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

S ubparagraphs {(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 f rom 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 ye ar, 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 pr ovide 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 currentl y 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 (annuall y) the y 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/alter ations 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 b y an IA be an y 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 perform ed.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) Currentl y reads: (a) To be eligible for renewal of an inspection authorization for a 2

- year peri od an applicant must present evidence during the month of March of each odd

- numbered ye ar, 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 additio n, 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

- ye ar inspection authorization period, and completion o f one of the five activities during the second ye ar of the 2

- ye ar period: (1) Performed at least one annual inspection for each 90 day s that the applicant held the current authority ; or (2) Performed at least two major repairs or major alterations for ea ch 90 day s that the applicant held the current authority ; or (3) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed b y 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 b y an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current. (b) The holder of an inspect ion authorization that has been in effect: (1) for less than 90 day s before the expiration date need not compl y with paragraphs (a)(1) through (5) of this section. (2) for less than 90 day s 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

- ye ar 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 Marc h 31 of the first year of the 2

- ye ar 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 isdeemed to have completed the requirements of §65. 93(a) (1) through (5) by March 31 of

the first year. I suggest it read: ( C hange 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 ye ar, at an FAA Flight Standards District Office or an International Field Office, that the applicant still mee ts 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

- ye ar inspection authorization period, and completion of one of the six activities during the second ye ar of the 2

- year period: (1) Performed at least one annual inspection for each 90 day s that the applicant held the current authority ; or (2) P erf ormed at least two major repairs / alterations for each 90 day s that the applicant held the current authorit y; 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 leas t 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 ye ar; or, 1 annual (25%) + 7 major repairs/alterations (87.5%) = 112.5%, qualified for one renewal ye ar. ( 4 ) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed b y the Administrator; or ( 5 ) Attended and successfully completed a refresher course, accept able 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 authorizat ion that has been in effect: (1) for less than 90 day s before the expiration date need not compl y with paragraphs (a)(1) through (5) of this section.(2) for less than 90 day s before March 31 of an even

- numbered year need not comply

with paragraphs (a)(1 ) through (5) of this section for the first y ear of the 2

- ye ar 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 fi rst year of the 2

- ye ar 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) thro ugh (5) by March 31 of the first year.