Brian Blazey

I oppose this proposed change as it relates to renewal of Inspection Authorization (IA). Airworthiness Safety Inspectors (ASI) will have an unfair advantage over other Aviation maintenance Technicians who hold Inspection Authorization. This proposed change will allow an ASI to perform inspections provided he is not compensated, and will not require him to meet the same level of competency as non-FAA employed IAs. Since ASIs provide governmental oversight over all Aviation Technicians, they should be held to the same standard, not a lesser standard. There is no documented evidence that the frequency of performing IA duties has an effect on the competency of the IA. An IA with many years of experience who works infrequently is likely more competent than a new IA with limited experience who happens to work continuously. We would lose a vital experience resource if "retired" IAs were not allowed to renew because they are less than actively engaged. It is not required to "renew" and A&P certificate. There is no recency of experience required. It should be the same for an IA. Only if an ASI has reason to believe that an IA is performing less than satisfactory work should that IA be required to demonstrate competency. (Just like an A&P or a pilot). The FAA should be finding ways to make government smaller and less restrictive while preserving or improving safety. I also object to the FAA revising FAA Form 8610-1, Mechanic's Application for Inspection Authorization, before this comment period has closed. It gives the appearance that the rule change will proceed regardless of the comments received.