Joint Comments Differentiate Between Authorization and Rating
September 08, 2026
On Sept. 1, ARSA and the Aircraft Electronics Association (AEA) jointly submitted comments to the FAA’s notice of proposed rulemaking to eliminate the need for a mechanic that holds an inspection authorization (IA) to renew the privilege. The proposal would amend part 65, subpart D to create an “Inspection” rating for mechanic’s certificates.
The associations fully supported the government’s intended result: Reduce the burdens on agency and industry associated with IA renewal efforts. However, their comments highlight the special privileges afforded are maintenance activities and are not appropriate for a rating.
“The associations propose the agency merely adjust the current regulations to remove the requirement to renew the authority,” the comments said. “The renewal would be replaced with the requirement for the mechanic with inspection authorization to keep records showing active engagement, capability to perform the tasks, and the authorizations undertaken.”
The comments focus particularly on the requirement for all mechanics to demonstrate “active engagement” under § 65.83. The documentation and attention needed to assure this “active engagement” is consistent with an IA’s responsibility to maintain the knowledge, professionalism, and consistent application of capabilities in performance of work.
By leaving the authorization where it is and merely adding the new requirements for recordkeeping that replace the renewal requirement, the agency can save itself and the industry even more time and effort.
To read ARSA and AEA’s comments, click here.
Previous IA-related policy updates...
4/10/23 - FAA Can’t Help Itself on IA Renewal Policy
April 10, 2023
On April 10, the FAA informed providers of Inspection Authorization renewal courses that applications for acceptance can now be made on the new Form 8610-6. The document’s release is part of the agency’s multi-year overhaul of its procedures and guidance for managing acceptance of IA training. Although an updated advisory circular for course management and credit remains in development, the FAA has prioritized beginning to accept applications under the new guidance in Order 8900.1.
Unfortunately, the policy updates double down on the most unwieldy elements of the previous FAA process. The new procedures in 8900.1 simply rearrange various responsibilities, tweak communications steps, and extend timelines but do nothing to balance the system’s complexity with the simplicity of § 65.93(a)(4).
In October 2021, ARSA submitted comments (see below) on the still-in-production draft AC to provide overarching encouragement to the FAA for enabling such simplicity. The association’s comments continued years of dialogue regarding the flexibility afforded by the words “acceptable to” in the rule. ARSA provided its own draft guidance that would allow the government to eliminate individual training review, remove unnecessary time restrictions, and refocus attention on mechanics seeking acceptance rather than expending resources on provider oversight.
The new policy fails to offer new industry flexibility and does not significantly decrease bureaucratic burden. Given the value of broad access to professional training, ARSA will continue to focus on ways to streamline credit acceptability while pressing the government to improve how it supports professional and technical growth not only in the industry but also in its own ranks.
Stay tuned to ARSA for continued efforts related to career development and training. The association’s 22 sessions that have been found acceptable for IA renewal credit will remain valid through 2026.
To read the new language in Order 8900.1, click here.
To see ARSA’s IA renewal training sessions, click here.
11/2/21 - Thinking Simpler on IA Renewal
November 2, 2021
On Oct. 28, ARSA submitted comments to the FAA on Draft Advisory Circular (AC) 65-IART, which would overhaul the agency’s approach to acceptance of training for Inspection Authorization (IA) renewal credit.
For several years, ARSA has been encouraging the FAA to streamline its procedures related to IA renewal course acceptability. Citing the relative simplicity of § 65.93(a)(4), the flexibility afforded the words “acceptable to” under the rules and the value of broad access to professional training, the association has urged the agency to eliminate cumbersome, time-bound reviews of individual training sessions.
“The agency already recognizes this flexibility in both the current procedures outlined in Order 8900.1 and in … the draft AC. Certain entities, including private organizations as well as specified FAA offices, may provide courses that are acceptable to the Administrator without prior review. This practice should be expanded to any provider that demonstrates in writing their ability to offer appropriate training and document completion in a way that is ‘sufficient for the student to claim IA renewal credit,’” ARSA’s comments said, quoting applicable language from the draft AC.
To support the FAA, the association provided a rewritten draft AC that its team has been circulating among trade association allies and referencing in direct engagement with the agency. The rewrite defined basic requirements for acceptable courses while offering three key alterations from current practice:
(1) Eliminating individual acceptance of training courses by setting standards for provider acceptability.
(2) Removing unnecessary time restrictions on course acceptability by eliminating the automatic expiration of acceptance.
(3) Including instruction for eligible mechanics in submitting evidence of course completion.
“By simplifying IA renewal training acceptance, the FAA can limit its own administrative burden while allowing flexibility to both training providers and IA renewal applicants,” ARSA concluded. “The resulting procedures would be consistent with the requirements of § 65.93(a)(4) while advancing agency-wide goals for improving workforce development and training.”
To review the entire comment package, including cover letter and rewritten Draft AC 65-IART, click here.
What you should do…
(1) Contact the FAA and indicate support for the comments (click here to load an email to the responsible agency contractor).
(2) Share IA renewal experiences with the association by emailing Vice President of Operations Brett Levanto (brett.levanto@arsa.org) with the subject line “Overhauling IA Renewal.”
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