The establishment of ARAC
Further impetus for the Part 65 review came with the establishment of the Aviation Rulemaking Advisory Committee (ARAC). The ARAC charter became effective on Feb. 5, 1991, and was renewed on Feb. 21, 1995. The ARAC was established to assist the FAA in the rulemaking process by providing input from outside the federal government on major regulatory issues affecting aviation safety. The ARAC included representatives of air carriers, manufacturers, general aviation, labor groups, colleges, universities, associations, airline passenger groups, and the general public. The ARAC’s formation has given the FAA additional opportunities to solicit information directly from affected parties, who meet and exchange ideas about proposed and existing rules that should either be revised or eliminated. The FAA received significant assistance from the ARAC in this review and in the formulation of the proposals contained in the NPRM that offered Part 66 to replace Part 65.
At its first meeting on air carrier/general aviation maintenance issues on May 24, 1991, the ARAC established the Part 65 Working Group. The ARAC tasked this working group to conduct a review of the certification requirements for mechanics, mechanics holding inspection authorizations, and repairmen. Due to the extensive scope, the working group divided its review of the certification requirements for aviation maintenance personnel into phases.
Once the first phase of this review was complete, the ARAC analyzed the efforts of the working group and made a series of recommendations to the FAA, which resulted in the FAA’s issuance of an NPRM on Aug. 17, 1994. That NPRM proposed: (1) establishing a separate part in the FAR for aviation maintenance personnel; (2) removing gender-specific terms from the original regulation; (3) changing the term “mechanic” to “aviation maintenance technician;” (4) changing the term “repairman” to “aviation repair specialist;” (5) establishing the equivalency of the aviation maintenance technician certificate and the aviation repair specialist certificate with current certificates; (6) allowing facsimiles to be used in the process of replacing lost or destroyed aviation maintenance technician and aviation repair specialist certificates; (7) requiring applicants to demonstrate English-language proficiency by reading and explaining appropriate maintenance publications and by writing defect and repair statements; (8) discontinuing the certification of aviation maintenance personnel who are employed outside the United States and who are not proficient in the English language; (9) requiring all aviation maintenance technician applicants to pass a written test that would examine their knowledge of all applicable maintenance regulations; (10) clarifying the requirement that each applicant for an aviation maintenance technician certificate pass all written tests before applying for oral and practical tests; (11) recognizing computer-based testing methods; (12) specifying all experience requirements in hours instead of months for initial certification; (13) establishing a basic competency requirement for aviation maintenance technicians; (14) allowing aviation maintenance technicians to use equipment-specific training as an additional means to qualify for the exercise of certificate privileges; (15) permitting aviation maintenance instructors to use instructional time to satisfy currency requirements; (16) establishing training requirements for aviation maintenance technicians who desire to use their certificates for compensation or hire; (17) extending the duration of an inspection authorization from one to two years; and (18) expanding the renewal options available to the holder of an inspection authorization.
Part 65 and 66
After further work by the Part 65 Working Group and the rapid completion of the second phase of the review of the certification requirements for mechanics and repairmen, the ARAC recommended that the FAA consolidate the proposals made in the earlier NPRM with those proposals made by the ARAC .
The FAA, in an effort to avoid confusion in the implementation of the final rule, agreed and determined that the changes should be reconciled and consolidated into a single NPRM containing both sets of proposals. The FAA, therefore, withdrew the initial NPRM.
The end result was that the FAA proposed the general use of the term aviation maintenance technician (AMT).
Many of the discrepancies between the second proposal and the earlier NPRM resulted from the previously proposed equivalency of a mechanic certificate to an aviation maintenance technician (AMT) certificate. The current mechanic certificate has airframe and powerplant ratings. The holders of mechanics certificate with an aircraft rating or powerplant rating possess the approval for return-to-service privilege. Information pertaining to inspection authorizations is found solely in the subpart 65.
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