IA Renewal

[Gilbert Pierce]

How many of you IA's out there believe 2 major repairs or alterations count as 1 annual for IA renewal?

I was just told you have to do either all annuals or all major repairs/alterations and they cannot be mixed in a one year period.
Here is what 65:93 says:

Electronic Code of Federal Regulations

e-CFR data is current as of March 14, 2019

Title 14 → Chapter I → Subchapter D → Part 65 → Subpart D → §65.93

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Title 14: Aeronautics and Space
PART 65—CERTIFICATION: AIRMEN OTHER THAN FLIGHT CREWMEMBERS
Subpart D—Mechanics

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§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 the responsible Flight Standards 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.




Here is what my PMI just told me:

VOLUME 5 AIRMAN CERTIFICATION

CHAPTER 5 TITLE 14 CFR PART 65—AIRMEN OTHER THAN FLIGHT CREWMEMBERS Section 8 Renew a Part 65 Inspection Authorization


B. Eligibility.

Meeting the requirements of § 65.93(a) does not mean that the applicant has to meet all five of the listed requirements. To be eligible for renewal of an IA for a 2-year period, the applicant must show evidence of:
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 (see Figure 5-99, Sample FAA Form 8610-1, Mechanic’s Application for Inspection Authorization (Renewal by Completion of One of the Activities in § 65.93(a)(1) through (3))).

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 within one year simply because § 65.93 does not provide for such combinations.

This defies all logic in my mind. But who ever said bureaucrats were logical.