"Refresh" old A&P License

Scott_M

Filing Flight Plan
Joined
Nov 14, 2021
Messages
27
Display Name

Display name:
Scott_M
I received my original A & P mechanic license in the early 1990s. It has never been surrendered, suspended, or revoked. I used it for a brief time and then left the industry and made money. I remember the FARs requires me to use my license for at least 6 months in any 24 month period to maintain my license. How should I make my license active/valid again?
 
Start working….have a friend supervise you for 6 months. There isn’t any sign off or anything formal. Just begin performing your A&P duties.
 
How should I make my license active/valid again?
Technically, you either work under the supervision of another AP for that 6 months or you visit your local FSDO and have an ASI annoint you with their blessing to exercise your A&P priviledges. However, neither require any formal documentation.
 
I received my ... mechanic license ... used it for a brief time and then left the industry and made money...
Ah, an alternative to the "in order to make a small fortune in aviation, start with a much larger one" plan. :)
 
Is your license still the original paper one from the 90s? If so, you'll need to apply for the current 'new' plastic version. If I remember, this can be done simply, online, for maybe a very nominal fee, no test required.
Edit: You'll also probably want to change your certificate number from your social security number, which was standard as your airmen certificate number back then.
 
Last edited:
Buy a bunch of used aircraft spark plugs, clean and gap them everyday for 6 months.
Ah, the Pat Morita (Mr. Miyagi) school of Aviation Maintenance and Karate, "wax on-- wax off."
 
Technically yes, there is that vague currency requirement but it's not clear as to what sort or how much activity is required. So it really depends on what you are planning to do with your "reactivated" A&P license. If you intend to just start working on other people's airplanes and signing off their logbooks there is also the vague requirement that you have experience and know what you're doing but there's nobody running checks or watching you. It's like a video surveillance camera. there isn't a guy watching 24 hrs of video every day, nobody looks at it unless something happens. If you're an aircraft owner I'd say your covered. If you want to become an aircraft owner well then you'd surely be covered six months after writing the check.
 
Here's the deal.

It is always best to read the relevant regulation along with any other published guidance or rulings and attempt to understand it. The applicable regulation is pasted below.

65.83 Recent experience requirements.
A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months -
(a) The Administrator has found that he is able to do that work; or
(b) He has, for at least 6 months -
(1) Served as a mechanic under his certificate and rating;
(2) Technically supervised other mechanics;
(3) Supervised, in an executive capacity, the maintenance or alteration of aircraft; or
(4) Been engaged in any combination of paragraph (b) (1), (2), or (3) of this section.


So there are two basic ways to have the requisite recent experience requirements, and both of them are based on events occurring in the most recent 24 month period.

Let us look at 65.83(b) first, specifically (b)(1). I will not deal with (2) through (4) as those are not applicable to the OP as written. (b)(1) states in part mechanic must have "served as a mechanic under his certificate and rating". Note that it states it needs to be under his certificate and rating, not his buddy Tom's certificate. So unless you have actually worked under your own certificate for 6 months out of the most recent 24 months, you may no longer exercise the privileges of your certificate. You still have the certificate but you cannot use it. Working under another mechanic's certificate does not "refresh" your certificate. This is a very common misunderstanding.

So, without that 6 months in 24 months, you are essential SOL... unless you comply with 65.83(a). This paragraph is used in two manners by the FAA.

The first manner in which it is used is for the 24 month period beginning immediately after initial certification. When you successfully pass your written exams, pass your oral & practical exams, and are issued your certificate, you have been found capable of performing that work by the Administrator. This applies even though it is issued by a DME as they are designees of the Administrator. This is how a brand spanking new Mechanic can work as a Mechanic. He has been found capable.

The second manner in which 65.83(a) is used and the manner which applies to the OP is for someone who in the preceding 24 months did not meet the 6 month requirement of serving as a mechanic under his own certificate. If you fail to have the recent experience as prescribed in (b), your one and only option is to have the Administrator find you able to do the work. Simple as that. No self-healing by working for another mechanic for 6 months.

So how will the Administrator find you able? Well, first you have to know who the Administrator is in this case. The answer is that it would be your local FSDO Airworthiness ASI. And how he chooses to find you able is greatly at his discretion and will be dependent on factors such as; how long you have worked as an A&P, how long since you last worked as an A&P, and YOU. What I mean is that if you worked as an A&P for 20 years and then took two years off, he might very well just give you a brief oral exam/interview and then call you good. If you got your A&P, worked for a very short timeframe and then dropped out for several years or a couple of decades, expect a lot more. Do not discount the possibility of an abbreviated written exam along with an interview. It is very likely to happen. He might also refer you to the local Part 147 school. Some offer refresher courses. At the end of the day, it is up to your local FAA.

In support of this point of view, I'd offer for your reading pleasure FAA Order 8900.1 Volume 6, Chapter 11, Section 15, Paragraph 6-2521 D. There is a note that states:

NOTE: Recent experience determination in § 65.83 is through a thorough evaluation of the individual's knowledge and skill to the extent that the inspector can determine sufficient qualification exists for exercising the privileges and limitations of a mechanic certificate. The evaluation criteria are at the discretion of the inspector and may consist of a review of past experience, a knowledge test, or other information provided by the mechanic that would show the FAA that the certificated mechanic possesses the knowledge and skills needed to continue to exercise the privileges and limitations of their certificate.

There is also a Chief Counsel opinion you can read if you so desire. It covers the issue fairly well.
https://www.faa.gov/about/office_or...ilva-CommuteAir_2015_Legal_Interpretation.pdf

So a big fat nope to working under Tom, Dick, or Harry. You might as well work under Larry, Curly, and Moe. Unless, that course of action is prescribed by your FAA ASI. And yes, that can and has happened. But it is the FAA's prerogative to allow you to do that.

So before you do anything, call the FSDO and ask to speak to an airworthiness ASI.

By the way, I became an A&P in 1980 and worked until late 2003 in the industry before taking a sabbatical and returning in early 2006. I was out for approximately 2.5 years and when I returned and went to work for a large Part 145 Repair Station, they had me take a 100 question computerized test that their PMI had blessed for folks like me before they let me start work.

And that is my final answer. What one chooses to do with it is up to them. I am not willing to debate it. Homey ain't playin' that game no mo'.
 
I looked up the FAA order that you referenced, and here's what I found:

1/29/20



8900.1 CHG 0

VOLUME 6 SURVEILLANCE
CHAPTER 11 OTHER SURVEILLANCE

Section 11 Monitor an Air Show/Air Race for Airworthiness Inspectors
 
When I went for my IA some time ago…. No one even asked. They just wanted the last couple sign offs. And I went over fifteen years of nothin.
 
Here's the deal...

NOTE: Recent experience determination in § 65.83 is through a thorough evaluation of the individual's knowledge and skill to the extent that the inspector can determine sufficient qualification exists for exercising the privileges and limitations of a mechanic certificate. The evaluation criteria are at the discretion of the inspector and may consist of a review of past experience, a knowledge test, or other information provided by the mechanic that would show the FAA that the certificated mechanic possesses the knowledge and skills needed to continue to exercise the privileges and limitations of their certificate...

Well you see this is one of those things that are vague. Who does this evaluation? Do you get a stamp or a letter or some indication to prove you've been "evaluated"? There is nothing on the A&P license itself that indicates any sort of currency status and as far as the administrator determining you are capable well, they did that when you passed the written and practical so unless you've gone blind or lost a couple of limbs why would you now not be? If you were looking to be hired by someone as a mechanic I imagine it would be up to them to determine if you were qualified or if they wanted to hire you and maybe they would want you to get an administrator's blessing but, like I said, it's just kind of gray and undefined despite being a typically wordy regulation.
 
Back
Top