If you are an IA, then I'll be glad to post the name and phone number of my PMI and you can argue your case with him
If you are not, I choose not to continue the argument.
He has to sign my renewal, not you, and it is the Sacramento FSDOs opinion that this part of the regulations requires an annual once in every 90 day (annual quarter) period.
Jim
Maybe you should copy this and give to your PMI.
NOTICE
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
N 8900.67
National Policy
Effective Date: 03/05/09
Cancellation Date: 03/05/10
SUBJ: Renew Title 14 CFR Part 65, Inspection Authorization Holder
1. Purpose of This Notice. This notice provides policy and guidance to supplement Flight Standards Information Management System Order 8900.1, Volume 5, Chapter 5, Section 8, Renew Title 14 CFR Part 65 Inspection Authorization, and 2-year Inspection Authorization (IA) cycle procedures.
2. Audience. The primary audience for this notice is Flight Standards District Office (FSDO) aviation safety inspectors. The secondary audience includes Flight Standards branches and divisions in the regions and in headquarters.
3. Where You Can Find This Notice. Inspectors can access this notice through the Flight Standards Information Management System (FSIMS) at
http://fsims.avs.faa.gov. Operators may find this information at:
http://fsims.faa.gov.
4. Background.
a. With the issuance of Title 14 of the Code of Federal Regulations (14 CFR) part 65, § 65.93, holders of a Federal Aviation Administration (FAA) IA will not be required to renew their certificates until March 2009. Each IA holder, however, must maintain their eligibility to hold the certificate throughout the 2-year renewal cycle. IA holders must have written documentation to support their continued eligibility through March 2008 and 2009, and include it with the renewal application package (FAA Form 8610‑1, Mechanic’s Application for Inspection Authorization) submitted to the assigned Flight Standards District office (FSDO) in March 2009, and each subsequent odd year renewal cycle.
b. For the purposes of IA activity, the year begins on April 1 and extends through March 31. During this 12‑month period, IA holders must meet one of the renewal requirements set forth in § 65.93(a). An IA holder must continue to meet the yearly requirements of § 65.93 in order to retain the authorization.
5. Policy Action. Applicants for IA renewal must meet one of the following:
a. Title 14 CFR § 65.93(a)(1) Requirements. 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.
b. Title 14 CFR § 65.93(a)(2) Requirements. 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 the two.
c. Title 14 CFR § 65.93(a)(3) Requirements. Has performed or supervised and approved at least one progressive inspection in accordance with the standards prescribed by the Administrator.
d. Title 14 § 65.93(a)(4) Requirements. Has attended and successfully completed a refresher course acceptable to the Administrator of not less than 8 hours of instruction during the 12 months 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.
e. Title 14 CFR § 65.93(a)(5) Requirements. Has passed an oral test by an FAA inspector to determine whether 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 that allows positive interaction with FAA personnel during the renewal process. Oral tests may be based on the current revision of the FAA Inspection Authorization Knowledge Test Guide, FAA‑G‑8082‑11B, and IA privileges and limitations per part 65.
6. Guidelines for Question Development. The FSDO or International Field Office (IFO) should develop the oral test questions, which should meet the following criteria:
a. Clear. Content should establish the conditions or circumstances so the inspector and IA applicant will have the same mental picture with regard to the question’s intent and expected answer.
b. Concise. Questions should not be too complex, ambiguous, or have multiple answers.
c. Focused. Questions should have one specific answer and be referenced to a specific, FAA‑accepted guidance document or regulation; questions should not be manufacturer‑specific.
7. Sources for Test Development and Questions.
a. FAA Inspection Authorization Knowledge Test Guide, FAA‑G‑8082‑11B, current edition, is an example source for question development of oral questions along with the Practical Test Standards, Aviation Mechanic General Test Standards (FAA‑S‑8081‑26), specific to maintenance form and records. Reference
http://www.faa.gov/education_research/testing/airmen/test_questions/.
b. IA privileges and limitations per part 65 would be additional sources for test development, as there should be enough variance in the test to prevent the applicant from having prior knowledge of the specific questions. It is recommended that a minimum of 10 oral questions be asked to each IA affected, with a passing grade of 70 percent.
8. Administration and Use of the Oral Test as Evidence of Authorization. Aviation safety inspectors assigned to a FSDO or IFO administering oral tests must issue the IA with evidence of the applicant having passed or failed the test in the form of written documentation. The IA should instruct IA holders to retain the oral test results and be prepared to present the results to the FAA upon renewal or by request. Upon renewal during the odd‑year renewal month, IA holders may use FAA Form 8610‑1 as evidence of having passed the oral test if the completion is noted in the Remarks section of the form. Failing the oral test will result in nonrenewal of the IA.
Note: Oral tests administered at any other time will require written evidence of completion signed by the inspector conducting the test, and a copy placed in the IA office file.
9. Disposition. We will permanently incorporate this information into FSIMS before this notice expires. Direct questions concerning this notice to the General Aviation and Avionics Branch, AFS‑350, Attn: Kim Barnette at (202) 385‑6403 or Ed Hall at (804) 222‑7494, extension 240.
ORIGINAL SIGNED by
John W. McGraw for
John M. Allen
Director, Flight Standards Service