AMTSociety Comments Regarding Docket No. FAA-2010-1060

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.

AMTSociety Board of Directors

Response from Edward L. Hall, Federal Aviation Administration

Thank you for your e mail and attached comments. It is evident from the number and content of comments received as a result of the Federal Register Notice that a considerable amount of misunderstanding exist with regard to Title 14 CFR part 65, specifically 65.91 and 65.93.

The FAA does not seek to change an existing rule however the FAA does seek to re-established consistence and standardization when applied to both Inspection Authorization (IA) initial application and renewals, especially with regard to the previously troublesome term actively engaged as required by 65.91 (noted herein).

65.93 Inspection authorization: Renewal.

(a) To be eligible for renewal of an inspection authorization for a 2-year period an applicant must present evidence during the month of March of each odd-numbered year, at an FAA Flight Standards District Office or an International Field Office, that the applicant still meets the requirements of §65.91(c) (1) through (4). In addition, during the time the applicant held the inspection authorization, the applicant must show completion of one of the activities in §65.93(a) (1) through (5) below by March 31 of the first year of the 2-year inspection authorization period, and completion of one of the five activities during the second year of the 2-year period:

65.91 Inspection authorization.

(a) An application for an inspection authorization is made on a form and in a manner prescribed by the Administrator.

(b) An applicant who meets the requirements of this section is entitled to an inspection authorization.

(c) To be eligible for an inspection authorization, an applicant must —

(1) Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;

(2) Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;

(3) Have a fixed base of operations at which he may be located in person or by telephone during a normal working week but it need not be the place where he will exercise his inspection authority;

(4) Have available to him the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance; and

It appears from the comments received thus far including those provided by the AMT Society, that an important part of an existing regulation has been applied previously based on subjective and judgmental decisions that have been inconsistent in the past for which we wish to correct.

The FAA wishes to clarify and restate existing regulatory requirements as applied to a mechanic or IA, by defining and seeking additional industry comments that could further define actively engaged in FSIMS Order 8900.1 along with encouraging mechanic/ IA continued education.

Your assistance in that regard would be of greater benefit to the aviation industry and to the existing professional mechanics and IA authorization holders that make our industry so great.