AMTSociety Comments Regarding Docket No. FAA-2010-1060

It is our opinion that, while the goal has some merit, the consequence is not in the best interest of our constituency or, as a matter of fact, the general aviation industry.

AMTSociety has a membership of more than 3,000 active aircraft technicians. After conferring with our leadership we wish to state our objection to the proposed policy clarification.

Currently the process for acquiring and subsequently holding an Inspection Authorization is clearly defined in the regulations. After perusing the proposed docket, it is our opinion that, while the goal has some merit, the consequence is not in the best interest of our constituency or, as a matter of fact, the general aviation industry. It is clear that the proposed course of action could lead to both subjective and judgmental decisions related to “actively engaged,” raising concern that personalities could play into the IA renewal process. In addition to being unfair, this action will most likely result in a plethora of appeals and/or mediation, slowing the system interminably. For a self-employed person IA in general aviation this could be disastrous.

We do not understand why the FAA would pursue this goal in this manner. It is well known that one of its main challenges is to standardize field interpretation of regulations. Why create another monster?

Another issue is obvious … such a course of action could very well lead to the loss of jobs; middle income jobs that are precariously threatened in this time of economic challenge.

Understandably the terminology “actively engaged” can be misconstrued and there is a perceived inconsistency between the “recent experience” requirements outlined in part 65.83 for a “certified mechanic” and the term “actively engaged.” Being a “certified mechanic” is a prerequisite for the inspection authorization as outlined in part 65.91.

Currently part 65.93.a., (1-5) addresses IA renewal and considers “approved training” as an acceptable alternative to completing inspections or approving major repairs and alterations, yet this essential element does not appear in the proposal. The criteria outlined in part 65.83 addressing supervisors and those “supervising in an executive capacity” would no longer be qualified as “actively engaged.”

We recognize the importance of an Aviation Safety Inspector (ASI) to be as qualified as those they endorse, but oppose the current proposal’s intent for automatic renewal. It is our belief that those issuing the qualification should in fact be equally qualified, requiring either the hands on element or participation in sanctioned training initiatives. It goes without saying that such a direction will take the emphasis away from continued and upgraded training of current technicians.

The aviation maintenance industry has encountered significant challenges in recent years with much of the world’s fleet qualifying as aging aircraft and/or technological expansion in new product lines that exceeds current awareness levels. Our tribal knowledge is in the hands of seasoned professionals, many contemplating retirement. Finally, the understanding of the need for continued learning by aviation maintenance professionals is lacking compared to other technical fields. The mission of AMTSociety is to provide educational resources to our constituency and in our view an effective alternative to defining “actively engaged’ would be to prime industry into developing learning programs that enlighten our seasoned professionals as well as enhancing knowledge levels of their successors.

We encourage you to extend the comment period on this proposed change through February 2011.

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