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pmanton

pmanton

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N1431A
They're after us part timers

They’re after us part time guys

To all IA's, A&P's and concerned antique/classic owners,
The FAA has issued a policy (http://edocket.access.gpo.gov/2010/pdf/2010-27834.pdf) which is intended to clarify the definition of "Actively Engaged" for purposes of issuing and renewing the A & P Inspector Authorization. It appears to be an attempt by the agency to by-pass the IA renewal requirements contained in FAR 65.93 and hand the IA renewal process over to individual FAA individual Aviation Safety Inspectors (ASI), who will be exempt from said new requirements/policies!
You can read a bit more about this proposed "policy change" at: http://www.aea.net/governmentaffairs/regulatoryupdates_item.asp?ID=55 and/or http://www.aero-news.net/index.cfm?ContentBlockID=d12fa23e-83b5-47b9-9e17-c50faba0e0ae.
Time is of the essence however in commenting on this matter (Docket # FAA-2101-1060). It was published in the Nov 5th, 2010 Federal Register with a comment period to close on Dec. 6th, 2010.
This blatant and bald face attempt by the FAA to by-pass the FAR requirements for IA renewal is a serious threat not only to the livelihood and viability of general and sport aviation but also to aviation safety itself. Please take the time today to read this proposal (via the link above) and submit your comments to the FAA electronically, via US Mail or by FAX (information on how to do each is contained within Docket # FAA-2010-1060).
Please feel free to pass this information on to any and all A&P's, IA's and concerned aircraft owners you may know.
 
I see nothing changing.

Quote
The FAA intends this policy statement to clarify rather than change the definition of ‘‘actively engaged’’ and provide clear guidance to ASIs that can be applied consistently. The FAA intends for this clarification to be in effect for the next IA renewal cycle in March 2011.

end quote

WE all fill out an activity sheet for each year, and send it in with the request for renewal.

We are required to complete 4 annuals, or 8 337s, or a mix of each to qualify.

The FSDO ASIs are required to screen each applicant every time they request a certificate or a renewal. It's always been that way.

the difference in the reading is the ability of the ASI to waver any of the requirements. and that has not been happening at the SEA FSDO for as long as I can remember.
 
dmccormack said:
I don't see how it threatens part timers and antique owners..?
Click to expand...

The problem the FAA sees is the part 135 operators have a DOM to do all the return to service entries and the A&P-IAs never get a signature they can count for renewal. Those folks are covered by the ability of the FAA ASIs to review on a one on one bases. So the A&P-IA who hides in the back office and does nothing but research and other paper work will in fact get the boot.( I think that is a good thing)

The FAA has ran renewal classes a each year for any one who wanted to attend, this covered the renewal for any A&P-IA who did not qualify on their activity sheets. I do not know if the FAA will continue this practice. If it does not the old Codgers who hide out all year and go to the two day school will go away too.

So if you are doing the 4 annuals per year no problem, if you are hiding in the woods and doing nothing I'd be worried like the Avionic shops. referenced in the OPs post.
 
Tom-D said:
So if you are doing the 4 annuals per year no problem, if you are hiding in the woods and doing nothing I'd be worried like the Avionic shops. referenced in the OPs post.
Click to expand...


Ok... I still don't see the connection to "concerned antique/classic owners"

I'm guessing this post was a cut and paste from another board....
 
Notice who is waving the red flag ?

AEA: FAA To Restrict A & P Recognition

These guys are the portion of the GA that do upgrades to the instrument panel.

I'll bet we see a lot more 337s for radio upgrades. The aircraft may or may not need them, but the IAs do. :)
 
Tim said:
If nothing is changing, then there is no reason to clarify the rule!
Click to expand...

It's a clarification for the Aviation Safety Inspectors in their handbook, Order 8900.1. It just gives the ASI some leeway in determining "actively engaged" because in the past there were some misinterpretations.
 
Rotor&Wing said:
It's a clarification for the Aviation Safety Inspectors in their handbook, Order 8900.1. It just gives the ASI some leeway in determining "actively engaged" because in the past there were some misinterpretations.
Click to expand...


Something smells fishy to me.
 
Thank you for posting N1431A. I was getting ready to do it myself. Unfortunately this is complex and most people don’t understand the full implications and I don’t have the time (i.e. a lot of time) to explain it. Looks like the FAA will get this one through and make things just that much more difficult.

Thought experiment:

Define “actively engaged”

Now think about what the FAA wants to do with their definition of “actively engaged”.:rolleyes2:

Now think about how this might affect YOU, even if indirectly.:confused:
 
aventhu said:
Thank you for posting N1431A. I was getting ready to do it myself. Unfortunately this is complex and most people don’t understand the full implications and I don’t have the time (i.e. a lot of time) to explain it. Looks like the FAA will get this one through and make things just that much more difficult.

Thought experiment:

Define “actively engaged”

Now think about what the FAA wants to do with their definition of “actively engaged”.:rolleyes2:

Now think about how this might affect YOU, even if indirectly.:confused:
Click to expand...

I would also be wary of the black helicopters flying around your neighborhoods.
 
Tim said:
If nothing is changing, then there is no reason to clarify the rule!
Click to expand...
Thank you for speaking my mind before I had the chance to.
+1, and +100000 for that theory applied to bureaucratic rulemaking in general.
 
dmccormack said:
I don't see how it threatens part timers and antique owners..?
Click to expand...

After due thought process I believe the answer is simple, these Antiquers do one aircraft, (theirs) and then go to refresher course to renew. The ASI's now have the ability (like they always did ) to disqualify them on the bases they are not meeting FAR 65.93. And IMHO they aren't. "actively engaged"
 
Last edited:
This was my E-Mail to EAA

The EAA should support the FAA's trying to eliminate the A&P-IAs that are not working in the industry. each A&P-IA submits an activity sheet each year to renew their IA. the only people who will be effected are the IAs who do not do annuals or return to service 337 major repair/modifications. people who actually work in the industry such as part 135 A&P-IAs do not get signatures that count, so they still can re-qualify by attending the FAA sponsored re-training, The IA who work Certified Repair Station can still re-new because they are working.

This proposal does Nothing to changed the rules to re-qualify. Nor does it change the method the ASIs in FSDO review the A&P-IA's activity, they will continue to review the activity sheets for 4 annuals, or 8 337s or the retraining each IA submits,

It's actuality it is a good thing to drop those IAs who are not active in the industry. The A&P-IA who re-quals on the FAA sponsored training so they can maintain their own aircraft are those who are raising the red flag over this, not those of us that actually work for the GA public.

Tom Downey A&P-IA
EAA member/Vintage aircraft
http://www.whidbey.net/fairchild-nc19143/

This was their response

Thanks Tom, I just spoke with the folks at AFS-350 about this, and you’re right, as long as a A&P-IA meets the requirements of FAR 65.91 and 65.93, and qualifies using one of the 5 different methods spelled out in .93, they are deemed “actively engaged.” Only those who are not willing to meet those requirements would be in jeopardy of losing their authorization, and that’s the way it’s been for many years. I’ll have more on this shortly in Vintage Aircraft Online and in the posts on Oshkosh365.



Best Regards,

H.G. Frautschy, EAA Lifetime 203490
Executive Director, EAA's Vintage Aircraft Association
Editor, Vintage Airplane magazine & Vintage Aircraft Online


EAA-The Spirit of Aviation
Phone: 920.426.4825
Fax: 920.426.6579
www.eaa.org
www.vintageaircraft.org
EAA AirVenture Oshkosh 2010 was fantastic - Visit www.airventure.org for more on this year's event. For the awards list, click here.

For more information on our e-newsletter, Vintage Aircraft Online, click here.

See you at EAA AirVenture Oshkosh: July 25-July 31, 2011
 
This Dog Don't hunt! If it ain't broke, Fix it till it is! From, FAA guide for better understanding.
 
aventhu said:
[Now think about what the FAA wants to do with their definition of “actively engaged”.
Click to expand...

Their Definition of "Actively Engaged" is defined in FAR 65.93, that has not changed, nor has any rule we call FARs

we are required to complete 4 annuals, or 8 return to service of 337s, that is the way it has always been, and that has not changed.

It's pretty clear to me, all the old codgers that hid in their hangars and do 1 annual on their aircraft, are going to be required to show the minimum requirements or go away.

So annual inspection costs should drop because now those old codgers will be looking for the other 3 annuals to do.
 
Additional info via EAA


IA Renewal Information
&
Questions and Answers
Holders of an FAA Inspection Authorization will not be required to renew their certificate
until March of 2011. However, each IA holder must maintain eligibility to hold the
certificate throughout the two year renewal cycle. Written documentation to support
continued eligibility through March of 2010 is required to be included with the renewal
application package in March of 2011.​

For the purposes of IA activity, the year begins on April 1st and extends through
March 31st. During this 12 month period, holders of an FAA Inspection
Authorization must meet one of the renewal requirements set forth in 14 CFR
§65.93(a).​

Those requirements are:​

14 CFR §65.93(a)(1): Has performed at least one annual inspection for each 90 days
that the applicant held the current authority. These four annual inspections could be
performed at any time during the year. Some individuals incorrectly assume that at least
one annual inspection must be completed during each 90 day period.​

OR​

14 CFR §65.93(a)(2): Has performed inspections of at least two major repairs or major
alterations for each 90 days that the applicant has held the current authority. Likewise,
the completion of these activities need not occur during each 90 day period. You may
renew on either annual inspections OR major repairs/alterations – not a combination of
both.​

OR​

14 CFR §65.93(a)(3): Has performed or supervised and approved at least one
progressive inspection in accordance with the standards prescribed by the
Administrator.​

OR​

14 CFR §65.93(a)(4): Has attended and successfully completed a refresher course
acceptable to the Administrator, of not less than 8 hours of instruction during the 12
month period preceding the application for renewal. Many renew an IA through
attending the classes provided at an annual approved IA symposium. Many of the
manufacturer’s training courses have also been approved as a basis for IA renewal.
Generally these courses will display an FAA approved course number on the certificate
of completion. There are also a number of approved computer based instruction
courses available on the internet.​

OR​

14 CFR §65.93(a)(5): Has passed an oral test by an FAA inspector to determine the
applicant’s knowledge of the applicable regulations and standards are current. This
method of renewal may not be your first choice, but it is a viable option which allows
positive interaction with FAA personnel during the renewal process.
Oral test will be based on the current revision of the FAA Inspection Authorization
Knowledge Test Guide FAA-G-8082-11B and IA privileges and limitations per Title 14
Part 65.​

NOTE: 14 CFR §65.93(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.​

In March 2011, IA Certificate holders will be required to submit a Mechanic’s Application
for Inspection Authorization, FAA Form 8610-1, in duplicate, with the documentation
establishing your compliance with 14 CFR 65.93(a) during the previous two year period.​

An IA who does not meet one of 14 CFR §65.93(1) to (5) during the first year may not
exercise IA privileges after March 31 of the first year. (14 CFR §65.93(c)) An IA may
resume privileges after passing an oral test per 14 CFR §65.93(c). The IA’s activity
must show during the odd year (month of March), that they meet the 2 year renewal
requirements as the statement indicates.​

NOTE: The mixing of annual inspections, major repairs, and major alterations is not
permitted. You may renew your IA certificate based on the completion of four annual
inspections OR eight major repairs/alterations – not a combination of both activities.​

Since we are on the subject of annual inspections, be advised that the inspection
programs for large airplanes, turbine powered multi-engine airplanes, turbopropeller
powered multi-engine airplanes and rotorcraft defined under 14 CFR 91.409(e) are NOT
an acceptable substitution for annual inspections. Examples include: Continuous
Airworthiness Maintenance Programs (CAMP), Approved Aircraft Inspection Programs
(AAIP), manufacturer’s recommended programs, and owner/operator developed
inspection programs.​

What if I am no longer actively engaged in the maintenance or repair of aircraft but I
attend an FAA approved refresher course?​

14 CFR 65.93(a) requires that an applicant for renewal must continue to meet the
requirements of 65.91(c)(1) through (c)(4). This means that an applicant must remain
active in maintaining aircraft and have the equipment, facility, and inspection data
available to properly inspect airframes, powerplants, propellers, or any related part or
appliance.​

What if I failed to meet the renewal requirements by March 31st of the first year of the
two-year renewal cycle?​

If you failed to maintain eligibility for renewal in March of the first year, you many not
exercise the privileges of the Inspection Authorization beyond March 31st of the first
year.​

Please be aware that FAA Inspectors may wish to verify your continued compliance with
65.93(a)(1-5) as they perform routine inspections throughout the year.​

We hope this explanation proves beneficial. Should any questions arise, feel free to
contact the Richmond Flight Standards District Office (804) 222-7494 for further​
guidance.
 
Tom-D said:
After due thought process I believe the answer is simple, these Antiquers do one aircraft, (theirs) and then go to refresher course to renew. The ASI's now have the ability (like they always did ) to disqualify them on the bases they are not meeting FAR 65.93. And IMHO they aren't. "actively engaged"
Click to expand...

God forbid that someone should maintain their own aircraft.
 
Do I need to be renewing my IA? I always felt I should have been doing something else over the years.

Kevin
 
Tom-D said:
Their Definition of "Actively Engaged" is defined in FAR 65.93, that has not changed, nor has any rule we call FARs

we are required to complete 4 annuals, or 8 return to service of 337s, that is the way it has always been, and that has not changed.

It's pretty clear to me, all the old codgers that hid in their hangars and do 1 annual on their aircraft, are going to be required to show the minimum requirements or go away.

So annual inspection costs should drop because now those old codgers will be looking for the other 3 annuals to do.
Click to expand...

Hmmm...4 annuals meets the requirements, eh? There is nothing to say that an aircraft needs 12 months between annuals, so those old codgers could do an annual on their old antique four times a year and meet the requirement, no?

Just a thought, mindya...

Jim
 
weirdjim said:
Hmmm...4 annuals meets the requirements, eh? There is nothing to say that an aircraft needs 12 months between annuals, so those old codgers could do an annual on their old antique four times a year and meet the requirement, no?

Just a thought, mindya...

Jim
Click to expand...

Yes, it is legal to annual the same aircraft 4 times a year. Heck, you are legally allowed to annual it every month if you wish.
 
Rotor&Wing said:
Yes, it is legal to annual the same aircraft 4 times a year. Heck, you are legally allowed to annual it every month if you wish.
Click to expand...

Or place it in a progressive inspection ...........
 
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