Two-year IA Renewal

The FAA has announced that it is extending the IA renewal period from every year to every two years. Effective March 1, 2007, the rule basically changes the expiration date of inspection authorization from March 31 of each year to March 31 of each odd-numbered year. You can click here to view the news release and read the entire rule as it appears in the Federal Register. There is something quite strange with this new rule. Although an IA will now only be required to visit his local FAA office once every two years for IA renewal, he or she must still continue to meet the recurrency requirements each year in accordance with FAR 65.93(a)(1)-(5). So all of us who renew our IA this year will have a date of March 31, 2009 as the expiration. But if we do not meet the annual recurrency requirements between April 1 of this year and March 31 of 2008, even though we do not have to renew our certificate then, we "may not exercise the inspection authorization privileges after that date." Here is a scenario that is not too far-fetched. Suppose I get my IA renewed this year. According to the back of my certificate, I'm good until March 31, 2009. But the year goes by, and because of my own inadvertent oversight, I do not meet the recurrency requirements of FAR 65.93(a)(1)-(5). Technically, I can no longer exercise the privileges of an IA. But in April next year, I decide to supplement my income 'cause mama needs a new car. So I start doing some annuals in my spare time. One every two-weeks or so. By March 31 of 2009, I have roughly 20 annuals under my belt. But low and behold, when I go to my FSDO to renew for another two-year period, we find out that my IA is no longer valid because I didn't meet the requirements during the first year of the two-year period.What happens then? Technically, I am in violation of the FARs; have been for a whole year. But what about the annuals? They were performed by an IA who was no longer authorized to perform the privileges granted to an IA, including annuals. But how was the owner supposed to know that? If the owner happened to ask to see my IA certificate, I could have shown them it showing I had another year to go before my renewal date. They did no wrong, but could be forced to have any inspections I signed off re-done before further flight. The FAA says that this rulemaking will save the agency money. I don't argue that. Will it save IAs money? Not really. Worse off, many IAs could be stepping into a regulatory minefield that they are not aware of until everything blows up in their face. What do you think? Let us know. More importantly, let the FAA know. The deadline for comments is March 1.  Thanks for reading! Joe Escobar