Two Year IA Renewal

March 31, 2007 saw a change in the Aviation Industry, at least to those of us who hold Inspection Authorizations (IA's). But as I look deeper into the effects of the two year renewal for IA's and hearing many people complain about the new ruling, I did a little research on the subject and this is what I found. ( A couple of summarized facts):

1. IA's are required to have eight (8) hours of FAA Approved training every year (April 1 - March 31) 1 Annual Inspection or 2 FAA Form 337's for every 90 days.
2. IA's will only have to submit FAA Form 8610-1 (IA Application and Renewal Form) every March of ODD numbered years.
3. IA's need to be able to prove eligibility any time over the two years upon request.

So as I look forward to 2008, if asked by an FAA Inspector, I better be able to prove that between April 1, 2007 and March 31, 2008 I have documented eight hours of training or the required Annuals/337's. If I can't come up with the required documentation, my IA is invalid for 2008. Sounds simple - right.

To make sense of what has transpired, let's take a look at the history of the IA Two-year Renewal.

In July of 2005, AFS-300 issued the AFS-300 White Paper "Proposed Changes to FAR Parts 1, 43, & 65. The report was written by Bill O'Brien (AFS-350) based on a December 2004 Meeting between Michael Harkins (First State PAMA Chapter) and Brian Finnegan (PAMA President) and a formal request for rulemaking signed January of 2005.

In the formal request of rulemaking changes, the 2-year IA renewal was one of several proposed changes. In the AFS-300 White Paper, it was recommended that the IA would last for 24 months with the expiration on the last day of March. The requirements of renewal would double, but would also include other items. The following is the proposed change.

Revision to Sec. 65.93 Inspection Authorization Renewal

To be eligible for renewal of an inspection authorization for a two year period, an applicant must, within 60 days before the expiration of the inspection authorization, present evidence at a FSDO or IFO that the applicant still meets the requirements of the section 65.91(c)(1) through (c)(4) and show that, during the current period that the applicant held the inspection authorization, has:

1. Performed at least one annual inspection for each 90 days that the applicant held the current authority or;
2. Performed inspections of at least two major repairs or major alterations for each 90 days that the applicant held the current authority or;
3. Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator for each 12 months that the applicant held he current authorization or;
4. Performed any combination of annuals and Form 337 in paragraphs (a)(1) through (a)(2) of this section. For example, two Form 337 is the equivalent to one annual inspection or one annual inspection is equivalent to two Form 337 or;
5. Perform or supervise a section 91.409 inspection on a large or turbine powered aircraft that is operated under Part 91 or Part 135 nine or less passenger seats that is the equivalent in scope and detail to an annual type inspection or;
6. Successfully completed an inspection authorization refresher course or series of courses acceptable to the Administrator, of not less than 16 hours of instruction during the 24-month period preceding the application for renewal or;
7. Passed an oral test administered by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards are current.

So what is next for IA's, we either live with the ruling or affect a change by formally issuing a letter to the FAA requesting the change.