Type-rated IAs?
Last week, a change to IA renewal requirements was posted in the Federal Register. Effective March 1, this new rule would only require IAs to renew their certificate every two years with the FAA, although annual recurrency requirements would remain in effect. I discussed this topic in my last blog. You can read it by clicking here.
The Aircraft Electronics Association (AEA) took the opportunity to submit comments to the proposed rule change. In its comments, AEA took the opportunity to suggest that the FAA should further change Part 65 to implement a rating system for IAs. AEA says, “Aviation safety is a critical role of all who maintain aircraft and aviation products. The FAA has continually added additional controls to repair stations under their concern for aviation safety. The Association proposes to place the same limitation on the privileges of an A&P with Inspection Authorization that the Agency is placing on a repair station.”
Here are the proposed changes submitted by AEA:
… the Association proposes to establish a rating and limitation requirement for the issuance of Inspection Authorizations through the following changes to 14 CFR Section 65.95.
Amend paragraph a(1) to read:
Section 65.95 Inspection authorization: Privileges and limitations.
(a) The holder of an inspection authorization may –
(1) Inspect and approve for return-to-service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under Part 121 of this chapter) for which the holder is rated and within the limitations in their certificate after a major repair or major alteration to it in accordance with Part 43 of this chapter, if the work was done in accordance with technical data approved by the Administrator; and
(2) Perform an annual, or perform or supervise a progressive inspection according to §§ 43.13 and 43.15 of this chapter.
Section 65.97 Ratings.
The following ratings are issued under this subpart:
(a) Airframe ratings.
(1) Class 1: Composite construction of small aircraft.
(2) Class 2: Composite construction of large aircraft.
(3) Class 3: All-metal construction of small aircraft.
(4) Class 4: All-metal construction of large aircraft.
(b) Powerplant ratings.
(1) Class 1: Reciprocating engines of 400 horsepower or less.
(2) Class 2: Reciprocating engines of more than 400 horsepower.
(3) Class 3: Turbine engines.
(c) Propeller ratings.
(1) Class 1: Fixed-pitch and ground-adjustable propellers of wood, metal, or composite construction.
(2) Class 2: Other propellers, by make.
(d) The FAA may issue a limitation to the holder of an Inspection Authorization that maintains or alters only a limited type of airframe, powerplant, or propeller.
AEA says, “Why should a business with a quality system, a reviewed and accepted business plan and an approved employee training program be regulated when 60,000 individuals without a quality system, a business plan or a training program have unlimited authority for return to service of aircraft, engines, and accessories?”
You can read AEA’s comments by clicking here or visiting www.aea.net.
What are your thoughts?
Thanks for reading,
Joe Escobar
If the FAA is changing the IA renewal in order to save 50% on administrative costs, don’t see them even considering the added time, regulation, and $$$ to add additional ratings.
Another thought: Type-rated IA would be a different beast all by itself, similar to aircraft type ratings (e.g. CRJ) sought by pilots.
What they’re proposing is a class rating on an authorization(???), not a type rating.
Good point on the class rating Gary. Thanks!
I agree with the cost issue you brought up in your first comment. I can understand why AEA would submit these proposals in its comments. After all, it has brought the issues to the main stage and gotten some exposure in the trade press. I doubt the FAA will delay the effective date of the changes to Part 65 because of AEA’s comments. We’ll have to see if the agency takes any future action based on AEA’s suggestions.
Joe Escobar
Why is it that the Aircraft Electronics Association is so interested in putting down IA’s? Simply because they don’t like the fact that there are responsible and hard working A&P’s and IA’s who don’t belong to their organization? Many of us have training well above their minimums and implement our own quality control in what we sign off. Let’s see how many of the pencil pushers and bean counters are capable of inspecting, repairing, returning to service and then test flying the aircraft to ensure that everything is correct. Then, and only then, do they have the right to spout off.
Why is it that a business like the AEA that has “a quality system, a reviewed and accepted business plan and an approved employee training program” not able to return to service quality equipment for the installation into the aircraft that the IA is responsible for. Yet we have the ability to troubleshoot the faulty repaired electronic component. Keep up the good work AEA. You keep the IA’s and A&P’s working.
If the FAA is trying to save money this system AEA is pushing certainally will not.
Type ratings or limitations are an interesting topic in regards to the Inspection Authorization holders. It is my personal belief that we will eventually see regulations like this regardless of the associated cost, and that it will even work its way into license limitations for Airframe and Powerplant Mechanics. It is my opinion that as the technology used in current aircraft and rotor craft continues to advance we will be forced by limitations in our knowledge and training (more specifically the time available to learn, train, and remain current) to specialize in specific areas or segments.
With such a fantastic “Quality System” , ” Business Plan” , and Training program in place, why do we get DOA Radios, Instruments, and Black Boxes All The Time ! Typical Gravyonics Bigwigs !
More of the same, we’ve heard this so many times. What makes a group like this (AEA), think that we, the IA’s need tightened up on, or our shoulders looked over. I don’t need a sparkey, telling me how to do my job. I think they need to redue the FCC thing. I have the FCC license. I have never used it. I use my A&P, and IA every day. I think the FAA needs to tighten up on the Avionics guys, and make them get the A%P, or A, and get off our coat tails. Those give-me repairman license’s are a joke. If you want to fix a system, fix yours….
these guys should consider the avionics guys and put more emphasis on what their qualifications are. as a mechanic i can repair airframe and engine components and also repair or install radios and other avionics. can an avionics tech repair a crack in a wing or replace tappets in an engine? i don’t think that most of them would have the knowledge to do so.
For over the past 17 years I have seen many of the changes made that prop more and more responsibility on the shoulders of A&P’s and those with IA authorizations. Then along come groups who have no idea regarding the work being done by those of us who have the ratings trying to make us live to the standards that repair stations do. Many of the repair stations can hire anybody off the street, provide training, and cut them loose on projects under the scope of their repair station limitations. But I also know that those same individuals are never required to sign off any of their work like A&P’s and IA’s. I see a lot of avionics shops come, and I have seen many go; and then I see the mess we are left with under the panels when we have to do other repairs to the aircraft. Old harness tied up in bundles, improperly patched antenna holes, and I can’t tell you how much I hate in-line fuse holders that are not labled, and powering who knows what. There is a reason that the FAA is wanting to crack down on repair stations, and this is just a few examples. I for one have worked hard for my certificates, and I am proud to use and sign off when I do the work. AEA needs to stick with working for their members and stop trying to make our lives any more difficult than they are already.
Thank God I also have an associates degree in welding.
I have found more hardware and tools left in airplanes by avionics technicians than any AP/IA. I have had to reroute complete wire bundles to gain movement without interference for control columns, control cables, and who knows whatelse. Seems these guys only care about the gettng it done and billing it out, don’t worry about what it takes to make it right, that is what the AP/IA is for. I have my rating, it’s called an Airframe and Powerplant license with Inspectors Authorization. What’s your’s?
Thank God, atleast they are planning for a change. Let me tell u this was overdue as far as aviation safety and cost effectiveness is concerned. Rest all what you all said is right.
Well I believe the AEA may be on the right track. Ego’s aside, It is in the best intrest of the aviaiton industry. I will further state that the FAA needs to incorporate the same standards as our european counterparts. A&P mechanics should be type rated on each specific airframe and powerplant they work on. This would force the employer to formally train its people which would improve safety across the board.
Most of the time these “electronic experts” mess up more than they fix concentrating only on there one system. One with a Repair Cert actually made up a new metal dash without doing a wt and bal nor did they give the owner a new revised one when done. As a IA I had to have the plane wt/bal re-done costing the owner more of his hard earned $. I notified the FAA field office that a 337 form and/or new wt and bal was not done by these “experts” and that the plane was released to the owner for flight. Lucky the owner brought it to the shop with the statement… something doesn’t feel right. The plane was way out of the envelope.. tail heavy. Had he flown it.. we would have read about it in the NTSB report. The mechanical attachment ponts for the panel were simple hose clamps. ya that works. And these are the same “experts” who want me to do what??? sounds like its all about the money!!! I would like for them to expand on just how safe this new proposed system is going to make us!!. Clearly they have not read the FAR’s as to the larger engines which all are supercharged. May I suggest that they learn how to read first and then start to flap their lips… about what I should do. Yes I see a definate love hate relationship between the electronic “experts” and the IA&P’s. Only thing is we make it right. And that may be why the FAA doesn’t allow them to return a aircraft to service by themselves. Do you think the FAA doesn’t know? They should just stick to fixing the electronics… and let us do our job to keep the sky’s safe. it appears that they can’t.
but, if they want the liability (insurance and all) hey knock yourself out. Bet them so called “experts” never thought of that part with all the money they think we make.
As to the two year renewal… the FAA is going to be the loser. Their first remark is .. were here to help… the second remark is … whats new. Lots of smiles from our side… (they look real pretty wearing a suit and tie when they come to “Help” wonder what they use to get the blood off the clothing when they do “Help” I have yet to see one show up in a dirty jump suite.. to “help”) … They learn more from us than we from them. Why because were in the field where the airplanes are and they arn’t. They are in a nice a/c office pushing paper. its going be interesting to see how this is going to work.
Oh and the cost of a certified specialist is going to do what to the owner? If the shop has to type rate its mechanics.. now just who do you think gets stuck with the overhead cost??? Do we see a “expert” electronic repair person rated for only Nav Radios? and another for a Com radio?… Do we see the “expert” type rated for each black box? I don’t think so… not only would it be a financial problem for the “expert” but who is going to pay for his review every two years? he would be out of a job too, same for mechanics. Really dumb idea when one thinks about it… most mechanics know their limitations and respct that. If he wants to know more he goes to school and does exactly as what the “experts” say he needs to do… hmmmm… so in reality the system is already doing it…
A fundamental issue has been overlooked here. The IA privilege is only used for aircraft and rotorcraft weighing less than 12,500 Lbs. The “AEA” whom I have never heard of is probably misguided by the fact that avionics technicians are overwhelmingly former military or civilian electronics technicians with a repairman certificates.
A&P IA’s have had to complete approved training, proven by testing that they are qualified and have had sufficient experience.
Since accident investigation statistics show that the majority of crashes are due to pilot inattention, poor preflight planning, fuel starvation and inadvertent flight into IMC or operating into conditions that far exceed pilot skills and experience. The current system is working.
This is why the FAA has been pushing the “Personal Minimums” issue with pilots.
The AEA (who ever they are) is probably crying sour grapes here. If they want to have the systems equal and improve quality standards, I would recommend they be required to have airframe licenses for most of their work and power plant licenses for the installation of any engine monitoring devices and sensors.
My foundation for my opinion is based upon 21 years of experience comprised of 11 years as a US Army MX Sergeant, 18 years of experience as a licensed A&P and 15 years as an A&P IA. I have worked under FAR part 121, 135, 91 and the full gambit of 65 and 43.
Did the AEA try reading FAR 65.81(a)? “However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date.”
Also, just had a visit from my FAA inspector yesterday (one of our a/c caught a gust and went up on the nose & curled the prop). Happily, he does do a good job (and all my records were in order). But, we talked about the two year renewal. He doesn’t like it, either, since he still has to check on us every year (no savings of his time) and, if someone is using their IA without meeting currency requirements after a year, he has to violate them (much more time and FAA money). His personal opinion is that the two year renewal will cost the FAA more money in the long run.
If one wants to effect a change in the status of A&Ps and IAs perhaps lobbying for a change from “unskilled” to “skilled” labor, as per the U.S. Department of Labor, might be a better investment of time and energy than yanking the chains of grossly underpaid mechanics. Side note: we will be canceling any & all funding of AEA subscriptions & activities. It is obivious the organization no longer represents the welfare of aircraft technicians. Maybe a leadership change is called for.
For over the past 17 years I have seen many of the changes made that prop more and more responsibility on the shoulders of A&P’s and those with IA authorizations. Then along come groups who have no idea regarding the work being done by those of us who have the ratings trying to make us live to the standards that repair stations do. Many of the repair stations can hire anybody off the street, provide training, and cut them loose on projects under the scope of their repair station limitations. But I also know that those same individuals are never required to sign off any of their work like A&P’s and IA’s. I see a lot of avionics shops come, and I have seen many go; and then I see the mess we are left with under the panels when we have to do other repairs to the aircraft. Old harness tied up in bundles, improperly patched antenna holes, and I can’t tell you how much I hate in-line fuse holders that are not labled, and powering who knows what. There is a reason that the FAA is wanting to crack down on repair stations, and this is just a few examples. I for one have worked hard for my certificates, and I am proud to use and sign off when I do the work. AEA needs to stick with working for their members and stop trying to make our lives any more difficult than they are already.
Yes, well agreed!
But……….A fundamental issue has been overlooked here. The IA privilege is only used for aircraft and rotorcraft weighing less than 12,500 Lbs. The “AEA” whom I have never heard of is probably misguided by the fact that avionics technicians are overwhelmingly former military or civilian electronics technicians with a repairman certificates.??????????
My foundation for my opinion is based upon 21 years of experience comprised of 11 years as a US Army MX Sergeant, 18 years of experience as a licensed A&P and 15 years as an A&P IA. I have worked under FAR part 121, 135, 91 and the full gambit of 65 and 43.
Really???? are you sure?????
65.95 Inspection authorization: Privileges and limitations.
top
(a) The holder of an inspection authorization may—
(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 [New] of this chapter, if the work was done in accordance with technical data approved by the Administrator; and
(2) Perform an annual, or perform or supervise a progressive inspection according to §§43.13 and 43.15 of this chapter.
Please read the reg and look at the word ANY!!!!
Here is what A.E.A. has to say regarding this subject, copied direct from the A.E.A. Website. I would suggest that all send their comments and concerns to Mr. Ric Perry of the AEA, as well as responding to the NPRM via public comment at http://dms.dot.gov/osting
AEA Asks: Why Treat IA’s and Repair Stations Differently?
REFERENCE: AEA Comments on the FAA’s 2- Year IA Renewal Rule.
[Click here for a copy of the Federal Register]
[Click here for a copy of AEA’s comments]
SUMMARY:
The Aircraft Electronics Association, in its comments to the FAA, asks a simple question: Why should the FAA regulate return-to-service differently?
Why should a Part 145 business with a quality system, a reviewed and accepted business plan, and an approved employee training program be regulated when 60,000 individuals without a quality system, a business plan or a training program have unlimited authority for return-to- service of aircraft, engines and accessories?
In its comments approving of the FAA’s proposed 2-Year Renewal Rule, the AEA petitions the FAA to regulate IA’s with the very same ratings and limitations that are placed on repair stations.
For More Information, Contact:
Ric Peri, vice president of government and industry affairs for AEA, by e-mail: ricp@aea.net, or by phone: 202- 589-1144; fax: 202-220-3104.
The basic responsibility of the IA is to certify that the work accomplished was done in accordance with data approved by the administrator. The repair station actually does the work with non certified people. Therfore needing more oversite by the FAA. The oversite covers those non certified people. How can a IA have a business plan and trainingg program for the A&P’s that are doing the work they inspect? Didn’t all A&P’s go through a training program in order to be a certificated airman? The business plan is that A&P’s are doing the work. Quality? Will an IA sign off a persons work who knows nothing of part 43? So aren’t we covered?
Or is this some plan to create another buracracy. How many IA’s will it take to sign off a major alteration that has structures, electrical and hydraulics? Not to mention completions and mission modifications. Are there going to be enough IA’s in the area to get these sign offs done? Is a FBO going to need to hire five IA’s for every A&P?
AEA=HUA
This is simply ploy by AEA to increase their income . Who do you think would put on the required training classes for these new ratings?
I have attended AEA’s IA renewal classes and found them to be nothing but a review of the regulations. They have no added value. Now they will be doing the same thing for the new ratings. Just taking advantage of the requirement to increase their bottom line.
Oh well…AEA comments are part of the downside of free speech. They need to spend the time they waste talking nonsense to police their own. Just need to consider the source and take it for what it is worth, which is probably more substance less BS from some slick stupid mouthpiece that never touches an airplane or related article. AEA…please stick with what you know and stay out of things that you know little about. And by the way AEA,your IA refresher courses suck big time. I stay current on things I work on by working on them and using my hands and mind, study on my own throughout the year, and re-take the IA exam every year before 31MAR. I guarantee I stay more current on what I need to know than alot of people. Go away AEA, you make me sick.
I find it interesting that an industry which has very few FAA licensed people working is complaining about those of us who have gone to the trouble to obtain this rating while their people may have to get a repairman’s certificate. Maybe they want to make sure all of their employee’s meet the same requirement we do but then they would have a hard time finding qualified people and would have to pay them more. It is interesting that the AEA would want to have so much input on things that I don’t see them working on. How often do you work on piston engines period let alone ones over 400 HP. Maybe we should be submitting suggestions to the FAA on things the AEA should be monitored on. From the comments submitted and my personal experiance I am sure we could come up with quite a list.
Joe,
I agree with most of the IA’s in that this proposal will lead to unneeded bureaucracy, higher costs all around. My question to AEA is if you are proposing a regulation shouldn’t you also have the means in place for IAs to become “rated”, who picks up the tab for that, the IA, the shop, who? Not all IA’s work in shops large enough to send people off for additional training.
Sounds like this proposal will leave alot of us holding the bag.
I’ve worked with a lot of avionics technicians over the years in the airline industry, and while I have a lot of respect for their abilities to troubleshoot avionics related systems, very few of them know much about the rest of the A/C. On the other hand, a good inspector for the airline does not necessairly have to have an intimate knowlege of what he is inspecting to do a good job. He just needs to know what questions to ask. I doubt that there are many IA’s that are going to buy off something without knowing what they are signing off on
I cannot figure why the AEA needs to susbmit regulatory changes that do not affect them. I work on light aircraft in the middle of nowhere and I understand that I am not prepared to work on a Saber’s navigation system. I do not need another regulation to tell me what I already know. It will just create another level of bureacracy that they will want us to pay for.
As a A/P and IA with 20 years plus of experience, my question would be how would a person document experience? I have worked on helicopters (turbine and piston) and fixed wing aircraft piston 400 HP less and greater than 400 HP, also turbine powered aircraft. I have not kept a logbook like the pilots due. How would I prove my past experience? Their is plenty of “chop shops” out their with a AEA certificate on the wall. AEA needs to stick to their repairman.
Knowing that it took me 3 1/2 years just to change the IA renewal to two years, and the 20 other items we tried to get passed but didn’t. The AEA doesn’t have a chance. Plus there will be too many people in opposition to it. That will surely make it die on the vine.
Nothings perfect, but………
It would be nice for some IA’a to take a little more pride in what they do, and take it upon themselves to study and stay engaged in those things they need to. I see IA’s that can’t fill out a 337 or do a weight and balance to save their lives, can barely make a log entry. I’ve also worked in Repair Stations run by idiots who seem to think that their inspectors are “silver bullets” for anything that may go wrong. Instead of having sound effective Preliminary Inspections, Hidden Damage Inspections, In Process Inspections, and Final Return to Service procedures in their CRS manuals and sticking to them and making their people accountable for what they do to aircraft in their facilities, they put it all on the inspectors backs. These same morons typically give the inspector ALL the responsibility of ensuring a CRS maintained article is airworthy, but little to no authority to make sure it is. But still, the inspector catches hell when things go wrong after the fact.
And hey, who hasn’t seen the CRS Inspector who doesn’t know what he’s inspecting to the point production grinds to a halt while he/shes being educated on what he/she’s really should know to begin with? Wow! How did this person become an inspector? “We won’t go there” I’ve seen this to some degree in every Repair Station I’ve ever worked in for the past 10 years. It wasn’t always that way. People used to have pride and accountability in what they did in this country. Folks used to take responsibility for their actions and were proud of their work because it was good. They didn’t look for ways not to.
I’ve never seen a piece of paper full of bureaucratic crap fix an airplane ever. But I seen talented techs with good skills, and knowledge that were supported with adequate resources by good managers do lots of good work.
More and more things are being out sourced from our country. If we all don’t collectively “get it together” among ourselves, who knows? Aircraft maintenance may be next. Real change, improvement, and maintenance of many good things come from within. We all need to take a close look at ourselves.
If we can’t handle our own, on our own, sooner or later the Government will. And when we don’t like their methods, we only have ourselves to blame.
Does not 65.81, General privileges and Limitations. Already accomplish what AEA seeks?
Having looked a little more into this I have to argue that myself and my employees have met the minimum requirements of the FAA.
I am sorry if the AEA’s employees cannot.
AEA will lose this argument.
AEA has certainly approached this from a position of towering ignorance. They’d be far better off working with other aviation alphabet groups rather than sniping with comments such as this. Building ill will is not the way one thrives in the small aviation community. I hope AEA discovers this before they are branded a pariah.
IA and FCC General Radiotelephone
AEA wants to put those of us who have an IA and a FCC license simply because we can do everything that a repair station can do including repair radios. Simple economics. What is interesting is that the industry pushed to have non-licensed people work on aircraft because they were cheaper so the FAA said sure thing, we will call these dens of incompetence “repair stations”.