An effort to change the Inspection Authorization renewal period to two years has blossomed into a proposal to update 14CFR Part 43 and 65, and the result should be a notice of proposed rulemaking (NPRM) to be issued in November by the FAA. Mike Harkins, president of the First State Chapter of the Professional Aviation Maintenance Association (PAMA), launched this rulemaking effort early this year, initially working on just the expansion of the IA renewal to a two-year interval. Harkins and PAMA expanded the effort to include possible changes to Parts 43 and 65, and the FAA added its support as well.

The result of this effort is a pre-NPRM document, an FAA AFS-300 division white paper titled, Proposed Changes to FAR Parts 1, 43, & 65. The white paper is available online at www.pama.org/files/part_43_65_white_paper.pdf. and available for anyone to read and comment on. PAMA president Brian Finnegan is soliciting comments and can be reached at 703-417-8811 or bfinnegan@pama.org.

There are two phases in the rule-change proposal. Phase I covers simple changes that won't cost the FAA a lot of money and manpower. Phase II changes are more complicated and the process could stretch out to three to five years.

Phase I proposals:

• Require training for each task for any person performing maintenance, including pilots doing preventive maintenance. This would change rule 43.13.
• Change rule 65.81(a) so A&P mechanics could overhaul a wet compass.
• In 65.93, allow IAs to use a combination of annual inspections and major repairs or alterations to qualify for renewal. One annual would be equal to two major repairs or alterations. This rule would also allow an IA to qualify for renewal by performing one section 91.409(e)(f) inspection (large or turbine-powered Part 91 aircraft).
• Change the IA-renewal period to two years, but also double the renewal requirements.
• Allow IAs to sign FAA Form 8130-3 for approval to return to service only.
• Add the definitions of "airworthy" and "condition for safe operation" to Part 1.

Phase II proposals:

• Create subparts in Part 43 for Type Certificated, Experimental, Light-Sport, and Public-Use aircraft to make performance rules and inspection requirements are more clear.
• Replace Part 43 Appendix D (scope and detail for 100-hour/annual inspection with an easier-to-update advisory circular.
• Update Part 43 Appendices E and F to reflect current operational requirements for altimeter and transponder inspections.
• Revise Part 43 Appendix A to update major/minor repair listtings.
• Add a new aviation maintenance engineer rating for mechanics in Part 65 Subpart D.
• Create a new mechanic rating for avionics.

The FAA is hoping to include the Phase I changes in an upcoming NPRM for commercial space flight crewmember certification, which is on the FAA Office of Rulemaking A list. This NPRM is scheduled for publication in November 2005. "By piggybacking Phase I revised rules onto the commercial space flight crewmembers NPRM," the FAA white paper stated, "it will reduce the amount of time needed for rulemaking from three years to one year."

The commercial space flight crewmembers NPRM has an interesting feature that impacts aircraft mechanics. According to the FAA, certification of spaceflight crewmembers will treat ground crew personnel as space flight crewmembers. What this means is that for the first time, maintainers (ground crew) will have the same status as flight crew.

PAMA president Finnegan is delighted with this recognition and believes it will enhance the status of aircraft mechanics. "We are part of the flight crew," he said, "and you don't go until we say you can go."