I am submitting this ‘Petition for Rulemaking’ to suggest amending 14 CFR § 65.93(a). 

Subparagraphs {(a)(1) and (2)} separate work performed by an IA towards renewal 

(annuals and major repairs/alterations) for no evident reason. The following is quoted 

from FAA Order 8900.1 CHG 211, Vol. 5, Ch. 5, Sec. 7, para. 5-1309 B (1) and its 

following NOTE:

“1) Performing four annual inspections during each 365-day period prior to March 31 of 

each year, for a total of eight annuals prior to the renewal date, to be able to qualify for 

renewal.”

“NOTE: The same logic applies for major repairs and major alterations or training. 

However, the number of annual inspections, major repairs, and major alterations 

performed cannot be mixed simply because § 65.93 does not provide for such 

combinations.”

It appears by the language used in the note, “simply because”, that there is no other 

reason for not allowing annuals and major repairs/alterations to be mixed. Rather than 

modify/clarify the rule there is an excuse as to why something can’t be done, thus the 

problem is the rule.

If a percentage of value for each task were assigned to annuals performed by an IA each 

would receive 25%, as an IA must currently do 4 annuals each year to qualify; 

 4 annuals x 25% each = 100%, ‘qualified’ for one renewal year.

Since renewal requires 8 major repairs or alterations (annually) they add up as:

 8 major repairs/alterations x 12.5% each = 100% qualified for one renewal year.

Currently if an IA does 3 annuals and 7 major repairs/alterations he is not qualified for 

renewal, even though he would have performed 162.5% of the required tasks by the 

method demonstrated above.

It is suggested that the work performed by an IA be any combination of annuals or major 

repairs/alterations that arrive at or exceed 100%. Example; 

2 annuals (50%) + 4 majors (50%) = 100%, qualified for one renewal year.

or

1 annual (25%) + 7 majors (87.5%) = 112.5%, qualified for one renewal year.

“Simply because” is not a good enough reason to discount what could be a substantial 

amount of an IA’s work. IA’s that are performing annuals and major repairs/alterations 

should be better versed in their work than those that are performing just one or the other. 

The rules should reward them for the work they’ve performed.
If this suggestion is adopted changes to the FAA Order 8900.1 referenced above would 

also be necessary.

14 CFR § 65.93 (Inspection authorization: Renewal) Currently reads: 

(a) To be eligible for renewal of an inspection authorization for a 2-year period an 

applicant must present evidence during the month of March of each odd-numbered 

year, at an FAA Flight Standards District Office or an International Field Office, that 

the applicant still meets the requirements of §65.91(c) (1) through (4). In addition, 

during the time the applicant held the inspection authorization, the applicant must 

show completion of one of the activities in §65.93(a) (1) through (5) below by March 

31 of the first year of the 2-year inspection authorization period, and completion of 

one of the five activities during the second year of the 2-year period:

(1) Performed at least one annual inspection for each 90 days that the applicant held the 

current authority; or

(2) Performed at least two major repairs or major alterations for each 90 days that the 

applicant held the current authority; or

(3) Performed or supervised and approved at least one progressive inspection in 

accordance with standards prescribed by the Administrator; or

(4) Attended and successfully completed a refresher course, acceptable to the 

Administrator, of not less than 8 hours of instruction; or

(5) Passed an oral test by an FAA inspector to determine that the applicant's knowledge 

of applicable regulations and standards is current.

(b) The holder of an inspection authorization that has been in effect:

(1) for less than 90 days before the expiration date need not comply with paragraphs 

(a)(1) through (5) of this section.

(2) for less than 90 days before March 31 of an even-numbered year need not comply

with paragraphs (a)(1) through (5) of this section for the first year of the 2-year 

inspection authorization period.

(c) An inspection authorization holder who does not complete one of the activities set 

forth in §65.93(a) (1) through (5) of this section by March 31 of the first year of the 2-

year inspection authorization period may not exercise inspection authorization privileges 

after March 31 of the first year. The inspection authorization holder may resume 

exercising inspection authorization privileges after passing an oral test from an FAA 

inspector to determine that the applicant's knowledge of the applicable regulations and 

standards is current. An inspection authorization holder who passes this oral test is 
deemed to have completed the requirements of §65.93(a) (1) through (5) by March 31 of 

the first year.

I suggest it read: 

(Change bars identify locations of changed text, underlining identifies the exact locations 

of the changes)

14 CFR § 65.93 (Inspection authorization: Renewal) 

(a) To be eligible for renewal of an inspection authorization for a 2-year period an 

applicant must present evidence during the month of March of each odd-numbered 

year, at an FAA Flight Standards District Office or an International Field Office, that 

the applicant still meets the requirements of §65.91(c) (1) through (4). In addition, 

during the time the applicant held the inspection authorization, the applicant must 

show completion of one of the activities in §65.93(a) (1) through (6) below by March 

31 of the first year of the 2-year inspection authorization period, and completion of 

one of the six activities during the second year of the 2-year period:

(1) Performed at least one annual inspection for each 90 days that the applicant held the 

current authority; or

(2) Performed at least two major repairs/alterations for each 90 days that the applicant 

held the current authority; or

(3) Performed a combination of (1) and (2). To qualify for renewal the combined 

annuals and major repairs/alterations must add up to at least 100%. Each annual is worth 

25% and each major repair/alteration is worth 12.5%. Examples of combining: 2 

annuals (50%) + 4 major repairs/alterations (50%) = 100% qualified for one renewal 

year; or, 1 annual (25%) + 7 major repairs/alterations (87.5%) = 112.5%, qualified for 

one renewal year. 

(4) Performed or supervised and approved at least one progressive inspection in 

accordance with standards prescribed by the Administrator; or

(5) Attended and successfully completed a refresher course, acceptable to the 

Administrator, of not less than 8 hours of instruction; or

(6) Passed an oral test by an FAA inspector to determine that the applicant's knowledge 

of applicable regulations and standards is current.

(b) The holder of an inspection authorization that has been in effect:

(1) for less than 90 days before the expiration date need not comply with paragraphs 

(a)(1) through (5) of this section.
(2) for less than 90 days before March 31 of an even-numbered year need not comply

with paragraphs (a)(1) through (5) of this section for the first year of the 2-year 

inspection authorization period.

(c) An inspection authorization holder who does not complete one of the activities set 

forth in §65.93(a) (1) through (5) of this section by March 31 of the first year of the 2-

year inspection authorization period may not exercise inspection authorization privileges 

after March 31 of the first year. The inspection authorization holder may resume 

exercising inspection authorization privileges after passing an oral test from an FAA 

inspector to determine that the applicant's knowledge of the applicable regulations and 

standards is current. An inspection authorization holder who passes this oral test is 

deemed to have completed the requirements of §65.93(a) (1) through (5) by March 31 of 

the first year.