Comments to Proposed IA Renewal Policy Change Submitted
December 23, 2010 —EAA, the Vintage Aircraft Association, and Warbirds of America jointly submitted comments this week to the FAA’s proposed “Policy Clarifying Definition of ‘Actively Engaged’ for Purposes of Inspection Authorization.” The clarified policy’s goal should be to maintain the current level of part-time IAs and encourage eligible mechanics to apply. Comments were purposely submitted well before the January 17, 2011, deadline to allow members of their organizations ample opportunity for review so as to better formulate and submit their own. (Read the comments here.)
While not a notice of proposed rulemaking, the policy and its revision have far-reaching implications for those who apply their professional skills as an IA on a part-time basis. As published in the Federal Register, the policy is intended to provide aviation safety inspectors (ASIs) with a more tightly defined definition of “actively engaged.” The FAA intends to enforce the new policy when the IA renewal cycle begins on March 31, 2011.
EAA has maintained contact with FAA management on the issue, stressing that ASIs have too much latitude in the proposed language. EAA, VAA, and WOA recommend the agency clarify the process for both first-time and renewal applications with FAA Order 8900.1, Vol. 5, Ch. 5, Secs. 7-8. In that way, an applicant can be assured that ASIs will make their determination regarding eligibility by using current FARs as the only criteria, and the agency should ensure that an ASI cannot subjectively reject an application based on irrelevant information.
EAA urges its members to submit comments to the proposed policy. You can review it here. Comments can be submitted electronically starting here. Begin the process on that page by entering the docket number FAA-2010-1060 in the “Enter Keyword or ID” window. For additional information and continuous conversation on this topic, visit the Red Barn Forum on Oshkosh365.