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EAA Comments on NavWorx Airworthiness Directive
December 22, 2016 - EAA submitted comments on a proposed FAA airworthiness directive (AD) concerning NavWorx ADS-B systems that would set a troubling precedent involving FAA oversight of “non-certified” parts commonly used in experimental aircraft. The AD covers the company’s model ADS600-B units (part numbers 200-0012 and 200-0013) and model ADS600-EXP units. EAA objected to the inclusion of the latter model in the AD, as it is produced solely for the experimental and light-sport markets.
Thanks to previous advocacy work conducted by EAA, in 2012 the FAA clarified that airworthiness directives do not apply to experimental aircraft unless specifically noted in the AD’s applicability statement. In this case, experimental aircraft owners must in some way address any airworthiness concerns on the parts used in their aircraft that are outlined in the AD. But ADs are only used to address airworthiness concerns in items, such as an engine or propeller, that are intended for use in type-certificated aircraft. ADs are never used against “non-certified” parts, which is why the proposed AD would set a troubling precedent.
The FAA only requires experimental aircraft owners to meet the performance standards of FARs 91.225 and 91.227 in order to satisfy the ADS-B out mandate. Therefore, the aircraft owner is the final authority in ensuring compliance.
“If a potential unsafe condition exists in any product installed on an aircraft operating in the NAS, EAA does not object to manufacturers and operators being alerted through appropriate means. But an airworthiness directive is not appropriate to address such an issue regarding a part that was never intended for installation in a type-certificated aircraft,” EAA Vice President of Advocacy and Safety Sean Elliott wrote in the comments. EAA requested that the FAA withdraw the AD for the ADS600-EXP and instead communicate safety concerns through non-regulatory special airworthiness information bulletins (SAIBs) or safety alerts for operators (SAFOs).