Originally Posted by
Mike Busch
Other than the revised guidance to PMIs concerning the interpretation of the phrase "actively engaged" in 65.91, I was not aware that there were any other changes that would affect IA renewal. There have been no changes to 65.93 since 2007 (when the renewal cycle changed from 1 year to 2 years), and there have been no changes to 65.91 since 1985. What are the changes that concern you?
I have heard that some FSDOs have been saying that attendance at an approved 8-hour renewal seminar is no longer an acceptable basis for IA renewal, but that cannot possibly be correct because it's written right into 65.93 and the only way the FAA could change this would be to amend 65.93 with a full rulemaking action (NPRM, comment period, final rule) and that simply has not happened (nor do I believe it's even being contemplated).
The FAA did come out with FSDO guidance saying that "actively engaged" meant "swings wrenches full-time." There was a huge negative reaction to this, and the FAA quickly rescinded that guidance and replaced it with guidance saying that part-timers could be considered to be "actively engages," as could IAs working in supervisory and management capacities that did not actually swing wrenches very often.
If you are aware of any other changes beside the "actively engaged" interpretation, please let me know ASAP. Thanks...Mike