Two-year IA Renewal
The FAA has announced that it is extending the IA renewal period from every year to every two years. Effective March 1, 2007, the rule basically changes the expiration date of inspection authorization from March 31 of each year to March 31 of each odd-numbered year. You can click here to view the news release and read the entire rule as it appears in the Federal Register.
There is something quite strange with this new rule. Although an IA will now only be required to visit his local FAA office once every two years for IA renewal, he or she must still continue to meet the recurrency requirements each year in accordance with FAR 65.93(a)(1)-(5). So all of us who renew our IA this year will have a date of March 31, 2009 as the expiration. But if we do not meet the annual recurrency requirements between April 1 of this year and March 31 of 2008, even though we do not have to renew our certificate then, we “may not exercise the inspection authorization privileges after that date.”
Here is a scenario that is not too far-fetched. Suppose I get my IA renewed this year. According to the back of my certificate, I’m good until March 31, 2009. But the year goes by, and because of my own inadvertent oversight, I do not meet the recurrency requirements of FAR 65.93(a)(1)-(5). Technically, I can no longer exercise the privileges of an IA. But in April next year, I decide to supplement my income ’cause mama needs a new car. So I start doing some annuals in my spare time. One every two-weeks or so. By March 31 of 2009, I have roughly 20 annuals under my belt. But low and behold, when I go to my FSDO to renew for another two-year period, we find out that my IA is no longer valid because I didn’t meet the requirements during the first year of the two-year period.What happens then? Technically, I am in violation of the FARs; have been for a whole year. But what about the annuals? They were performed by an IA who was no longer authorized to perform the privileges granted to an IA, including annuals. But how was the owner supposed to know that? If the owner happened to ask to see my IA certificate, I could have shown them it showing I had another year to go before my renewal date. They did no wrong, but could be forced to have any inspections I signed off re-done before further flight.
The FAA says that this rulemaking will save the agency money. I don’t argue that. Will it save IAs money? Not really. Worse off, many IAs could be stepping into a regulatory minefield that they are not aware of until everything blows up in their face.
What do you think? Let us know. More importantly, let the FAA know. The deadline for comments is March 1.
Thanks for reading!
Joe Escobar
VERY good point and … quite possible!
Joe, the reg seems pretty straight forward. We have the same renewal requirements as before. Now we only have to deal with the paperwork for renewal every two years. Now if only the FAA would allow us to renew on line.
Yep the one year honor system. If you are close take the 8 hr class. The suggested alternate is an oral at the FSDO and we know that is not the direction they go.
When I saw the Federal Register earlier today, a similar though came to mind. I suspect the FAA maintenance inspectors will now spend their time trying to figure out if IAs are doing legal annuals and 337s instead of processing renewal paperwork. Awhile back, the rumor was that the annual inspections and major repairs or major alterations were going to be allowed to be mixed, to meet the renewal requirements. It appears the FAA still does not want to allow this.
I also find it interesting that the FAA Industry Cost Savings chart shows 15,000 IAs in 2007 and only 12,000 IAs in 2011. Are we going the way of the dinosaurs?
Why not change the requirements to 16 hours training in the 24 month period or x number of sign offs in a 24 month period. The proposed is a concern for possible enforcement action due to missing requirements by a few days.
I can see for the the back yard mechanic this would be a problem. Those of us who do this every day it will save us a lot of time and money. If you are in between jobs 8hrs of training would be a good thing.
I agree with mr. Moon, I thought that this was the way we were going to start with. The 16 hours of training in a 24 month period is the way to go.
Joe First off I think this is a step in the right direction by the FAA. We can thank, the resently retired Bill O’Brien, for getting this through for us. We also have to remember this is an IA Privilege we are given by the FAA and it comes with clear cut requirements that we should take very seriously. Your comment about starting to do some annuals, in your spare time, because mama needs a new car really rubbed me the wrong way. I make my living using my IA on a daily basis. I don’t have it just for another feather in my cap. I also take training very seriously. Maybe if we can’t remember to keep current on our training we are not taking our privilege seriously enough.
Neil,
Sorry for rubbing you the wrong way, but unfortunately it is a fact that there are a few IAs that do not take the privilege of having Inspection Authorization seriously. My sarcastic example of 20 annuals a year was just to make a point. Sadly, I knew an IA years ago that pencil whipped 6 annuals each weekend to make extra money. He was cheaper than anyone else in the area, and had enough business to keep him busy all year. The owners must also be blamed in this situation because they kept on coming back for more cheap annuals.
This change to part 65 will save honest IAs a little money without affecting safety. Apparently, it will also save the FAA a boat load of money.
The only problem comes with the few that don’t take the job seriously. It could affect not only them, but quite a few aircraft owners.
Joe Escobar
I haven’t used my IA in 25 years becuase I was a factory Tech Rep and also ran a CRS for 19 years where all of the work was signed off by the repair station and the IA was not required, but I attended the required 8 hours of training every year and really enjoyed it, I met old friends and also would actually learn something new.I have just retired and plan on keeping my IA current and I look forward to attending the meetings, I may never use my IA again but even though it is a privilege I worked hard to get it and plan on keeping it.For the people that are worried they may forget to meet the minium requirements just think about letting your drivers license expire and you will always have to re-test so I think 8 hours of training annually would not be that hard to work into your schedule. As far as forgetting about it the old IA’s can still use a day planner and the new IA’s can use a Blackberry.
Greetings to all US technicians from down under her in New Zealand. In 1990 our new rule system was enacted and became law. The rules system was based on the FAR’s. Subject to a few “bedding in” issues, that have been addressed via the amendment process, my opinion is that the rule system is working well in New Zealand. The IA system is also working very well. The IA is issued as a certificate, not a licence, and like you folk in the USA it is a privilage bestowed, if you will, upon the certificate holder by the Director of Civil Aviation to act on his behalf to review annually the documentation, airworthiness status and condition of aircraft as well as certifiy conformity of any design changes (Major Modifications or repairs) embodied. As the IA is a certificate and is issued issued for 5 years! But, like you folk in the USA the following applies:-
66.207 Recent experience requirements
The holder of a certificate of inspection authorisation shall not exercise the privileges of that certificate unless, within the preceding 12 months, the holder has:-
1. performed 4 annual reviews of aircraft maintenance in accordance with Part 43, Subpart D; or
2. performed 4 annual reviews of aircraft maintenance in accordance with Part 43, Subpart D; or
3. certified 4 aircraft or components for conformity with the data listed in Appendix D to Part 21 after completion of major repairs or major modifications; or
4. performed a combination of subparagraphs (1) and (2); or
5. successfully completed a refresher course comprising at least 8 hours instruction that is acceptable to the Director; or
6. successfully completed an examination acceptable to the Director.
As you can see, like you folk, the IA’s here are also bound by ‘recency’ requirements. What we do is simply keep a logbook and each time we perform an ARA or conformity inspection we log it. When the CAANZ carry out an audit or spot check you simply show the airworthiness Inspector your logbook. If he wants to verify the events then he simply goes to the aircraft maintenance records and confirms it. The issue and renewal training is done by CAANZ and the courses are typically around 2 to 3 days duration and are very well put together with a mixture of theory and practical tests in the form of various scenarios. The exchange of information between fellow IA’s is also very worthwhile during the training sessions. I really think you folk should push for the 5 years. Like the man from “Miami Vice” says “It works for me.”
It seems that the FAA is slowly putting mechanics on the back burner since the failure of part 66. Maybe they are realizing most IAs are part timers and that the value of an A&P is so low that even revocation is not all that threatening. I expect the FAA to slowly loosen their grip on part 91 and go where they can collect the most money and best political exposure.
I agree that the FAA has gone two steps forward and one back. While I have no problems with the the recurrancy requirements there is an obvious problem with the requirements being seperated annually. If we need 16 hrs training every two years why can’t we get it all at once instead of having to get it 8 hrs a year. I have time and enjoy the training but now have another regulatory requirement to keep track of tht could be a land mine. Plus, I have always attended the FSDO IA training classes each year. Now I wonder if the FSDO will put on the annual training now that it is not required every year. It is more of a problem then aa cure. i would have been glad to have left it the old way.
“Why not change the requirements to 16 hours training in the 24 month period or x number of sign offs in a 24 month period. The proposed is a concern for possible enforcement action due to missing requirements by a few days.”
Luther Moon, When I sent in the orginal letter to the faa I wrote it that way. but some people were complaining about going a year without Training. So I guess the FAA thought to change it. Here is how the orginal letter read.
U.S. Department of Transportation,
Docket Management System,
400 7th Street, SW.,
Plaza Level 401,
Washington, DC 20591.
In accordance with Part 11, section 11.61, of CFR Title 14, of the Federal Aviation Regulations I would like to submit a petition to change the following sections in Part 65 Certification of Airmen other than Flight Crewmembers: Section 65.92, Inspection Authorization, Duration and Section 65.93 Inspection Authorization –Renewal.
Discussion of the proposed changes:
The changes to the above sections would allow the Inspection Authorization (IA) to remain in effect for a 2-year period instead of having to renew the IA each year. This small change will reduce the paperwork and cost requirements for both the FAA and the IA by 50%. However, the two year renewal requirements (annuals, major repairs and major alterations, and progressive inspections, would be doubled the 1 year requirements, so the requirement for IA activity and safety is not compromised.
Explanation why this action would be in the public interest:
1. Extending of the renewal from 1 year to every 2 years does not reduce the IA activity requirements.
2. It will reduce FAA’s Flight Standards District Office processing of FAA Form 8610-1 IA Renewals by 50%.
3. It will reduce FAA Flight Standards District Office notification of IA renewal meeting mailings to IA by 50%.
4. It reduces the IA time spent on filling out FAA Form 8610-1 IA renewal by 50%.
5. It will improve IA Renewal training by having the ability to offer 8 or 16 hr classes or 1-hour classes spread through out the 24-month period.
6. It will reduce by 50% the man hours spent recording the new authorization at Airmen Records in Oklahoma City and revising AC 65-13 FAA Authorization Directory.
7. This revision will not impose any additional regulatory or cost burden to the industry or the FAA
8. It would have a positive effect on the industry because government requirements for data and renewal paperwork are reduced by 50%.
9. This proposal would have no effect on the natural or social environments.
10. It reduces by 50% all FAA and industry accrued costs for IA renewal.
The revised rules should read as follows:
§65.92 Inspection authorization: Duration.
(a) Each inspection authorization expires on March 31 of each uneven numbered year. However, the holder may exercise the privileges of that authorization only while he holds a currently effective mechanic certificate with both a currently effective airframe rating and a currently effective powerplant rating.
(b) An inspection authorization ceases to be effective whenever any of the following occurs:
(1) The authorization is surrendered, suspended, or revoked.
(2) The holder no longer has a fixed base of operation.
(3) The holder no longer has the equipment, facilities, and inspection data required by §65.91(c) (3) and (4) for issuance of his authorization.
(c) The holder of an inspection authorization that is suspended or revoked shall, upon the Administrator’s request, return it to the Administrator.
§65.93 Inspection authorization: Renewal.
(a) To be eligible for renewal of an inspection authorization for a 2-year period an applicant must present evidence every two years, during the month of March on uneven numbered years, at an FAA Flight Standards District Office or an International Field Office that the applicant still meets the requirements of §65.91(c) (1) through (4) and must show that, during the current period that the applicant held the inspection authorization, the applicant –
(1) Has performed at least one annual inspection for each 90 days that the applicant held the current authority; or
(2) Has performed inspections of at least two major repairs or major alterations for each 90 days that the applicant held the current authority; or
(3) Has performed or supervised and approved at least two progressive inspections in accordance with standards prescribed by the Administrator; or
(4) Has attended and successfully completed a refresher course or courses, acceptable to the Administrator, of not less than 16 hours of instruction during the 24-month period preceding the application for renewal; or
(5) Has passed on oral test by an FAA inspector to determine that the applicant’s knowledge of applicable regulations and standards is current.
(b) The holder of an inspection authorization that has been in effect for less than 90 days before the expiration date need not comply with paragraphs (a) (1) through (5) of this section.
being in aviation 58 years, i’m glad to wind down ..AND i consider FAA in general .,, a HUGE
bunch of under educated assholes .. thank you ………
Oddly enough, I stumbled across this information this morning, as a result of my own desire to know exactly what the current requirements are as far as the forms that I need to mail in to the FA for my IA renewal. I have received NO mailed notification this year of forms required, NO e-mail notification, NO phone call, nothing. So while searching the net for any information that I could ferret out, I found this website that tells me that I’m now only required to renew my certificate every 2 years, oddly numbered. I’m still sitting here in a steam because I have heard no news of this in any fashion from anywhere. The FAA has every piece of geograhpical, and electronic contact information that can possibly be available for me, and I have to find this by stumbling across it while looking for something else. If they’re going to save huge amounts of money on this scheme, seems to me they should possibly invest a tiny bit of it, making sure that we in the field are notified of what’s going on.
My opinion of the actual rule change is that it will maybe be a wash as to effect. The requirements apparently will not change, you simply have to make the effort only every 24 months instead of every 12. I qualify yearly on the basis of annuals completed, but still attend a renewal seminar about every other year regardless, simply to keep up on current information. I’m actually much more concerned about placing my certificate into the safekeeping of the US postal system for the amount of time it takes to send it and receive it back from the FSDO, since you almost can’t get into the buildings anymore in person. I HATE letting that slip of paper out of my hand for 2 weeks. My Crackberry® does indeed have the entire month of March calendared to notify me daily of the necessity of renewing my IA certificate. I spent a lot of time and effort earning the right to exercise the priviledges inherent in that card.