there are a lot of uniquely skilled individuals that are prevented from offering any mobile services due to the archaic and overbearing regulations of Part 145. And it’s only gotten worse.

Bottom-line it’s the FAA, and subsequent OEM requirements to a point, that prevent this flexibility. However, in my experience, the majority of the avionics type work in GA is on older equipment outside the OEM requirements. Problem is a crack avionics guy has only one route to ply his trade, through a CRS since most spark chasers don't have the ability to gain all the requirements for an Airframe certificate.

For example, why can’t a person with extensive avionics experience obtain FAA certification to perform only transponder checks per 43, or certified to perform minor field based radio repair/install without having to obtain a full blown CRS with a permanent location or an A cert? There's existing FAA guidance that could be applied to this type of certification which could include annual training or re-certification like an IA. There’s also a multitude of portable test equipment out there along with various vendors that do sell new/reconditioned equipment that fits right into the GA market.

If you want a Garmin stack sure you need to see a CRS dealer. But what if your old Cessna radio went dead. Wouldn’t it be nice to have the local sparky order a new ICOM from Sarasota or Coast to Coast, wire it up in your hangar, and have it signed off ready to go for your next breakfast fly-in?

I think there’s room for both.
Very valid points made here, (TYVM) why should an avionic tech be required to gain a A portion of the A&P to do what they do?
The other great point made was the old stuff is going away, Narco is already gone, king is well on its way, and the new era equipment isn't fixable in the field. So that brings us down to installs, trouble shooting, and replacements.
 
To rub salt in a sore wound, we see home builders do this almost every day.

Now you know how I feel about this, I'd like your opinions on how we can get the FAA to do this.
 
See for your self, http://www.aircraftspruce.com/menus/av/index.html

I'll wager that when these manufacturers see their computers items being installed, they'll change their policies.
The Garmin and Dynon seem to be experimental only, though I didn't click through all the links. AFAIK, even I can do almost anything I want to an experimental plane. I think the question that started this thread is for whatever we call planes that aren't experimental? Maybe you could find a link there for avionics for those planes.
 
The Garmin and Dynon seem to be experimental only, though I didn't click through all the links. AFAIK, even I can do almost anything I want to an experimental plane. I think the question that started this thread is for whatever we call planes that aren't experimental? Maybe you could find a link there for avionics for those planes.
the repair man will still be required to install PMAed equipment. there will be no change there until we get guidance from the FAA on what we can install under the re-write of FAR part 21.
 
What I'm reading from your post makes it more attractive to have a certification for an avionic tech. They won't be able to do any thing in side the new boxes. Why not allow the service tech sign off their own work.
a simple application for a test, pass with a 70 or better and get a license/certificate.

My only concerns are what would qualify a technician to take that test (do we need to do another 18 months or take an approved course?) and are current airframe mechanics exempted from these tests?

What would your proposed certificate allow these mechanics/repairmen to do? Installations only or actual repairs inside the box? As Ron mentioned, some of this is regulated by other groups (FCC) and their requirements need to be met as well.

My main concern is that I would lose the ability to install a basic radio or intercom that can be signed off under a mechanic certificate.

To rub salt in a sore wound, we see home builders do this almost every day.

Now you know how I feel about this, I'd like your opinions on how we can get the FAA to do this.

We do, and some of these installations are pi$$ poor. That's not to say that some of the avionics shop installations are much, if any better. I'm cleaning up a prime example of this right now.
 
the repair man will still be required to install PMAed equipment. there will be no change there until we get guidance from the FAA on what we can install under the re-write of FAR part 21.
Not on experimental planes. Even I can install it, if I could get it. That's pretty much what you say in your post #21.

See for your self, http://www.aircraftspruce.com/menus/av/index.html

I'll wager that when these manufacturers see their computers items being installed, they'll change their policies.
Is there a link there for avionics for non-experimental planes? Otherwise, you really haven't proven @bnt83 's statement to be incorrect.
 
The airport authority here would tell the tech to get lost as they threaten to cancel the hangar lease because of a "station wagon mechanic" clause.
 
Agreed, and why not?

Its not needed IMHO. Installers are mostly making wires go from pin to pin on a drawing, remaining is sheet metal related and a bit of cosmetics.

As far as actual troubleshooting, verifying wiring and connections are good is about all you can do. The real magic is recording the failure and deciphering what could be making it happen by looking at prints and vendor support. As soon as its narrowed down to being in a box it gets pulled and sent to a lab (avionics bench).
 
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We do, and some of these installations are pi$$ poor. That's not to say that some of the avionics shop installations are much, if any better. I'm cleaning up a prime example of this right now.

The backshells are missing from two connectors on my dad's plane, one on a GMA the other on GTX, I'm sure it was the garmin dealer that initially installed them. Also found no silicone tape in the wire clamp on the GTN.
 
The backshells are missing from two connectors on my dad's plane, one on a GMA the other on GTX, I'm sure it was the garmin dealer that initially installed them. Also found no silicone tape in the wire clamp on the GTN.

I see lots of that sort of thing, some from very well known shops.

I find avionics interesting and I have sought out more information on my own to hopefully make me a better AME. I have done a few installs and I find my quality of work in this area is getting better the more I do. I wish there was a class or set of classes geared more for those in the industry already, who want to learn more of the sparky world. Maybe have a supplement rating for those who already have their A&P for limited avionics work?
 
The Garmin and Dynon seem to be experimental only, though I didn't click through all the links. AFAIK, even I can do almost anything I want to an experimental plane. I think the question that started this thread is for whatever we call planes that aren't experimental? Maybe you could find a link there for avionics for those planes.

Cap:
A couple sites that I used to do business with. Radios and harnesses ready to go unless blocked by OEM like Garmin.
http://sarasotaavionics.com/
https://www.gulfcoastavionics.com/
 
My only concerns are what would qualify a technician to take that test (do we need to do another 18 months or take an approved course?) and are current airframe mechanics exempted from these tests?

What would your proposed certificate allow these mechanics/repairmen to do? Installations only or actual repairs inside the box? As Ron mentioned, some of this is regulated by other groups (FCC) and their requirements need to be met as well.

My main concern is that I would lose the ability to install a basic radio or intercom that can be signed off under a mechanic certificate.



We do, and some of these installations are pi$$ poor. That's not to say that some of the avionics shop installations are much, if any better. I'm cleaning up a prime example of this right now.

Mod:
Our A&P is the catch-all. Allowing an avionics tech to obtain a specific certification would be below an A&P. The "A" already gives us the ability to do this work. The avionics tech has no option other than obtaining an Airframe certificate or work at a CRS in order to sign for their work.

If the feds decide to allow more privileges under a "Avionics Certificate" like xspndr certification then I would imagine that would be made available to existing A&Ps with additional qualifications no different than an IA privilege. The FAA allows some 135 mx programs, that have an associated 145 CRS, to permit 135 mechanics to certify xspndrs in the field.

As to what an "Avionics Certificate" allow? Everything they could perform as a repairman under a CRS. Except the avionics tech could approve return to service for their work. Just like we can as an A&P. When it comes to "inside-the-box" issues, as Tom mentioned this is all but N/A in todays world. You don't even need a FCC Radio License in an aircraft flown within the States anymore. And even A&Ps can't repair certain items per 65.

Also, I doubt with almost certainty, a current A&P would not lose any privileges with the development of a "Avionics Certificate." If you remember, the past attempt at a Part 66 which based maintenance privileges on an aircraft's gross weight included a grandfather clause which granted existing A&Ps complete privileges for all new limitations.

I think any movement in a positive direction will help the industry not hurt it.
 
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The airport authority here would tell the tech to get lost as they threaten to cancel the hangar lease because of a "station wagon mechanic" clause.

bnt83:
Maybe in your neck of the woods or on a private airport, but in my area on a public airport the commission has tried and failed on that attempt. The closest they got was to limit the type of worked performed in the hangars under their control. However, by some obscure FAA rule, which most airports get money from, they had to provide a means for owners to work on their aircraft. And if an owner brings in his own mechanic then that is a "private" contract and not under control of the commission. I've personally stood in front of several boards with aircraft owners and seen the process.
 
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Its not needed IMHO. Installers are mostly making wires go from pin to pin on a drawing, remaining is sheet metal related and a bit of cosmetics.

As far as actual troubleshooting, verifying wiring and connections are good is about all you can do. The real magic is recording the failure and deciphering what could be making it happen by looking at prints and vendor support. As soon as its narrowed down to being in a box it gets pulled and sent to a lab (avionics bench).

bnt83:
In a structured environment you are correct. But in the loose world of GA I think it would work.

From my view it would be a welcomed addition. My niche was electrical/avionics stuff. The electrical was easy compared to the avionics side. I mainly bought complete radio, bracket and harness packages from a number of vendors. Was I an expert at it? No. Did it work? Yes.

Then I got a smarter and brought over a couple avionics guys from the day job. They could do things in their sleep, I took a couple hours to complete. Now could they make a living at doing this work if they had the ability to sign off for themselves? A good question. But I kept them busy and quit buying the "install packages."

I think if an "Avionics Certificate" or a "Sheetmetal/Composite Certificate" were to materialize, a market for this type of service would be created by the simple fact of supply and demand. Would it hurt the existing fixed based repair shops? To an extent yes, but then they would also have the ability to adapt and offer similar services which are very hard to do under current CRS rules.
 
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Its BS based on a rule made 35 years ago as a knee jerk reaction to a situation that had more to do with a FSDO giving waivers to mess-cooks than anything to do with Avionics techs. And, it was one of the deciding factors for me getting out of aviation maintenance after my last layoff from a "Certified Repair Station".
 
Its not needed IMHO. Installers are mostly making wires go from pin to pin on a drawing, remaining is sheet metal related and a bit of cosmetics.

As far as actual troubleshooting, verifying wiring and connections are good is about all you can do. The real magic is recording the failure and deciphering what could be making it happen by looking at prints and vendor support. As soon as its narrowed down to being in a box it gets pulled and sent to a lab (avionics bench).

Hmm.... I disagree. Can't tell you how many times I've pitched in to help someone who didn't know how to use a multimeter correctly, how to isolate a circuit under test, or how to test a diode.

As far as installing stuff, theres quite of skill, knowledge and experience in creating an installation that integrates various components to fully utilize all of the desired features, is light weight and reliable. Homebuilders spend a lot of time figuring this stuff out. And, companies like Dynon put quite a bit of effort into assisting them with tooling and instructions. When you're a pro, getting paid, you don't have all that, you've gotta figure it out and get it done fast, or you don't feed your family.

Getting avionics techs a better route to at least get an "A" would be a good thing. As far as the existing credentials for avionics techs - thats a racket that is very similar to Microsoft's MCSE credentials and the like. Looks nice, but ....
 
As to what an "Avionics Certificate" allow? Everything they could perform as a repairman under a CRS. Except the avionics tech could approve return to service for their work.
that would be the objective and what we really need.
I believe any Repairman working in the CRS has a training record on file at there. the FAA could issue the certificate on that alone.
147 schools could have a training tract to lead to a repairman certificate.
 
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that would be the objective and what we really need.
I believe any Repairman working in the CRS has a training record on file at there. the FAA could issue the certificate on that alone.
141 schools could have a training tract to lead to a repairman certificate.
147, Tom.
 
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that would be the objective and what we really need.
I believe any Repairman working in the CRS has a training record on file at there. the FAA could issue the certificate on that alone.
147 schools could have a training tract to lead to a repairman certificate.

Tom-D:
I believe most of the repairmen we are referring to have been chasing sparks for a number of years and are good at it. So I don’t think the 147 school route would be the ticket. Then we would have inexperienced techs with a piece of paper and no usable experience.

Now if an experienced tech wanted to pursue his A cert then he should be given 147 credit for that experience and the ability to test out of some of the A requirements. This would effectively give him a shorter path to an A cert.

Since all repairmen have already taken a test to get their cert, I think a short training requirement on Part 43 paperwork requirements and a short test by the feds should allow the repairman to be authorized to sign off their work. This could be done at the FSDO level. And since every office has a PAI they could manage the program.

To qualify for this added privilege, a 3 or 5 year stint as a certified practicing repairman would do. It only takes 3 years to get an IA. Add in an annual or bi-annual reissue requirement and I think it is a workable system. The only push back I would see would be the CRS industry associations and their political machine, as it would definitely cause some turmoil in their ranks. To combat that the feds could limit the “Avionics Certificate” to aircraft under 12,500 or Part 91 only which is where this need is greatest.
 
The GROL is a completely useless test for certifying someone knows anything about avionics. The FCC doesn't even much put any faith in it anymore. They have placed the onus on the employer to make sure that the tehcnicians involved are properly qualified subject to employer's license. The FAA isn't handling this much differently other than they still require the worthless piece of personal paper.
 
Tom-D:
I believe most of the repairmen we are referring to have been chasing sparks for a number of years and are good at it. So I don’t think the 147 school route would be the ticket. Then we would have inexperienced techs with a piece of paper and no usable experience..
They produce A&Ps with no usable experience, we all started some where.
 
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