a. Application Requirements: Application for renewal may be required to comply with the following: (1) Show evidence that applicant still meets the requirements of 65.91(c)(1) thru (4). Note: Refer to Paragraph 5-1279(A)-(C) of this document for information on meeting section 65.91(c)(1) through (4) requirements. Because Volume 1, Chapter 3, Section 2 of this order limits the type of maintenance that ASIs can perform, an ASI may renew an IA regardless of the volume of maintenance work (he or she) performed. (This of course refers to inspectors who happen to have Inspection Authority. ASIs are not permitted to perform maintenance in the field except for their own aircraft.)
This proposal clearly does not affect ASIs who also have IA authority and they can certainly work on and certify the airworthiness (perform annual inspections) on their own aircraft and perhaps others under certain restrictions. In this proposal, they do not have to show that they meet the requirements of 65.91(c)1 thru 4. Many airmen in their comments to the proposal have voiced objection to this “carved out exception” for ASIs. Most comments oppose the granting of automatic renewal for anyone including ASIs and that they should at least be required to participate in the approved seminar training activities that other IAs utilize to renew their authority as provided for in Part 65.
Further, many IAs maintain that this proposed change utterly fails to consider the unique nature of the contributions to overall safety in the general aviation field that senior IAs contribute, but who do not necessarily turn a wrench or are not employed full time as technicians. This clearly would contribute to a negative feeling toward the FAA and affect the morale of maintenance people at a time when our maintenance activities have been faced with serious economic challenges and jobs are scarce. This proposal seems to be poorly timed to say the least.
Bill O’Brien, the former national resource specialist for the FAA in Washington, may he rest in peace, must be rolling over in his grave on hearing of this proposal which many comments by technicians suggest is a transparent attempt to disenfranchise a whole segment of our GA industry, in a failed attempt to clarify what does not need to be clarified. Indeed, O’Brien would most likely appeal to the Almighty, as the Man on the Cross exclaimed … Father forgive them for they know not what they do …
Most IAs’ comments would acknowledge that O’Brien would strongly disagree with the proposal as it is currently written. He addressed IAs for many years and his strong support of the IA system as it presently exists is legion. In one of his most memorable writings he refers to the IA as a “Silverback,” the 800-pound gorilla of general aviation maintenance.” (See “Silverback” by Bill O’Brien, May 1995 AMT magazine.)
The FAA has long considered the IA designation as akin to a higher educational degree and is looked upon as a measure of the professional status of the holder. The FAA has itself elevated this person to a higher status than the certificated technician. This recognition of career advancement by the FAA, appears to be compromised in its proposal. It would have the effect of removing this recognition from the mostly senior IAs who work in management in the industry and or perform fewer maintenance tasks. It takes much experience and study to acquire the authority and it should not be so cavalierly threatened or removed by Flight Standards. Most of the persons concerned are senior members of the general aviation community and it would appear that they may be unfairly and perhaps unlawfully, targeted by this proposal.
New policy rules will be in effect
It is our opinion that, while the goal has some merit, the consequence is not in the best interest of our constituency or, as a matter of fact, the general aviation industry.
The revised latest directive with broad definition of actively engaged
Last chance to comment on this NPRM!