Leave the System As It Is

Hello Joe,

I have not spoken to you in some time. I always read your magazine however, and usually agree with what you have to say, until the Jan/Feb 2011 issue.

Your position on the “surrender” of an Inspection Authorization (IA) certificate is somewhat mystifying to me. The IA certificate, the possession of which allows one to exercise, on behalf of the FAA, the privileges delineated in FAR 65.95, is not easily earned or lightly exercised. It is a statement of the drive and desire of an individual to acquire specified knowledge, and the demonstration of applying that knowledge through rigorous testing.

Further, the IA is not something which once obtained, is yours forever. Rather, it requires constant and continuous exercising of the privilege through hands on labor, supervision of labor or continuing education in the field.  And, as has been explained often in the past by representatives of the FAA, including their legal division in Washington, Paragraph 65.93 (a)(4) was specifically written to address the kinds of non-hands on IA holders you talk about in the article. It provides for keeping abreast of the changes going on in the aviation field, and changes in the regulations which govern that endeavor; that same kind of continuing education doctors, nurses, teachers, CPA’s and many other professions are required to obtain to retain their credentials. I can’t recall hearing of any instances where, when doctors became administrators, they were asked to surrender their medical license.

Moving up within ones chosen profession (and our “trade” is as critical a profession as the medical field) does not mean you leave behind the knowledge and expertise you have gained in working within the profession. It is rather a chance to expand your knowledge, and apply it in new and different ways.

As to an individual being in a position where he/she “has no need to exercise the privileges of an IA,” who can forecast the future? 

Using myself as an example, I retired from the position of facility manager of an overhaul depot which worked on U.S. Government aircraft. Because the aircraft were nominally maintained in accordance with FAR Part 43, with the concurrence of the FAA, we were able to retain our IA’s. After leaving there, I was able to maintain my IA by virtue of Paragraph 65.93 (a)(4). Then, having becoming bored with nothing much to do (after rebuilding my house as a result of a visit from something named Katrina), I started flying occasionally for the local FBO, and maintained my own aircraft in their facility. Because there is a serious shortage of IA’s in that area this led to other aircraft owners asking if I would perform their Annual Inspections, and that became a full time job. Had I surrendered my IA years earlier because I ”had no need to exercise the privileges of an IA,” it would have deprived me of something constructive to do, and the others of a reasonably priced place to have their required maintenance performed.

You posit that this move by someone within the FAA might be about advanced certification. What advanced certification? The FAA is not in that business, that is the business of companies or “professional” organizations which have something to sell. They become the certifiers, and control who gets admitted and advanced.

No, Joe, I think we need to leave the system as it is, and stop trying to fix something which gets more broke every time we adjust it.

Gary B. Frederickson