IA Renewal Requirements
10/21/1977
October 21, 1977
Mr. James P. Entrekin, Esq.
Dear Mr. Entrekin:
The Chief Counsel has asked me to respond to your letter of August 27, 1977 inquiring about the "Activity Report" requested by the Houston GADO in connection with Inspection Authorization (AI) renewal forms.
Section 65.93 of the Federal Aviation Regulations (14 C.F.R. 65.93) details the requirements for inspection authorization renewal. Subsection (a) provides, in pertinent part, that:
To be eligible for renewal of an inspection authorization for a one-year period an applicant must present evidence at an FAA General Aviation District Office during the month of March that he still meets the requirements of Section 65.91(c)(1) through (4), and by showing that during the current period that he held the inspection authority
He:
(1) Has performed at least one annual inspection for each 90 days that he has held the current authority;
(2) Has performed inspections of at least two major repairs or major alterations for each 90 days that he held the current authority; or
(3) Has performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator.
The reason for requesting the Activity Report is found in the section 65.93 language, "present evidence," followed by an explanation of what that evidence should include. The Activity Report is merely a means of providing evidence of the information supplied in Item 10 ("Basis for Renewal") of Form 8310-1. Included in the report should be a listing of all pertinent information regarding the aircraft inspected, repaired or altered by the mechanic since the last renewal application was filed.
The GADO is, of course, available to further explain the specifics of their request to those individuals who might be unsure of what to include in the Activity Report.
The GADO request for an Activity Report in advance of the annual AI/Maintenance meeting, which is announced in the same Maintenance Bulletin as the one which encloses the renewal forms, is done primarily to expedite the renewal process. By sending the forms and the Activity Report to the GADO prior to this meeting, the applicant helps ensure that the necessary paperwork is completed in advance. The AI certificates can then be signed and issued at the meeting after a quick oral review with the applicant of the information contained in the report.
The annual meeting is not mandatory. If the applicant does not attend, other arrangements must be made individually with the GADO. In this instance as well, the Activity Report should be prepared in advance so that, when the applicant meets with the inspector, the two of them can orally go over the aircraft inspected and repaired and the AI Certificate can be issued during the same appointment.
The Activity Report procedure is as much for the convenience of the applicant as for the GADO. Without the information contained in the report, the FAA Inspector will not be able to properly make the determination that section 65.93(a) has been complied with, and the renewal process for the applicant could then become unnecessarily protracted.
The statutory authority of the FAA for requesting this report is contained in sections 313 and 601 of the Federal Aviation Act of 1958.These provisions confer on the Federal Aviation Administrator the power to issue regulations necessary to provide adequately for safety in air commerce. In addition, section 609 of the Act gives the Administrator specific authority to reexamine any civil airman.
I hope this information will clear up any questions you may have had concerning this matter.
Sincerely,
ORIGINAL SIGNED BY
EDWARD P. FABERMAN
for
NEIL EISNER
Assistant Chief Counsel
Regulations & Enforcement Division
Office of the Chief Counsel