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FAA Responds to EAA Concerns

EAA asks for extension of IA policy proposal

November 24, 2010 — The proposed “policy clarification” regarding A&P mechanics with Inspection Authorization (IA), published by the FAA in the Federal Register, is still creating many questions among EAA members – as well as varying interpretations of the policy.

EAA has continued its dialogue with FAA officials to determine the intent of the policy change in order to help EAA members as they provide their comments to the docket by the December 6 deadline. In addition, EAA has requested an extended deadline to allow comments from all who want to participate.

In recent conversations with senior FAA officials, EAA asked a direct question: “Is the intent of the policy revision to decrease the number of part-time A&P mechanics who hold an Inspection Authorization?”

FAA’s answer was an unequivocal “No.”

The confusion arises from the wide gap between how EAA and its members are interpreting the proposal and the need for clarification, compared to FAA’s intent with the policy proposal.

EAA hopes that the clarification will make it more difficult for air safety inspectors in the field to make subjective judgments on an IA applicant being “actively engaged.” That should make the approval process more standardized, and more difficult to deny an IA renewal or first-time application based on anything other than a well-defined set of rules set forth in §65.91 and §65.93. Those rules would NOT change under this proposal.

In nearly all the comments received to date in both the docket and here at EAA headquarters, however, the opposite opinion of FAA’s intent is perceived. Most commenters believe the agency’s revised policy will make it easier to be subjective, giving an FAA inspector more room to deny or not renew an IA.

EAA firmly believes that the FAA’s policy should be to maintain the current level of part-time IAs, and encourage those mechanics who are eligible to apply for an Inspection Authorization. The agency should clarify the process of both first-time application and renewal so an applicant can be assured that aviation safety inspectors (ASI) will make their determination regarding eligibility by using the current FARs as the only criteria, and the agency should ensure that an ASI cannot subjectively reject an application based on non-relevant information.

EAA encourages all members to express their opinion on this manner no matter how they interpret the policy clarification. Doing so will show the agency how important the work of part-time IAs is to this segment of general aviation. Also, while the FAA is using the regulations.gov website to provide the ability for the public to comment electronically, the “Policy Clarification” is not an NPRM. It does not seek to change any current regulation.

FAA is seeking your input as it works to clarify a policy that has created an internal problem for more than 20 years. The agency has also expressed a desire to learn more about how the public views the definition of “actively engaged” for an IA.

 It is EAA’s position that if mechanics meet the requirements defined in §65.91 and §65.93, they’re “actively engaged,” and are eligible for either a first-time or renewal of an Inspection Authorization.

Remember the comment period for Docket No.: FAA-2010-1060 ends December 6, 2010. You can review it here. Comments can be submitted electronically starting here. Begin the process on that page by entering the docket number in the “Enter Keyword or ID” window.

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