For IAs, this March Inspection Authorization (IA) meeting held a little bureaucratic surprise. The local FSDO inspectors notified you that your little buff colored IA, 8310-5 card is now being signed off for a two-year renewal period, instead of one. This is because FAR section 65.93 that governs IA renewal was revised on Jan. 30, 2007 and made effective on March 1, 2007. So now an applicant for IA renewal is required to renew at the FSDO in the month of March of each odd-number year. At which time the applicant must submit evidence that he or she still meets the requirements of sections 65.93(c)(1)(5) for each of the two preceding 12 calendar month periods since the last renewal.
To keep confusion to a minimum when I say 12 calendar months or calendar year in this article I am referring to the 12-month period that starts on April 1 and ends on March 31. These are the months that form the IA calendar year in which the IA must meet the requirement of section 65.93.
After reading the first two paragraphs I can almost hear you thinking: OK, what is really happening here? What's really changed and how much is it going to cost me? First, let me assure you the only thing that was changed was the FAA went from one-year to two-year IA renewal period. That's it! Everything else stays the same. The IA application for renewal form stays the same, the IA card stays the same, and your annual renewal requirements stay the same. However, perhaps the biggest surprise is the new rule may save you a little money.
Let me try to fill in the blanks. Just like, every other IA renewal since June 17, 1956 when the CAA passed CAR 24.43-1, that created the IA authorization rule, each IA calendar year you will still have to get your four annuals or do eight FAA major repairs or major alterations, or do one progressive inspection, or get eight hours of FAA accepted training, or exercise everyone's favorite option, and take an oral exam by an FAA inspector to renew. The new rule made no changes to these time-honored annual IA renewal requirements.
Remember, the only big change is in the IA renewal paperwork process itself. The next time you have to renew at the FSDO will be in March 2009 instead of March of 2008. In that odd-numbered year you will have to fill out the FAA 8610-1 Mechanic Application for Inspection Authorization just like always, except instead of paying attention only to marking the proper yes/no blocks on the form, this time around you will have to show that you met the requirements for the preceding two IA calendar years instead of just one. So if you are smart, put the IA certificates of training or list of annuals or Form 337s you have accomplished for each IA calendar year in a safe place so in March of 2009 you have the information for renewal at your fingertips. If everything is copasetic with the next renewal then your IA card will be signed off for March 2011.
Now, let me see if I can answer some of your burning questions.
The first question is always; why? Why change renewal from one to two years? To be blunt, the new rule change will save the FAA a lot of time and money renewing 14,000 plus IAs every year. By changing the renewal period from one year to two it will reduce FAA administrative costs by half and get the IA renewal period in line with other two-year FAA renewal periods like flight instructors, DMEs, DARs, and DERs.
Furthermore, it will not impact the current level of safety or pass on any additional costs to the IA. It will not impact the local FSDO annual eight-hour IA renewal seminars or hurt trade shows or conventions. Both of which do a great job providing FAA accepted IA renewal training each year. All you have to remember about this rule change is the IA calendar year requirements for renewal remain the same, only the FAA paperwork has been cut in half!
Many IAs, especially those located quite a distance from the FSDO and who already met the IA calendar year requirements will enjoy a cost benefit because the annual cost to travel to the IA meeting will be cut in half. It is estimated in the rulemaking that both government and industry will split the $795,000 savings in 2006 dollars over the next 10 years ($545,863 savings for FAA and $295,856 for industry). If you couple the two-year renewal with on-line training from AMT, Gleim Publications, Blue Tuna, and other Internet providers of FAA accepted training, a clever IA can save a lot of travel time and money.
What happens if I don't renew the first year? Good question. Now it is a given at least 1 percent of the 14,000 IAs out there will screw up and either forget to get the training in the first IA calendar year, or they get sick, lose their jobs, or work out of the country so they don't meet their IA renewal requirements. If any of these disasters happen to you in the first year then you can no longer exercise the privileges of the IA in the second year. However, instead of turning in the IA and taking the written test all over again as the old rule required, the new rule has given the IA the option to request an oral exam from an FAA inspector. If the IA passes the oral exam then the first calendar year requirements for IA renewal are considered met.
How bad is the oral exam? There were several comments on the oral exam I picked off of the DOT docket website at http://dms.dot.gov. Several FAA inspectors thought that this would increase their workload because the oral will take at least eight hours to perform. Not to worry. The FAA inspectors got their guidance from Washington already. The purpose of the oral is to determine if the IA still is current and aware of the duties and responsibilities of the Inspection Authorization. The oral is not designed to be an IA test that we all sweated through the first time around. A good FAA inspector should take less than 15 minutes and 10 questions to figure if the IA is up to speed. Plus, as an IA I don't think I would be too much in a hurry to get an oral test from the FAA and show any of my short comings to the U.S. government.
What happens if the IA signs off an annual in the second year when he did not meet the requirements of the first IA calendar year? Simply put he would be in violation of section 65.93 and when discovered the FAA will drop a hammer on his head. The sad part is any annual(s) he performed in the second IA calendar year are not legal because the IA was not current. This means the owner will have to get his money back most likely through civil action based on fraud. Illegal annuals performed by someone who no longer meets the IA requirements is not a new phenomenon. It has existed for the past 30 years. I recommend that owners who want a "cheap" annual first check and see if the IA can supply proof that he is current before starting the annual.
Will this rule affect new applicants for the IA? No, any new applicant for the Inspection Authorization can still apply for the IA at any time. Let's say an individual gets the IA in Dec. 26, 2007. To renew he will have to show at least one annual or two Form 337 or eight hours of training for the period of time from Dec. 26, 2007 to March 31, 2008 and meet all of the requirements found in section 65.93 for the next IA calendar year starting in April 1, 2008 and ending on March 31, 2009.
What about meeting all of the two-year IA requirements at one time, like getting 16 hours of training, in either the first or second year? The answer is no. The rule is based on the IA renewal requirements being met within each one of the two IA calendar years. While one can argue what difference does it make if you get 16 hours of training on March 31 or take eight hours of training on March 31 and eight more hours of training on April 1. The answer is simply this: The rule does not allow it. This sounds arbitrary but so is the April 15 deadline for your tax return. Sometimes you've just got to accept the limits prescribed by the rule. Just in case you are looking for some additional wiggle room in the future and taking 16 hours of training at one time, I have been told that FAA General Council will not grant exemptions to this rule. However, any of us are still free to petition for rule change under Part 11 and change the renewal requirements.
Overall, I think this is a good rule. It cuts down on red tape a bit, saves both sides of the regulatory fence a little money, and doesn't hurt anyone in the process.
While every rule is an imperfect reflection of the public's will at least the FAA and IAs will have two years to get comfortable with the new rule change.