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January 13, 2011
By Dan Namowitz
AOPA is calling for the FAA to broaden the scope of a proposed inspection authorization renewal policy for aviation mechanics beyond a revision it offered last fall when attempting to explain the meaning of the qualifying term “actively engaged.”
Not only does the proposal fail to remedy widespread inconsistency in how FAA inspectors grant inspection authority (IA) to applicants, but it may make things worse, AOPA told the FAA in formal comments. AOPA reported on the FAA’s attempt to clarify the language on Nov. 11.
“Based on the reaction of our members since the publication of this proposed policy, it is evident that the recommended changes do little to resolve confusion surrounding the term and may actually be viewed as more restrictive than the current policy,” said Kristine Hartzell, AOPA manager of regulatory affairs.
“Any definition of the term ‘actively engaged’ must be broad enough to clearly allow IAs who perform part-time or occasional maintenance to be eligible for renewal of their IA,” Hartzell wrote in formal comments to the Department of Transportation on Nov. 22. “It must also clearly allow for those IAs who perform no actual maintenance but who have an extensive background of knowledge and use that knowledge to teach, supervise, evaluate or provide management or other specialized maintenance services, such as the example of the ASI [aviation safety inspector].”
Lending to the confusion, the proposal does not clearly discuss the regulations governing the issuance and renewal of IAs, or those governing maintaining supervisory status, she said.
AOPA wants to ensure that any FAA-sanctioned definition of the term “actively engaged” clearly includes those “wholly-qualified and competent IAs that may not have much or any time performing actual maintenance or inspections on aircraft in the past two years.” That would assure qualification for IAs who instruct, supervise, manage maintenance, or perform personal aircraft maintenance, and retired mechanics who perform occasional or relief maintenance. It would also clearly cover IAs working in rural areas or offering specialized expertise in electrical systems, composites, and rare or vintage aircraft.
AOPA agrees that the widespread inconsistent application of the term “actively engaged” indicates the need for clarification. “However this proposal as is, appears to give more ambiguity to the term and does little to guide aviation safety inspectors on how to make an impartial determination of eligibility,” she wrote.
The deadline for comments on the proposal is Jan. 17, after the FAA granted an extension requested by AOPA to study the proposal.
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