Officials at the FAA have recently indicated they are considering adopting a two-year IA renewal period — and that the proposal has gone to the FAA’s rulemaking committee. According to Bill O’Brien in our recent May FAA Feedback, “The committee will decide whether or not to revise 14 CFR section 65.93 to allow for a two-year renewal period.”
Well, a two-year IA renewal! Let’s see, our IA program can now charge $40 every-other year, instead of $20 once a year! Less work for us and less processing of mechanics, so more money to be made! That’s nice! Hmmm, mechanics only have to think about training every other year — less work for them — perhaps less travel! Ahhh, the FAA saves lots of money from having to process less paperwork — less work for it as well! Everybody should be happy right?
Let’s stop and think a minute! Doesn’t this fly in the face of everything the industry, including trade groups, and the FAA has been preaching for years? “Mechanics don’t train often enough!” The industry has been fighting for years to get mechanics to train on an annual basis! So how does it make sense that we should go to a two-year IA renewal?
Let’s look at a couple of other reasons used for changing to a two-year period:
Standardization: Proponents of a two-year renewal say that it will standardize with the two-year requirements for DARs, DMEs, and DERs. This is just not an excuse that should be weighed in the face of safety. If anything, DARs, DMEs, and DERs should have even more frequent training requirements as some of their responsibilities require them to be even more up to date! So I say keep IAs at a year, and make DARs, DMEs, and DERs renew every six months!
Equivalent level of safety: It’s argued that 16 hours every two years is the same as eight hours every year! Sorry, I don’t buy this either. To go two full years without any type of recurrency training, regulatory review, or technical update is not the equivalent level of safety! A greater amount of time between technical and regulatory updates is not safer. Heck, why don’t we just go to 160 hours of training every 20 years? See what I mean?
Savings: Let’s look at them one at a time:
Mechanics will be cutting travel costs in half: If you now will need to go to a 16-hour IA renewal program, that will mean a hotel bill, and if you come in the night before, that means two nights of hotels, and meals! I argue that this will cost mechanics at least as much as before, if not more!
Hosts of these annual training events: Regional hosts will now have to pay for a room for two days, make arrangements for staying over night, arrange for food, etc. I don’t see any savings here! It’s much more expensive to hold a conference facility overnight for two days, than for a simple one-day period.
There are other complications related to a two-year renewal which I don’t think have been thoroughly considered. For example, the FAA will also have to absorb some additional hotel costs at these two-day renewals. Also, the review of the records will be more cumbersome — two years of paperwork instead of one. Can the same course be repeated annually by one individual and submitted as part of a 16-hour package? And so on.
The real reasons why this is being proposed are simple — the FAA feels it will save money and time — and some IAs want less training hassles. This is one proposal that promises to do neither!
But more importantly, this is a move that de-values the emphasis on training. My feeling is that if you are at the level of an IA in this industry, and you don’t want to at least train on an annual basis, either give up your IA, or get out of the business!