Type-rated IAs?

Last week, a change to IA renewal requirements was posted in the Federal Register. Effective March 1, this new rule would only require IAs to renew their certificate every two years with the FAA, although annual recurrency requirements would remain in effect. I discussed this topic in my last blog. You can read it by clicking here. The Aircraft Electronics Association (AEA) took the opportunity to submit comments to the proposed rule change. In its comments, AEA took the opportunity to suggest that the FAA should further change Part 65 to implement a rating system for IAs. AEA says, "Aviation safety is a critical role of all who maintain aircraft and aviation products. The FAA has continually added additional controls to repair stations under their concern for aviation safety. The Association proposes to place the same limitation on the privileges of an A&P with Inspection Authorization that the Agency is placing on a repair station." Here are the proposed changes submitted by AEA: ... the Association proposes to establish a rating and limitation requirement for the issuance of Inspection Authorizations through the following changes to 14 CFR Section 65.95. Amend paragraph a(1) to read: Section 65.95 Inspection authorization: Privileges and limitations. (a) The holder of an inspection authorization may – (1) Inspect and approve for return-to-service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under Part 121 of this chapter) for which the holder is rated and within the limitations in their certificate after a major repair or major alteration to it in accordance with Part 43 of this chapter, if the work was done in accordance with technical data approved by the Administrator; and (2) Perform an annual, or perform or supervise a progressive inspection according to §§ 43.13 and 43.15 of this chapter. The Association further proposes the addition of 14 CFR Section 65.97. This section will be linked to Section 145.59 Ratings, such that any change in the rating and limitation structure of Part 145 will reflect in a change in the rating and limitations structure of the A & P with Inspection Authorization. Section 65.97 Ratings. The following ratings are issued under this subpart: (a) Airframe ratings. (1) Class 1: Composite construction of small aircraft. (2) Class 2: Composite construction of large aircraft. (3) Class 3: All-metal construction of small aircraft. (4) Class 4: All-metal construction of large aircraft. (b) Powerplant ratings. (1) Class 1: Reciprocating engines of 400 horsepower or less. (2) Class 2: Reciprocating engines of more than 400 horsepower. (3) Class 3: Turbine engines. (c) Propeller ratings. (1) Class 1: Fixed-pitch and ground-adjustable propellers of wood, metal, or composite construction. (2) Class 2: Other propellers, by make. (d) The FAA may issue a limitation to the holder of an Inspection Authorization that maintains or alters only a limited type of airframe, powerplant, or propeller. AEA says, "Why should a business with a quality system, a reviewed and accepted business plan and an approved employee training program be regulated when 60,000 individuals without a quality system, a business plan or a training program have unlimited authority for return to service of aircraft, engines, and accessories?" You can read AEA's comments by clicking here or visiting www.aea.net. What are your thoughts? Thanks for reading, Joe Escobar