I.A. renewal documentation for 2011

Attention I.A.'s

This might be a good time to check if you have met the new requirements for I.A. renewal (with less than a month of 2011 remaining).

The rules have been revised and some documentation of activity in 2011 is required. How much documentation is not clear to me.



This document seems to require the additional proof that will now be required:
http://www.eaa.org/news/2011/New_IA_policy.pdf

“The ASI may use evidence or documentation provided by the applicant showing inspection,
overhauling, repairing, preserving, or replacing parts on aircraft or supervision of
those activities. This evidence or documentation when required could include
employment records showing performance or supervision of aircraft maintenance, return to
service documents and or copies of maintenance record entries.”


The I.A. guide has been revised and split into two parts. The second part has some of the new renewal process, but is not complete, in my opinion (since it does not mention additional documentation needed in 2011):

FAA-8082-11C http://www.faa.gov/training_testing/...g-8082-11c.pdf
and
FAA-8082-19 http://www.faa.gov/training_testing/...-g-8082-19.pdf
Bill

I just read something the other day that for the sake of IA renewals, the "year" starts and ends with March 31 which is the last day to renew. So for the purpose of meeting the renewal requirements, you should have up until that point.

Can't remember where I read it, but can someone confirm?

Yeh, I thought of that as well. But I bet that might only mean March 31 of 2013 when the card expires. I can't say, and my hurts enough already to look it up.

The thing is, just going to the yearly 8 hour I.A Renewal like we did in the past, is not enough now.
Need some sort of log book copies now.

I think FAA-8082-19 needs to be updated again to explain the logbook documentation requirements.
Bill

This is more about the actively engaged. I think it means if the fsdo wants proof that you are actively engaged. I'm not sure they will want to know that at every renewel, but if they question your active engagement. The best thing would be to call your local fsdo and ask them what they want at renewel time

For most IAs nothing changed, you now must submit the required documentation to certify every two years rather than each year, but you still must prove you were active for both years. double the paper but half the stamps.

Quote:

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Originally Posted by Bill Berson

The thing is, just going to the yearly 8 hour I.A Renewal like we did in the past, is not enough now.
Need some sort of log book copies now.
Bill

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That is not true bill, the training is still good enough, but you must go each year going once won't cut it for both years.
"Actively engaged" is about your A&P not the IA.
When you submit your application and the documentation as proof you attended the classes you are good to go.
If the FAA requires you to prove you are active as an A&P you must be able to do that.

Quote:

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Originally Posted by Tom Downey

If the FAA requires you to prove you are active as an A&P you must be able to do that.

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That was my point Tom.
If the FAA requests documentation from 2011, you better have it in your file.
It will be too late if you wait till 2013 and find yourself in the position of needing to "create" some documentation from 2011.

I don't know if logbook copies will be required with the application or not. Or if it will be requested on a random basis as you suggest. How many logbook copies are required to prove "actively engaged" as an A&P?
Bill

Quote:

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Originally Posted by Bill Berson

That was my point Tom.
If the FAA requests documentation from 2011, you better have it in your file.
It will be too late if you wait till 2013 and find yourself in the position of needing to "create" some documentation from 2011.

I don't know if logbook copies will be required with the application or not. Or if it will be requested on a random basis as you suggest. How many logbook copies are required to prove "actively engaged" as an A&P?
Bill

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If you are really in a position to be worried about it, call your PMI and ask. I have my activity sheet, and application ready to go long before I am required to send it in. and yes now we are required to actually have the activity sheet, SEA FSDO has been doing that a long time.
I asked my PMI about what he thought about the change in their directions from OKC about enforcing the "Actively engaged" he simply said it's about time we can eliminate the machinists at Boeing that are not using their A&P tickets from being an IA.
And I agree. if you are not working in the GA industry why should you keep your IA. You are actively engaged if you have a job that supports GA in any way. If you are supporting your own aircraft, you are good to go, If you are supporting a war bird activity you are good to go, If you changed your ex-brother in law's cousin's oil in their aircraft just once and logged it you are good to go.

I work in Maint Control for a major air express carrier and wrench on my own aircraft and do a yearly IA seminar.

I believe I'm covered. Now, is an IA required to do an annual on a Homebuilt that now belongs to new owner that did not build it? And if so, does that count towards his activity?

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Originally Posted by george r. garrison vaa 58

I work in Maint Control for a major air express carrier and wrench on my own aircraft and do a yearly IA seminar.

I believe I'm covered. Now, is an IA required to do an annual on a Homebuilt that now belongs to new owner that did not build it? And if so, does that count towards his activity?

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Inspection Authorization is not required to perform an annual condition inspection on a homebuilt and no, performing an annual condition inspection on a homebuilt does not count for renwal IAW with 65.93.

Based on your other experience, I too believe you are covered.

Martymayes - thanks for the reply, so in the case of the homebuilt, an A&P can do the condition inspection for the owner that did not build the airplane? I've been an IA since 1973 and have never gotten involved in this aspect of inspection.

So, I'm stupid of the facts. You can never know enough, so I bring it up.

You sound like your right on top of the reg's. Thats pretty cool. Thanks again.

Quote:

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Originally Posted by martymayes

Inspection Authorization is not required to perform an annual condition inspection on a homebuilt and no, performing an annual condition inspection on a homebuilt does not count for renwal IAW with 65.93.

Based on your other experience, I too believe you are covered.

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The requirement for an A&P to do the conditional is activity for the A&P, and that is what this is all about, being active as an A&P. If he is signing any log book in GA he is active, and with that and the refresher course he is good to go as far as renewal is concerned.

here is the guide for renewal..

http://www.faa.gov/training_testing/...-g-8082-19.pdf

Quote:

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Originally Posted by george r. garrison vaa 58

Martymayes - thanks for the reply, so in the case of the homebuilt, an A&P can do the condition inspection for the owner that did not build the airplane? I've been an IA since 1973 and have never gotten involved in this aspect of inspection.

So, I'm stupid of the facts. You can never know enough, so I bring it up.

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No you're not George but hang in there. Lot of part-time IA's are going to be surprised when they show up for renwal in '13 and find out it's not automatic.

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Originally Posted by martymayes

No you're not George but hang in there. Lot of part-time IA's are going to be surprised when they show up for renwal in '13 and find out it's not automatic.

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If an A&P-IA isn't smart enough to stay current with what's going on in his field of occupation, do you really want them working/inspecting your aircraft?

If the A&P-IA is only running a milling machine at some factory Why do they need their IA?

So very true.

The FAA Activity form for IA renewal
http://www.faa.gov/about/office_org/...ist%20form.pdf

Tom,
That form is the typical local FAA form for I.A. activity. (for I.A.'s that choose the option of either four annuals or eight major repairs as needed)

Do you they have a new form for the new required A&P activity? (For I.A.'s that choose the eight hour renewal option)
Bill

Quote:

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Originally Posted by Bill Berson

Tom,
That form is the typical local FAA form for I.A. activity. (for I.A.'s that choose the option of either four annuals or eight major repairs as needed)

Do you they have a new form for the new required A&P activity? (For I.A.'s that choose the eight hour renewal option)
Bill

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When you attend the seminar you will receive the sign off for the remedial training, that with the IA renewal request is good to go. but if you have completed even 1 337 you can place that on the activity sheet. that alone will show you are active as an A&P.
If you are worried about your activity as an A&P I'd call your FSDO and see what they need to prove that.
My PMI at FSDO knows me and doesn't require that I prove any thing.

Quote:

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Originally Posted by Tom Downey

My PMI at FSDO knows me and doesn't require that I prove any thing.

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Then you are fortunate. Not all PMI are this agreeable.
Who knows what will be the policy in 2013? That's why standard procedures should be announced ahead of time.

The FAA may decide to enforce 65.83 which requires 6 months of A&P activity:

§ 65.83 Recent experience requirements.
A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months—
(a) The Administrator has found that he is able to do that work; or
(b) He has, for at least 6 months—
(1) Served as a mechanic under his certificate and rating;
(2) Technically supervised other mechanics;
(3) Supervised, in an executive capacity, the maintenance or alteration of aircraft; or
(4) Been engaged in any combination of paragraph (b) (1), (2), or (3) of this section.

Quote:

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Originally Posted by Bill Berson

Then you are fortunate. Not all PMI are this agreeable.
Who knows what will be the policy in 2013? That's why standard procedures should be announced ahead of time.

The FAA may decide to enforce 65.83 which requires 6 months of A&P activity:

§ 65.83 Recent experience requirements.
A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months—
(a) The Administrator has found that he is able to do that work; or
(b) He has, for at least 6 months—
(1) Served as a mechanic under his certificate and rating;
(2) Technically supervised other mechanics;
(3) Supervised, in an executive capacity, the maintenance or alteration of aircraft; or
(4) Been engaged in any combination of paragraph (b) (1), (2), or (3) of this section.

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So, what's the problem? If in the 24 months if you did any thing to any GA aircraft that required a return to service sign off you are good to go, (Item 1) there is no minimum required amount of work, simply be active as a A&P.
Did you change oil in your own aircraft? you are good to go.

Quote:

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Originally Posted by Bill Berson

Do you they have a new form for the new required A&P activity? (For I.A.'s that choose the eight hour renewal option)
Bill

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No Bill, of course not. But if you are not employed full time as an A&P mechanic, you may need proof that you are active engaged beyond 8 hrs of training. I just finished my 8 hrs of IA training last week. Not only are lots of IA's are not aware of the changes but because the requirement for part time A&P's to prove they are actively engaged, there's going to be a lot of surprised folks at renewal time next year.

Quote:

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Originally Posted by Tom Downey

If the A&P-IA is only running a milling machine at some factory Why do they need their IA?

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I'm not the one questioning if they need it or not. However, in the past the FAA would renew this person's IA as long as they did 8 hrs or training and now they won't. They are changing the rules without an official rule change and that's where the beef is.

Quote:

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Originally Posted by martymayes

I'm not the one questioning if they need it or not. However, in the past the FAA would renew this person's IA as long as they did 8 hrs or training and now they won't. They are changing the rules without an official rule change and that's where the beef is.

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No Marty, the rules did not change, The FAA has always had these rules, they simply did not enforce them, they always assumed that any IA was an active A&P. Which as it turns out isn't true. There was no Notice to proposed rule change, no FAR got changed, the method of enforcement did.
As it turns out many IA holders were not working in the industry at all but keeping their IAs by attending the seminars. That ain't going to work any more.

THis is the official press release from the FAA.

http://www.gpo.gov/fdsys/pkg/FR-2011-08-04/pdf/2011-19741.pdf

It says The FAA believes these comments result from a common mis-understanding of the IA renewal requirements under 65.93. Section 65.93 sets forth five activities, at least one of which must be completed in the first year and at least one of which must be completed in the second year, to be eligible for renewal of an IA. However, 65.93(a) also states ‘‘an applicant must present evidence * * * that the applicant still meets the requirements of 65.91(c)(1) through (4).’’ Accordingly, IA applicants must hold a current mechanic’s certificate with both airframe and powerplant ratings that has been in effect for at least 3 years and must have been actively engaged in maintaining aircraft for 2 years prior tothe application.

Quote:

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Originally Posted by Tom Downey

No Marty, the rules did not change, The FAA has always had these rules, they simply did not enforce them, they always assumed that any IA was an active A&P. Which as it turns out isn't true. There was no Notice to proposed rule change, no FAR got changed, the method of enforcement did.
As it turns out many IA holders were not working in the industry at all but keeping their IAs by attending the seminars. That ain't going to work any more.

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Okay, I'm fine with that. Now the definition of "actively engaged" is published and available to all applicants. Line 6 on the 8610 application asks if the applicant has been actively engaged. If he checks "YES" he is making a self certification that he meets the requirements. WHY is checking the box not sufficient? WHY will part-time A&P's be required to produce additional documentation to show they are actively engaged? A full time A&P will not be required to do this, checking the box is sufficient. Is this not a double standard? And what Bill said, why is the "additional documentation" not standardized on a form? At least it should be a fair double standard. :(

Quote:

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Originally Posted by martymayes

Okay, I'm fine with that. Now the definition of "actively engaged" is published and available to all applicants. Line 6 on the 8610 application asks if the applicant has been actively engaged. If he checks "YES" he is making a self certification that he meets the requirements. WHY is checking the box not sufficient? WHY will part-time A&P's be required to produce additional documentation to show they are actively engaged? A full time A&P will not be required to do this, checking the box is sufficient. Is this not a double standard? And what Bill said, why is the "additional documentation" not standardized on a form? At least it should be a fair double standard. :(

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Yes this is troublesome and we should have a standard for all FSDOs to abide by.

I have always checked the block, and never been asked for other proof. I have never seen or heard of any form or authorized evidence that the FAA says is good to go for that purpose.

But like I have said before, if you are worried about this I'd be on the phone to my PMI to see what he needs.

The FAA document say's "copies" not copy.
So your claim that one oil change is sufficient (wherever that came from), may not be be valid.

Any promise from a PMI can be overruled by new policy at any time.

Quote:

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Originally Posted by Bill Berson

The FAA document say's "copies" not copy.
So your claim that one oil change is sufficient (wherever that came from), may not be be valid.

Any promise from a PMI can be overruled by new policy at any time.

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There is only 1 guy to worry about, the 1 signing the renewal. "actively engaged" has no amount of work attached to the term. Remember Item "1" But as Marty pointed out, it is up to the ASI/PMI who is signing the renewal. I hope they never set a standard requirement there, That really would draw a line in the sand that many couldn't cross.

IMHO the FAA should have a web page that all A&Ps and IAs could access with a secure log in and renew on line by listing their activity. They do have on line remedial training that qualifys you to renew, if you only support 1 or 2 aircraft. Why not go all the way, and do it all in one web page?

Simply stop the paper pushers and their idea of what this all means.