Finally, it appears clear that only IAs are required to renew their certificates (authority) every two years and have to execute this ersatz Miranda warning document; no other certificate holders have an annual or biannual renewal requirement, except of course, flight instructors. In their case, there is no performance requirement, only the attendance at a renewal educational seminar, just like IAs.
Some observers have suggested that the whole affair regarding this Miranda form and so-called “policy” publication addition is nothing more than a continuing attack against senior IA holders and a clear attempt to continue the effort to intimidate them and others into leaving the profession. What do you think?
Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He has an A&P certificate and is an ATP rated pilot. He is a USAF veteran. Please send comments to firstname.lastname@example.org.
Some practical observations on the Pilots Bill of Rights