FAA Common Sense NOT

[Watkinsnv]

#### I just got my IA renewed Those ####### FAA types always come out of left field with some interpretation of how they think the regs are to be interpreted. This is after they just ###### up in an effort to clarify the renewal process. For sure this is one government agency that is only getting more ###### Up by the minute.

[wingnut]

Can you elaborate? I am about to send in my stuff for renewal. Just curious, so I might avoid ####### problems

[voorheesh]

I think there might be an issue concerning the definition of "actively engaged" for IAs. I heard that the FAA may want an IA to be actively working on/inspecting aircraft in between renewals and not spending the majority of professional time holding management positions or supervising others.

[Watkinsnv]

§ 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:
(1) Performed at least one annual inspection for each 90 days that the applicant held the current authority; or
(2) Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority; or
(3) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator; or
(4) Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction; or
(5) Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current.
(b) The holder of an inspection authorization that has been in effect:
(1) for less than 90 days before the expiration date need not comply with paragraphs (a)(1) through (5) of this section.
(2) for less than 90 days before March 31 of an even-numbered year need not comply with paragraphs (a)(1) through (5) of this section for the first year of the 2-year inspection authorization period.
(c) An inspection authorization holder who does not complete one of the activities set forth in §65.93(a) (1) through (5) of this section by March 31 of the first year of the 2-year inspection authorization period may not exercise inspection authorization privileges after March 31 of the first year. The inspection authorization holder may resume exercising inspection authorization privileges after passing an oral test from an FAA inspector to determine that the applicant's knowledge of the applicable regulations and standards is current. An inspection authorization holder who passes this oral test is deemed to have completed the requirements of §65.93(a) (1) through (5) by March 31 of the first year.

I completed 9 annuals and 2 STC's the first year and 10 annuals with 13 STC's and a 337 major repair the secound year. I have 4 aircraft in my company but I'm semi retired
Now for my 170B that had the majority of the STC's the plane was down for a considerable time, but I entered it all as of the date of annual. along with the other aircraft and STC's
there was one 90 day period that had no entries. The manager of the office started my renewal and concluded eveything was fine I had more than was required and he left it up to one of his guys to sign me off and thats where this guy say's your really not in compliance. I stated that I had done alot of this work over a period of time. How they also say that the number of annual inspections, major repairs, and major alterations performed cannot be mixed simply because 65.93 does not provide for such combinations. I don't get that one!
So you can do double or triple the requirement but leave a 90 day period open and your hosed. or take a 8hr class once a year not know a thing and keep your IA. I guess I just condensed the information down to much on the dates. You have to cover all the bases. He signed me off saying to put start and finnish dates next time. during all this I told him I was on the pit crew for 4 AT6s and working with the owners Fixed Base of Operations on his race planes also but didn't want to put too much information down on the renewal form.

[bagarre]

First google hit for "faa ia renewal"

http://www.faa.gov/about/office_org/fie ... %20Q&a.PDF

Quote from the FAA on their website

14 CFR §65.93(a)(1): Has performed at least one annual inspection for each 90 days
that the applicant held the current authority. These four annual inspections could be
performed at any time during the year. Some individuals incorrectly assume that at least
one annual inspection must be completed during each 90 day period.

[wingnut]

First google hit for "faa ia renewal"

http://www.faa.gov/about/office_org/fie ... %20Q&a.PDF

Quote from the FAA on their website

14 CFR §65.93(a)(1): Has performed at least one annual inspection for each 90 days
that the applicant held the current authority. These four annual inspections could be
performed at any time during the year. Some individuals incorrectly assume that at least
one annual inspection must be completed during each 90 day period.

I have always assumed, maybe incorrectly, that I had to perform one annual, or 2 repairs/alterations every 90 days. Why would they word it "at least one annual inspection for each 90 days", instead of "four annual inspections for each one year period of the two year renewal period"?

I do know, without doubt, that you can ask 'em all the same question, and get a lot of different answers

[GAHorn]

The stated purpose of these rules is to insure that IA's are "actively engaged" in aircraft maintenance and repair, not simply doing a supervisory desk-job like the FAA Inspectors who reauthorize them , to retain their inspection authority....

[wingnut]

The stated purpose of these rules is to insure that IA's are "actively engaged" in aircraft maintenance and repair, not simply doing a supervisory desk-job like the FAA Inspectors who reauthorize them , to retain their inspection authority....

I guess that's what I was getting at; having 'signed off and returned to service' with a more uniform frequency throughout the year would imply that the IA is actively engaged, more so than a bunch of sign offs at one time, such as could happen if the IA didn't have the required amount, and 'pencil whipped' a bunch in the last quarter. How's that for a run-on sentence?

[GAHorn]

Yes...and I don't know if my hidden-meaning/criticism came thru in my statement:
The FAA requires professional maintenance people to jump thru hoops to maintain their certificates....that the FAA inspectors themselves do not. What keeps THEM current on aircraft maintenance?

Meanwhile, like income taxes and H & R Block, it creates an entirely new for-profit industry ...giving 8-hour courses of instruction to IA's just so they can keep doing what they do.

[jrenwick]

...What keeps THEM current on aircraft maintenance?...

I think they only have to keep current on the paperwork of maintenance, right? Last I heard, they don't look at actual airplanes very much.

[GAHorn]

...What keeps THEM current on aircraft maintenance?...

I think they only have to keep current on the paperwork of maintenance, right? Last I heard, they don't look at actual airplanes very much.

It reminds me of my History Dept. Prof in college who had a running disagreement with the Education Dept. He would occasionally rant "They know ALL ABOUT how to teach. Trouble is ...they don't KNOW ANTHING TO...teach!"

[Watkinsnv]

Most annuals are done from April thru September. No one likes to do their annual in the winter. A lot of modifications are done in the winter. I did a large one and almost froze to death last winter. It doesn’t take much to see whose doing what. Its idiotic to be bureaucratic about it. With the same interpretations being fought over and over agin. When we loose the few knowledgeable A/P's IA's that are willing to work with the aircraft owner or club. General Aviation will be in a lot of trouble. I have never tried to make a living off of general aviation. I get all of my enjoyment from general aviation. Its not a matter of being current it’s the wealth of knowledge that you’ve acquired over the years that is irreplaceable.

[Bruce Fenstermacher]

And it's pretty foulish that the two guys who maintain the helicopter I fly couldn't keep current as an IA because the helicopters are maintained under a AAIP. There working on it, inspecting it and returning it to service every day. But they couldn't annual it (if it was required) or one exactly like it.

[voorheesh]

A AAIP is a progressive inspection and Part 65 provides that as one of the acceptable means for an IA to remain actively engaged.

[Bruce Fenstermacher]

A AAIP is a progressive inspection and Part 65 provides that as one of the acceptable means for an IA to remain actively engaged.

From the FAA document linked above:

• NOTE: The mixing of annual inspections, major repairs, and major alterations is not
  permitted. You may renew your IA certificate based on the completion of four annual
  inspections OR eight major repairs/alterations – not a combination of both activities.
  Since we are on the subject of annual inspections, be advised that the inspection
  programs for large airplanes, turbine powered multi-engine airplanes, turbopropeller
  powered multi-engine airplanes and rotorcraft defined under 14 CFR 91.409(e) are NOT
  an acceptable substitution for annual inspections. Examples include: Continuous
  Airworthiness Maintenance Programs (CAMP), Approved Aircraft Inspection Programs
  (AAIP), manufacturer’s recommended programs, and owner/operator developed
  inspection programs.

Am I reading this wrong?