Current vs. Actively engaged

Mr. Escobar.

I read your column in the Jan/Feb issue of D.O.M. and would like to add a thought or two.

I learned of the NPRM concerning “actively engaged,” but declined to comment because I had brought the phrase “hold a current mechanic’s certificate” to the attention of my local FSDO on numerous occasions when they asked for suggestions for content in their IA renewal seminars, but was ignored.

I emphasize the word current. This NPRM focused on “actively engaged,” but currency is being actively engaged, is it not? The regulation was already there: the mechanic certificate is current if the holder works six months during the previous two years.

If the certificate is not “current,” how can an IA take an eight-hour course to renew? Do not all the regulations have to be met?

Also, working under a repair station or airlines number is not “exercising the privileges of ... the certificate,” so an applicant could be “employed full-time in inspecting, overhauling, repairing ... etc. ... on aircraft,” and not qualify to apply to be an IA since he has not “exercised his privileges!”

I know of an A&P that worked on corporate aircraft for seven years, and his I.A. application was refused because he worked under a repair station number.

If “currency” is only applicable for the initial application and not renewal, as my local FSDO claims, why is the term used in the discussion of “actively engaged?”

 As for the rest of your column, yes indeed, we do need a “step up.” I wish I could offer some suggestions. Maybe the centuries-old apprentice-journeyman-master idea should make a come-back ... hopefully with different names! It would certainly address the Badge of Honor issue you mention. After all, we do have “Master Riggers” for the chute folks.

At any rate, I realize this is the FAA talking!

Thanks for D.O.M. magazine, and I look forward to receiving HeliMX magazine.

Thank you for your time.

Walt Hankinson

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