I.A. renewal documentation for 2011

[Tom Downey]

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.

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.

[martymayes]

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

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.

[martymayes]

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

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.

[Tom Downey]

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.

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.

[Tom Downey]

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.

[martymayes]

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.

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.

[Tom Downey]

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.

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.

[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.

[Tom Downey]

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.

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.