Charles Knowles

I am opposed to the Proposed Policy change 14 CFR Part 65; Federal Register Vol. 78, No. 214. Please withdraw. It seems as if government bureaucracy has instituted a poorly designed, ambiguous, expensive and arbitrary solution to a problem that doesn't exist. The current system works and needs no changes. Part 65 clearly provides for renewal of the IA authority. This is extremely important for IA renewal for many experienced IAs who are now in managerial positions or have moved to other industries but are employed in aviation part-time. To change the current system would be detrimental to the industry and those who have worked their way, through their hard work, great expense and efforts to reach their current status in the aviation maintenance industry. I have had my A&P license for over 30 years and my IA for 7. Although I am actively engaged (full time employment as a line mechanic for FedEx Express) thus I meet the requirements, I am still opposed to this proposed change. This proposed rule does not clarify what "minimum activity" is, and worse, it leaves the decision-making up to a government official (the ASI) to determine (clearly a subjective and time-consuming effort). The ASI cannot be made fully capable of determining this definition and is likely to base his or her decision on personal feelings and judgment. Further, it appears as if an ASI does not have to follow the same rules as all IAs would have to follow under this amendment. Are rules only for some? There is no due process if an ASI arbitrarily refuses an IA renewal.