text:
Federal Aviation Administration
Office of the Chief Counsel
Attn: Rules Docket (AGC-200), Rm. 915G
Docket No. 27863
800 Independence Avenue, SW
Washington, DC 20591
The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more than 340,000 pilots and aircraft owners, submits the following comments to the proposed Revision of Certification Requirements: Mechanics and Repairmen published in the Federal Register for public comment on July 9, 1998. AOPA counts among its membership approximately 20,000 airframe and powerplant mechanic certificate holders. Many of these certificate holders are actively engaged in the maintenance of aircraft for compensation or hire while others exercise the privileges of their certificate primarily for the conduct of maintenance and inspection of their own personal aircraft.
AOPA supports the notion of codifying the various maintenance personnel certification regulations under a separate Part 66. Further, we support the effort to generally review the certification standards for inconsistencies and relevance to current industry practice and technological advancements. However, we feel strongly that this proposal has far exceeded the bounds of being a general review and update to the regulation and has added a level of confusion and complexity that is likely to present significant disruption, economic, and administrative burdens to the aviation industry.
The existing aviation maintenance personnel certification regulations have provided a consistent, understandable, and efficient system for the training and assurance of competency of mechanics, inspectors, and repairmen for over four decades. The effectiveness of these regulations is demonstrated by the extraordinarily low number of petitions for rulemaking or exemption from Part 65 submitted to the Federal Aviation Administration (FAA) over the past 40 years. To our knowledge there have only been three petitions for rulemaking submitted to Part 65 since 1962. Of these three petitions, two have still not been addressed within the scope of this rulemaking. These are establishment of an avionics and instrument technician certificate and requests for students of Part 147 aviation maintenance training schools to be able to complete the oral and practical tests prior to completing the written tests. Nearly all of the petitions for exemption have focussed on renewal requirements for the inspection authorization (IA) or general eligibility and experience requirements. None of these issues have either been addressed or used by the FAA as justification for this rulemaking proposal.
In our view, the bulk of this rulemaking proposal represents a solution looking for a problem. The FAA appears to have lost sight of the elegant synergy that exists between the current §65.81 General privileges and limitations and the performance regulation of §43.13. Under this synergistic relationship, the exercise of any maintenance privilege on any aircraft (regardless of type certification basis) is predicated upon a combination of training, supervision, or experience. This simple yet comprehensive regulatory structure between Parts 65 and 43 already provides virtually everything that this extremely complex rulemaking proposal endeavors to create through its two-tiered certification of technicians, inspectors, and instructors.
The FAA has identified a number of "issues" in the preamble to the proposed rule that have been used as justification for this rulemaking activity. We believe that the bulk of these justifications are either not relevant to the aviation maintenance environment today or have not been addressed by the proposed rulemaking. Over the past decade there have been considerable changes in the aviation maintenance profession that has rendered much of the original rationale for this proposal obsolete. These points have been addressed at great length in comments submitted to the docket by the National Air Transportation Association (NATA) and the Professional Aviation Maintenance Association (PAMA), so we will not endeavor to repeat them here. However, it does raise the point that since the facts used as supporting rationale behind this rulemaking activity have changed, then the proposal should be substantially reexamined for its relevance and applicability today.
AOPA participated on the Aviation Rulemaking Advisory Committee (ARAC) working group, an issues group responsible for drafting and submitting the various rulemaking proposals for the revision to the current Part 65. We are dismayed to find that the potentially two most significant points of the ARAC process have not been documented in the preamble to the proposal. First, nowhere is it stated that the proposed rule set forth in this notice was submitted to the FAA without the consensus of ARAC. In fact, there was significant disagreement over this proposal within the aviation industry. A number of major organizations representing large segments of the aviation industry, including AOPA, opposed the draft final rule. Some organizations submitted minority opinions, which under the ARAC process are supposed to be reflected in the preamble of any proposed rule. None of this has been documented in Notice No. 98-5.
Further, at no point in the preamble is it mentioned that the primary if not sole motivator for the two-tiered certification process (which raises so much opposition) came strictly from labor union representatives. These labor unions ardently sought a second certificate for the common practice of seeking increased monetary benefit at the collective bargaining table from the added rating. The issue was not a deficiency in training and experience of maintenance personnel at the major air carriers or the technological differences between Part 25 and Part 23 aircraft as stated in the preamble. AOPA strongly urges the FAA to completely and fairly reexamine the entire rulemaking proposal with a view toward meeting the actual needs of the aviation industry as a whole. We believe that the existing certification, proficiency, and currency processes for aviation maintenance personnel are not broken and do not require a complete overhaul. We do, however, recognize that certain aspects of the aviation maintenance training curriculum requires updating, and there may in fact be a need to increase the amount of classroom time it takes to present this new information. However, AOPA maintains that this training or experience should be applied to all future aviation maintenance personnel regardless of the type certification basis of the equipment they work on.
The following is a section-by-section response to the proposed new Part 66, Revision of Certification Requirements: Mechanics and repairmen:
§66.1 Applicability.
AOPA is strongly opposed to the proposal to create two levels of certification for aviation maintenance personnel. In our view, the distinction between the AMT and AMT(T) ratings is unjustified and impractical and could ultimately lead to a shortage of qualified aviation maintenance personnel for large segments of general aviation. This is due to the fact that most AMTs would become something of a second-class citizen and could not be hired in the majority of repair stations since maintenance is often performed on the full range of Normal, Utility, Commuter, and Transport category aircraft by these facilities. Further, the burden of ensuring that maintenance personnel are in fact current on Transport category aircraft or equipment falls to the employer, adding new economic burdens that have not been accounted for by the FAA in its cost analysis for this proposed rule.
AOPA will provide more detailed comment on the two-tiered certification proposal in the applicable sections of Subpart C—Aviation Maintenance Technician (Transport). However, we believe that the entire proposal for the AMT(T) should be dropped from Part 66 and all reference to the AMT(T) be removed from each section of the proposed rule.
§66.3 Certification of foreign aviation maintenance personnel.
This section remains unchanged from existing §65.3. AOPA has no additional comment to this section.
§66.5 Application and issue.
This section remains substantively unchanged from existing §65.11 with the exception of a change in terminology from "written" test to "knowledge" test. While the meaning and intent of this change in terminology are understood by previous experience with the relatively recent rewrite of 14 CFR Part 61, nowhere in the regulation, applicable to Part 66, is there any reference to this term. The definition of a knowledge test is not contained in either 14 CFR Part 1 or the proposed Part 66. A knowledge test is in fact defined under 14 CFR Parts 61, 141, and 142 as applicable to each of those parts, however, there is no legal tie to these definitions from proposed Part 66. AOPA recommends that the term "knowledge test" be appropriately set forth and defined in the proposed Part 66.
§66.7 Temporary certificate.
This section has been changed to remove gender references but appears to retain the original intent of existing §65.13. AOPA has no additional comment to this section.
§66.9 Duration of certificates.
This section adds references to the duration of the newly proposed aviation repair specialist issued on the basis of proficiency in a designated specialty area (ARS-I) and the aviation repair specialist certificate issued to an experimental aircraft builder (ARS-III). The duration of these two new certificates is identical to that of the aviation maintenance technician in that they both remain in effect until surrendered, suspended, or revoked. AOPA supports the proposal to develop repair specialist certificates who's portability is not dependent upon current employment by the certificate holder. In our view, a portable repair specialist certificate will improve the quality and quantity of professionals serving many of the specialized and highly technical functions within the aviation industry not currently served by the aviation maintenance technician. In addition, we believe that the ARS-I issuance should be expanded to include avionics as well.
The balance of the section remains largely unchanged with the aviation repair specialist certificate issued on the basis of employment (ARS-II) remaining substantially the same as the existing repairman certificate under §65.15(b).
§66.11 Display of certificate.
This section consolidates existing §65.89 and §65.105 into a single section applicable to all aviation maintenance personnel. The substance of the proposed rule remains largely unchanged from the existing regulations, and AOPA has no additional comment to this section.
§66.13 Change of name: Replacement of lost or destroyed certificate.
This section proposes two changes that will reduce the administrative burden for those maintenance personnel that need to replace lost or destroyed certificates. First, the FAA is proposing to add the use of facsimile confirmation from the Airman Certification Branch to the existing telegram methods used as proof of original certification. AOPA supports this change since the public generally has widespread access to facsimile technology. However, with the rapid increase in public access to the Internet, AOPA encourages the FAA to contemplate the use of e-mail correspondence as an additional alternative to the telegram and facsimile transmission.
The second proposal increases the period during which maintenance personnel may exercise the privileges of their certificates under a temporary confirmation of original certification sent by the FAA in Oklahoma City. The duration would be increased from 60 to 90 days. AOPA supports this change, particularly in light of the fact that the FAA Airman Certification Branch often suffers from considerable backlogs in processing airman certificate applications and replacements. Increasing the duration of a temporary proof of original certification notice does not address the underlying problem of a failure to process airman information in a timely manner; however, the burden imposed on the airmen by the backlog would be significantly reduced.
§66.15 Change of address.
This section proposes a significant new requirement on aviation maintenance personnel who change their permanent mailing address. Current §65.21 requires aviation maintenance personnel to notify the FAA within 30 days of a change in permanent mailing address. Presumably failure to adhere to the existing regulation and provide notification in a timely manner could provoke some form of administrative action against the airman should such a failure become an issue. However, AOPA is not aware of any instance in which the FAA has enforced this provision in the absence of any other violation or offense. Most importantly, the FAA has not substantiated any risk to aviation safety brought about by the longstanding address change procedure currently in place.
Despite this, the FAA is now proposing that aviation maintenance technicians and repair specialists may not exercise the privileges of their certificate after 30 days from a change in permanent address if notification of the change has not been provided to the FAA. This proposal places the employer of maintenance personnel and the aviation maintenance consumer/customer in an extremely perilous position. Under this proposal, an employer or customer of an aviation maintenance certificate holder must somehow be responsible for ensuring that the home address of record with the FAA is in fact where the maintenance technician or repair specialist lives each and every time maintenance is performed. Failure to accomplish this would risk having all work performed by the individual deemed unairworthy at some later date. Under 49 U.S.C. §44709 aircraft could be grounded pending any investigation and any maintenance and or inspections might have to repeated or verified as airworthy by a second source. Given that literally hundreds of aviation maintenance certificate holders may participate directly or indirectly in the maintenance and upkeep of an aircraft each year, there is no practical means to provide the necessary surveillance this proposal would require. The FAA under this proposal has in no manner addressed the costs associated with attempting to provide the required surveillance under this proposal and the fallout from legal, administrative, and certificate action cases that would inevitably ensue.
AOPA believes this proposal will create significant disruption to the aviation community and will spark an endless chain of legal and enforcement actions for no benefit to aviation safety. Currently, the FAA does not rely upon permanent mailing addresses for the dissemination of safety-related information to aviation maintenance personnel, nor has there been any discussion of using such a means in the future. In fact, the FAA is demonstrating its lack of concern for providing direct sources of this type of information by discontinuing the direct distribution of such safety-related information as the AC 43-16, Airworthiness Alerts, to maintenance personnel and other interested parties. The relatively low-priority desire to have accurate mailing addresses for maintenance personnel in no way warrants the suspension of maintenance certificate privileges and the severe disruption it would cause to the aviation industry. AOPA strongly urges the FAA to withdraw this provision from the proposed rule.
§66.17 Periodic registration.
This section proposes a new requirement for initial and periodic registration of aviation maintenance technicians with the FAA. The FAA's premise behind this new requirement is to develop "essential demographic information" that would ostensibly enhance safety. A second stated goal is that the FAA is interested in identifying "active" aviation maintenance technicians. The FAA contends that without demographic information, they are unable to provide safety and training information to active mechanics. AOPA strongly disagrees and further points out that changing an address or renewing a FAA-issued medical certificate, which are designed to satisfy the proposed registration requirement, do nothing for determining the "activity" status of maintenance certificate holders.
Provisions already exist in the regulations for maintaining an accurate database of aviation maintenance personnel demographic information. Current §65.21 and proposed §66.15 require notification of a change of address within 30 days of the change, mandating that the airmen keep their FAA records up to date. Some industry and government interests contend that most maintenance personnel fail to comply with the rule, and thus the FAA database has become inaccurate and out of date. AOPA contends that adding a burdensome periodic registration requirement will do nothing to change this pattern. If maintenance personnel cannot remember to change their address when they move, they certainly are not going to remember to do so every four years. In our view, the FAA is suffering from a compliance problem with an existing regulation. Compliance will only be increased if the maintenance community believes that the FAA is serious about pursuing any non-compliance through enforcement action. However, the FAA must bear the burden for this, not the employers and customers of aviation maintenance personnel.
This raises the point that we outlined in our comments to §66.15. Some parties obviously feel that by suspending the privileges of a maintenance certificate for failure to comply with the registration requirement, the database will suddenly become complete. We disagree and believe instead there will be tremendous enforcement fallout from a new requirement that most people simply would not remember to adhere to. If the FAA feels strongly about having an additional periodic update of its maintenance personnel database, then the FAA should take the initiative and responsibility for sending each affected airman a registration notification in the same manner as states notify automobile registrants and licensed drivers of renewal. Each state conducts this type of activity for millions of automobiles and drivers annually. Surely, the FAA could accomplish such a task for 100,000 maintenance personnel every four years. In any event, the responsibility for registration must lie with the FAA and not the individual airman. And under no circumstances can an unintentional failure to register result in a suspension of certificate privileges. AOPA vehemently opposes any change of address, registration, currency, or proficiency requirements that forces the aviation consumer or maintenance employer to verify unavailable maintenance personnel information in order to ensure that the work performed on aircraft is in fact legally airworthy. This proposal accomplishes few, if any, of the objectives outlined in the preamble to the proposed rule and has the potential to create severe disruption to the aviation industry.
§66.21 through §66.29.
These sections remain largely unchanged from the current Part 65. AOPA has no specific comment to these sections.
§66.31 Waivers: Policy and procedures.
AOPA strongly supports the addition of this section, which permits deviation from certain eligibility requirements if the administrator finds that an applicant can safely exercise the privileges of the certificate or rating. This section provides an avenue for potential applicants with certain medical or physical disabilities to serve as productive contributors to the aviation maintenance profession. This section brings the aviation maintenance personnel certification requirements in line with the Americans with Disabilities Act of 1990. AOPA supports the comments to this docket of the Internation Deaf Pilots Association (IDPA).
§66.51 Eligibility requirements: General.
AOPA strongly supports the addition of language permitting the use of qualifying statements and limitations on a maintenance certificate should an applicant not meet one or more of the eligibility requirements. Of greatest concern to us has been the inability of potential maintenance certificate applicants who are deaf, hearing impaired, or speech impaired to meet the requirements for speaking the English language. By permitting the latitude for the administrator to modify or place limitations on an applicant's certificate, the door has been opened for otherwise well-qualified applicants to engage in careers in aviation maintenance. Further, this removes any language that could have been deemed discriminatory under the Americans with Disabilities Act of 1990.
AOPA does not specifically oppose the change of certificate name from Mechanic to Aviation Maintenance Technician, as we do not believe that the change provides any substantive benefit or harm. It does, however, pose a cost associated with changing every reference to an aircraft mechanic in every document, both in government and industry. For the most part, the change seems more bureaucratic than substantive, and there are no links made by the FAA to the enhancement of aviation safety. It is possible that the title change could impart a more professional image of aviation maintenance personnel to the non-flying public, as many seem to hope. For the record, however, nearly all commentary received from AOPA members who currently hold a FAA-issued mechanic certificate with airframe and powerplant ratings has been against the proposed name change. Nearly all have indicated that they like the reference to being a "mechanic" of the whole aircraft and do not like being associated with the image of a task-oriented bench "technician." To these people, the name change is having an opposite effect from that desired by its proponents. A look back in time shows aviation maintenance personnel titles moving from "engineer" to "mechanic" to "technician." Many aviation maintenance personnel do not view this as progress toward higher professional standing. Having said this, however, AOPA is neither in favor or opposed to the proposed name change.
§66.53 Ratings.
This section proposes to combine the existing airframe and powerplant ratings on a mechanic certificate into a single "aircraft" rating. While AOPA supports the notion of having a single "aircraft" rating for those maintenance personnel who meet the knowledge and experience requirements for both the airframe and powerplant segments of the certificate, we do not believe that the powerplant rating should be dropped entirely. By deleting the powerplant rating entirely, the FAA and industry are failing to recognize continued specialized knowledge of powerplant mechanics who repair, alter, maintain, and overhaul powerplants of all types, specifically in repair stations and other maintenance facilities. We understand and support the FAA's attempts to recognize the ever-increasing integration of structure, propulsion, and systems within aircraft and the desire to have the maintenance personnel qualifications mirror that change. However, we do not wish to throw the baby out with the bath water; i.e., delete those things that are serving the industry well, simply for the sake of change. AOPA urges the FAA to consider adding the aircraft and aviation maintenance instructor ratings to the AMT certificate while retaining a separate powerplant rating that has proven to be very useful and successful to the industry. In lieu of this, AOPA recommends that the FAA establish the powerplant rating as being eligible under the ARS-I.
§66.55 Aircraft rating: Knowledge requirements.
In our view, taking a knowledge test on the "relevant provisions of this chapter" is unnecessarily vague. We believe that the former references to Parts 91, 43, and any other regulatory references should be included in the body of this regulatory section and not left solely to advisory material for presentation.
§66.57 Aircraft rating: Experience requirements.
AOPA is opposed to the proposed change in the experience requirements from 30 months to 5,000 hours of practical experience. This change creates a significant administrative burden on applicants wishing to meet the experience requirements based on work experience due to the new requirement to document hours of work. Further, since there has never been a requirement to "log" experience time up to this point, there will be a period of years where few if any applicants will be able to meet or document the required experience. In addition, the proposed change makes it far more difficult, if not impossible, for general aviation aircraft owners or individuals who have spent years restoring aircraft to ever obtain a maintenance certificate.
To this point, the FAA and designated maintenance examiners have demonstrated flexibility and a reasoned approach to addressing the experience requirements for "non-traditional" applicants who do not work full-time in the aviation maintenance field. The FAA even has policies in place for adjusting experience times for individuals who are not engaged in full-time aviation employment. AOPA is not aware of any instance where this flexible approach has caused any safety problem. Yet, the proposal for 5,000 hours of practical experience will forever remove any flexibility for weighing quality of experience over quantity. AOPA is strongly opposed to the proposed change and points out that the administrative burden associated with documenting the hours of experience has not been addressed under this proposal.
§66.59 Aircraft rating: Competency requirements.
AOPA has no specific comment on this section.
§66.61 Certificated aviation maintenance technician school students.
AOPA supports the additional language in §66.61(b) that clearly defines the completion of an aviation maintenance technician school and passing of the knowledge tests required under this subpart as fulfilling all of the knowledge, experience, and competency requirements for the issuance of an AMT certificate.
§66.63 Aircraft rating: Privileges and limitations.
AOPA is opposed to the limitations placed upon the AMT outlined in §66.63(d) restricting work performed on Parts 25 or 29 aircraft by an AMT to preventive maintenance. This proposal has no basis in aviation safety as mechanics with the equivalent of AMT training and experience are conducting maintenance on transport category aircraft safely today.
The two-tiered certification approach proposed by the FAA is fraught with impracticalities that will significantly disrupt the aviation industry. For example, many general aviation maintenance shops are called upon either routinely or at least occasionally to conduct maintenance, inspection, or repair on Transport category aircraft. Should this proposed rule go into effect, there will be few if any maintenance facilities available to provide maintenance to operators of corporate turbine aircraft because they will be either unqualified under this section or will not meet the currency requirements on Part 25 and Part 29 aircraft despite holding an AMT(T) certificate. Corporate aviation in this country would be dramatically inconvenienced by this proposal for no benefit in safety.
Other examples of the complete impracticality of the two-tiered certification system include an examination of the regional air carriers. These Part 121 air carriers would be required to hire AMT(T) certificate holders to approve their aircraft for return to service. Yet, in a matter of months, these certificate holders would not meet the currency and recent experience requirements under this proposal because most of the aircraft in regional air carrier service are not type certificated under Part 25. Rather, they operate Commuter category aircraft that are type certificated under Part 23. After 24 months the air carrier would have no qualified personnel to approve aircraft for return to service.
For yet another example of the short-sighted nature of the two-tier proposal, one need only look to the major flag air carriers and their labor unions who proposed and supported the notion of a "Transport" maintenance certificate. This proposal was motivated by monetary interests and was not driven by any identifiable technical need or safety deficiency. It should be considered by all parties concerned that the vast majority of Transport category aircraft operating in air carrier service today were not type certificated under Part 25 or Part 29 at all. These aircraft were type certificated under CAR 4 or are derivatives of CAR 4 aircraft. The AMT(T) provide no measurable benefit and simply becomes an administrative stumbling block for many air carriers. In fact, under this proposal even some air carriers would be hard pressed to maintain the proposed recent experience requirements for AMT(T) under their employ. AOPA remains adamantly opposed to the addition of an AMT(T) certificate.
AOPA supports the addition of maintenance of a horizontal-card liquid-filled compass as a privilege for the AMT.
§66.65 Aircraft rating: recent experience requirements.
AOPA does not support the proposals for new recurrent training requirements under this section. Many years ago during the development of this notice by ARAC, it was stated that there was a need for regulated recurrent training to keep pace with the "rapidly changing" technology in the aviation maintenance field. Of particular concern at the time to the proponents of mandatory recurrent training were the air carrier and repair station maintenance personnel. It was strongly expressed in ARAC that maintenance personnel engaged in maintaining aircraft used under Part 91 operations were not the primary concern. AOPA finds it incredible then that virtually the only maintenance personnel who will be required to undergo the proposed additional recurrent training are maintenance personnel engaged in Part 91 activities. All other maintenance personnel, who arguably are engaged in the most "rapidly changing" environments of all, are exempt from the new recurrent training requirements due to existing training conducted under Parts 121, 135, and 145.
The justification used by certain interests within ARAC to support the need for recurrent training was that existing training under the operations specifications of Parts 121, 135, and 145 certificate holders was insufficient. Yet, now we have a costly and burdensome new requirement that will apply only to maintenance personnel working on Part 91 aircraft and who are most likely to have to pay for this mandatory training out of their own pockets. They are the lowest-paid employees in the maintenance profession and will likely have to take time off of work to accomplish the training. Neither the cost of the training nor the lost wages have been accounted for by the FAA under this proposal.
Training, either formal or informal, is a constant and ongoing process in the aviation maintenance profession. The aviation maintenance technician is one of the best-informed and well-trained professionals in the various technical specialties. This is evidenced by the very low incidence of maintenance-related accidents, incidents, or failures. AOPA is opposed to a new requirement for recurrent training on the basis that it is unnecessary, does not address a specific need, and is being accomplished on an informal basis every day by the maintenance profession.
AOPA is also concerned with the new sole reliance upon a requalification course for reinstating the privileges of those maintenance personnel who have not met the recent experience and recurrent training requirements of §66.65. We recognize that the requirement for recent experience is not in and of itself new. However, the limitation that only requalification training will be accepted for reestablishing currency is extremely burdensome and unjustified. There is no evidence that the longstanding practice of regaining currency while working for six months under supervision is not working. In fact, it is fundamentally the best way to bring a non-current maintenance certificate holder back into the fold. Working under supervision is far more complete and comprehensive than any course could ever be. AOPA is opposed to the sole reliance upon requalification training as a means for regaining currency, and the FAA has not quantified the cost to non-current maintenance personnel of this new requirement.
§66.67 Aviation maintenance instructor rating: Additional eligibility requirements.
AOPA opposes the requirement for a potential aviation maintenance instructor to "have been actively engaged in maintaining aircraft for at least the two-year period before the date of application." This proposal would preclude any maintenance manager, supervisor, retiree, or FAA inspector from becoming an aviation maintenance instructor. We feel that this criterion is far too restrictive and should be left to the discretion of the aviation maintenance schools.
§66.69 Aviation maintenance instructor rating: Instructional knowledge and proficiency.
AOPA has no specific comment on this section except to state that we feel this section is unnecessary on the basis that its specific contents are covered by inference in §66.67 and therefore are redundant.
§66.71 Aviation maintenance instructor rating: Privileges and limitations.
The aviation maintenance instructor is an employee of a certificated aviation maintenance school under Part 147. Under the Part 147 certificate, the school is responsible for its program of instruction and conformity to the requirements of Part 147. We do not view the proficiency of an aviation maintenance instructor as being a regulatory matter, but rather an employment issue between the instructor and the school.
§66.73 Aviation maintenance instructor rating: Recent experience requirements.
AOPA does not believe that it is necessary to impose new recent experience requirements on the instructor rating since the instructor is already required to maintain currency on the underlying aviation maintenance technician certificate under §66.65. We believe this places a dual burden on instructors, and particularly inactive instructors, who are actively performing maintenance on aircraft. We maintain that this section should be removed from the proposal entirely.
As previously stated, AOPA is strongly opposed to multiple levels of certification for aviation maintenance personnel. The proposal for an AMT(T) certificate implements numerous qualifications, recent experience, currency, and privilege restrictions that must be complied with or the certificate reverts to an AMT certificate. Yet the proposal does not delineate how an employer of maintenance personnel or a customer will know that an individual currently may exercise the privileges of an AMT(T) or an AMT. Critically, the proposal fails to identify what happens when an AMT(T) cannot meet the Transport category recent experience requirements and reverts back to an AMT. There is no readily identifiable designation on the certificate to demonstrate this to potential or current employers or customers. Even if there were, there is no requirement for an aviation maintenance technician to display their certificate or any other currency documentation to employers or customers.
AOPA urges the FAA to withdraw the proposal for the two-tiered certification system in its entirety. The owners and operators of aircraft and the entire maintenance community cannot afford to suffer the continual disruption this series of proposals will create.
§66.101 Eligibility requirements: General
AOPA supports the notion that the aviation maintenance training curriculum should reflect the current state of the art in the aviation industry and provide a sound basis for all aviation maintenance personnel regardless of what equipment they maintain. Further, we believe that the focus of the AMT(T) certificate is flawed in its very concept because it is founded on the notion that Transport category aircraft require a higher level of training due to their higher level of complexity. This may have been true 20 years ago, but today some general aviation aircraft are every bit as complex as Transport category aircraft. In fact, most new technology found in civil aircraft today originates in general aviation and corporate aircraft long before the air carriers implement it. Consequently, AOPA believes that if additional training is in fact justified by some identifiable deficiency in the existing training curricula, then it should be applied to all maintenance personnel.
Having said this, AOPA does not support the proposed requirement for an additional 573 hours of instruction for the AMT(T) certificate. This proposal was based on a job task analysis that was conducted many years ago prior to the update and revision of Part 147. Thus the need for 573 hours of training does not take into consideration the fact that more than half of the additional training identified as being required for the AMT(T) is already a part of the basic AMT training curriculum today. If there is still a need to require additional training above and beyond the current Part 147 curriculum then AOPA strongly urges that the specific maintenance topics be identified and added into the basic Part 147 training program for all future aircraft maintenance certificate applicants. There is positively no justification or need for creating an entirely new certification structure for aviation maintenance personnel when all that needs to be accomplished is an update to the training curriculum.
§66.103 Ratings.
This section proposes to combine the existing airframe and powerplant ratings on a mechanic certificate into a single "aircraft" rating. While AOPA supports the notion of having a single "aircraft" rating for those maintenance personnel who meet the knowledge and experience requirements for both the airframe and powerplant segments of the certificate, we do not believe that the powerplant rating should be dropped entirely. By deleting the powerplant rating entirely, the FAA and industry are failing to recognize continued specialized knowledge of powerplant mechanics who repair, alter, maintain, and overhaul powerplants of all types, specifically in repair stations and other maintenance facilities. We understand and support the FAA's attempts to recognize the ever-increasing integration of structure, propulsion, and systems within aircraft and the desire to have the maintenance personnel qualifications mirror that change. However, we do not wish to throw the baby out with the bath water; i.e., delete those things that are serving the industry well simply for the sake of change. AOPA urges the FAA to consider adding the aircraft and aviation maintenance instructor ratings to the AMT certificate while retaining a separate powerplant rating that has proven to be very useful and successful to the industry. In lieu of this, AOPA recommends that FAA establish powerplant criteria as being eligible under the new ARS-I.
§66.105 Transition to new certificates and ratings.
AOPA is disturbed by the fact that the FAA has justified the impact of a transition to the multi-tiered certification of mechanics by claiming that there will be no impact on existing certificate holders. Statements have been made that all current certificate holders will be grandfathered and that current airframe and powerplant ratings will retain the same privileges throughout and after the transition. This is true, but it is only half the truth in that many current mechanics would lose a significant portion of their hard-earned privileges within 24 months of the transition. Any airframe and powerplant mechanic who transitions to an AMT(T) and does not remain current on Transport category (specifically Part 25 or Part 29) aircraft will in fact lose a very large portion of the privileges they possessed prior to the implementation of this rule. These AMT(T)s who revert to AMT privileges will not just lose the privilege of approving Transport category aircraft for return to service only to regain it by working under the supervision of others for a time. Rather, they lose the privilege altogether and must engage in some form of requalification training of an undetermined scope, duration, and cost.
The FAA has not directly informed the aviation maintenance community of this taking of existing privileges. Neither has there been any attempt made to quantify the costs associated with the taking of these privileges, the loss of potential wages that would be earned during the six months an AMT would work on Transport category aircraft under the supervision of AMT(T)s, or the cost of obtaining requalification training. AOPA believes that it is unconscionable that this has not been brought to the attention of current certificate holders. For this and numerous other reasons outlined throughout these comments, we remain adamantly opposed to the two-tiered certification proposal.
AOPA is also concerned that the FAA is proposing to no longer recognize mechanic certificates with aircraft and aircraft engine (A&E) ratings. For some unexplained bureaucratic reason, any person holding an A&E mechanic certificate, must exchange it for and an airframe and powerplant (A&P) certificate in order to transition to an AMT(T) certificate. Any failure to accomplish this prior to the effective date of the rule would limit the transition of an A&E mechanic to an AMT certificate regardless of experience. This defies all logic. These maintenance professionals are potentially the most experienced certificate holders in the industry, demonstrating 40 years of mastery in their profession. Yet the FAA is prepared to relegate them to the minimal privileges of an AMT. AOPA must insist that whatever the outcome of this rulemaking activity, any A&E mechanic must be grandfathered in the same manner as an A&P mechanic. To do otherwise is to place the value of some minimal amount of schooling over and above decades of aviation maintenance experience.
§66.107 Aircraft rating: Additional eligibility requirements.
It is our belief that should the FAA prevail in implementing a two-tiered certification system in the face of widespread public opposition, there will be but one Part 147 curriculum and that will be for the AMT(T) including an additional 573 hours. No aviation maintenance training school would consider graduating students with only the proposed AMT certificate. The market would simply not exist to hire these individuals. Therefore this section can only apply to those applicants for an AMT(T) who are establishing their qualifications by practical experience. Under this section, any applicant for an AMT(T) based upon experience would be required to attend formal AMT(T) additional training regardless of the nature of their experience. Their experience may be military or even air carrier on transport aircraft, but under the proposal everyone would be required to attend 573 hours of AMT(T) schooling. AOPA opposes this provision on the basis that no benefit has been identified to justify the cost and that it simply mandates classroom time without regard to the experience or performance of the applicant.
§66.109 Aircraft rating: Privileges and limitations.
AOPA does not support a multi-tiered certification approach for aviation maintenance personnel and maintains that all maintenance technicians should posses the privileges and limitations outlined in this section. If training is believed to be inadequate for today's A&P mechanics and future technicians to retain the scope of their current privileges, then the training should be updated and possibly expanded. There is no justification for overhauling the entire aviation maintenance personnel certification system.
§66.111 Aircraft rating: Recent experience requirement.
AOPA will restate its opposition to the recent experience requirements for the AMT outlined in §66.65 as it applies equally to the AMT(T) certificate.
AOPA does not support the proposals for new recurrent training requirements under this section. Many years ago during the development of this notice by ARAC, it was stated that there was a need for regulated recurrent training to keep pace with the "rapidly changing" technology in the aviation maintenance field. Of particular concern at the time to the proponents of mandatory recurrent training were the air carrier and repair station maintenance personnel. It was strongly expressed in ARAC that maintenance personnel engaged in maintaining aircraft used under Part 91 operations were not the primary concern. AOPA finds it incredible then that virtually the only maintenance personnel who will be required to undergo the proposed additional recurrent training are maintenance personnel engaged in Part 91 activities. All other maintenance personnel, who arguably are engaged in the most "rapidly changing" environments of all, are exempt from the recurrent training requirements due to existing training conducted under Parts 121, 135, and 145.
The justification used by certain interests within ARAC to support the need for recurrent training was that existing training under the operations specifications of Parts 121, 135, and 145 certificate holders was insufficient. Yet, now we have a costly and burdensome new requirement that will apply only to maintenance personnel working on Part 91 aircraft and who are most likely to have to pay for this mandatory training out of their own pockets. These are the lowest-paid employees in the maintenance profession and will likely have to take time off of work to accomplish the training. Neither the cost of the training nor the lost wages have been accounted for by the FAA under this proposal.
Training, either formal or informal, is a constant and ongoing process in the aviation maintenance profession. The aviation maintenance technician is one of the best-informed and well-trained professionals in the technical specialties. This has been evidenced by the very low incidence of maintenance-related accidents, incidents, or failures. AOPA is opposed to a new requirement for recurrent training on the basis that it is unnecessary, does not address a specific need, and is already being accomplished on an ongoing basis every day by the aviation maintenance profession.
AOPA is also concerned with the new sole reliance upon a requalification course for reinstating the privileges of those maintenance personnel who have not met the recent experience and recurrent training requirements of §66.111. We recognize that the requirement for recent experience is not in and of itself new. However, the limitation that only requalification training will be accepted for reestablishing currency is extremely burdensome and unjustified. There is no evidence that the longstanding practice of regaining currency while working for six months under supervision is not working. In fact, working under supervision is fundamentally the best way to bring a non-current maintenance certificate holder back into the fold. It is far more complete and comprehensive than any classroom course could ever be. AOPA is opposed to the sole reliance upon requalification training as a means for regaining currency, and the FAA has not quantified the cost to non-current maintenance personnel of this new requirement.
§66.113 Aviation maintenance instructor rating: Additional eligibility requirements.
AOPA is equally opposed to a two-tiered instructor rating as it is to the proposed two-tiered technician certification system. There is no indication in the proposal as to when a course of maintenance instruction is considered an AMT(T) course for meeting the recent experience requirements of §66.111. Nearly all of the training conducted under Part 147 is applicable to both the AMT and AMT(T) certificates, and the instruction is geared toward specific tasks, skills, or technologies. Instruction is not predicated upon the type certification basis of aircraft. AOPA maintains that there should be one level of training, one level of maintenance certificate, and one level of aviation maintenance instructor.
§66.115 Aviation maintenance instructor rating: Privileges and limitations.
Please see our comments to §66.113.
§66.117 Aviation maintenance instructor rating: Recent experience requirements.
Part 147 training is designed to provide a broad base of knowledge, skills, and exposure to technologies found in the field. The training does not distinguish between Part 25 technology and practices and those found and used on all other aircraft. The type certification basis of the aircraft is irrelevant to aviation maintenance instruction and curricula. Again, AOPA maintains that there should be one level of training, one level of maintenance certificate, and one level of aviation maintenance instructor.
§66.119 Aviation maintenance technician (transport) training providers.
This section imposes a significant new burden on certificate holders under Part 121, Part 135, and Part 145. These organizations will be required to submit proposals and request approval showing that their training programs meet the AMT(T) initial and recurrent training requirements of paragraph (d) of Appendix A to Part 66. This will effectively require that all of the required maintenance training under Parts 121, 135, and 145 will be required to be approved a second time by a different FAA office than originally approved their operations manuals in the first place. The FAA has not addressed the costs and administrative burdens associated with this initial and proposed recurring biannual approval requirement. AOPA maintains that any maintenance training that has been approved for Parts 121, 135, and 145 certificate holders be approved for both initial and recurrent training for all aviation maintenance personnel.
AOPA is opposed to a multi-tiered Inspection Authorization (IA) certification system in the same manner as we are opposed to multiple levels of maintenance technicians and aviation maintenance instructors. AOPA maintains that there should be one IA who is qualified to approve for return to service maintenance, inspections, repairs, and alterations on aircraft regardless of certification basis. This has worked effectively for decades, and AOPA is unaware of any justification for change other than to be consistent with the misguided two-tiered maintenance technician proposal.
§66.151 Eligibility requirements: General.
Apart from any references to the AMT(T) certificate to which we are opposed, AOPA has no specific comment on this section as it remains largely unchanged from the current Part 65.
§66.153 Duration of authorization.
AOPA strongly supports the proposed increase in the duration of an inspection authorization from 12 to 24 months. Additionally, we support the proposal that the authorization would expire 24 months after the date of issuance rather than having all IAs expire on March 31 of each year. This single proposal is perhaps the most positive and beneficial item in the entire notice and should be acted upon regardless of the disposition of the entire rulemaking.
§66.155 Renewal of authorization.
Generally, AOPA supports this section however; we are adamantly opposed to the reference in paragraph (b) of this section to removal of the restrictions for Part 25 and Part 29 aircraft outlined in §66.157(b). As stated repeatedly, AOPA is opposed to any multi-tiered maintenance personnel certification system.
§66.157 Privileges and limitations.
Apart from any references to the AMT(T) certificate to which we are opposed, AOPA has no specific comment on this section as it remains largely unchanged from the current Part 65.
§66.201 Aviation repair specialist certificates issued on the basis of proficiency in a designated specialty area (ARS-I): Eligibility.
AOPA supports the proposal to certificate individuals based upon their proficiency in a specialized task independent of their current employment. While we recognize that a Part 121, 135, or 145 certificate holder would predicate exercise of the privileges of an ARS-I certificate on employment, the portable nature of the certificate will be a significant improvement for the individual repair specialist. Further, we believe that development of this "portable" repair specialist certificate has the potential to increase the number and availability of individuals who posses these desperately needed specialty skills for this industry.
§66.203 Aviation repair specialist certificates issued on the basis of employment (ARS-II): Eligibility.
Proposed §66.203(f)(1) changes the practical experience requirement from 30 months to 3,000 hours. AOPA maintains that current employment records lend themselves to the documentation or substantiation of 30 months of active aircraft maintenance experience. However, there are no current labor requirements for documenting hours of practical experience, and we feel that employers could be significantly burdened by the administrative task of trying to generate or substantiate such documentation. The existing system has worked well, and we see no justification for change. AOPA urges the FAA to retain the existing experience requirements of §65.101 for the ARS-II.
§66.205 Aviation repair specialist certificates issued to experimental aircraft builders (ARS-III): Eligibility.
AOPA strongly supports the development of this separate repair specialist certificate for the builders of experimental amateur-built aircraft.
§66.207 Transition to new certificates.
AOPA has no specific comment on this section.
§66.209 Aviation repair specialists issued on the basis of proficiency in a designated specialty area (ARS-I): Privileges and limitations.
AOPA supports the development of the ARS-I certificate and agrees with the scope of the proposed privileges and limitations.
§66.211 Aviation repair specialist certificates issued on the basis of employment (ARS-II): Privileges and limitations.
AOPA has no specific comment on this section.
§66.213 Aviation repair specialist certificates issued to experimental aircraft builders (ARS-III): Privileges and limitations.
AOPA strongly supports the development of this separate repair specialist certificate for the builders of experimental amateur-built aircraft and agrees with the scope of the proposed privileges and limitations.
§66.215 Aviation repair specialist certificates issued on the basis of proficiency in a designated specialty area (ARS-I): Recent experience requirement.
AOPA has no specific comment to this section.
AOPA does not believe that the AMT(T) curriculum outlined in Appendix A belongs in Part 66 at all. Rather it or some similar updated curriculum should be included in the aviation maintenance training curriculum of Part 147 for all future maintenance technicians. AOPA remains adamantly opposed to any multiple level certification process and is greatly concerned with the potential for disruption, confusion, and burden such a system would impose on the entire aviation industry. AOPA urges the FAA to reconsider its position and determine whether the current curriculum for aviation maintenance training, combined with the various experience requirements, is adequate for the conduct of maintenance on all aircraft regardless of certification basis. If it is not, then the curriculum should be updated for all maintenance personnel to meet the current challenges of advancing technology.
Overall, AOPA maintains the this rulemaking proposal far exceeds what is necessary to bring the certification of maintenance personnel up to date with current technology and industry practices and, in do doing, creates numerous potential problems for compliance, oversight, and management. We urge the FAA to withdraw this proposal and reconsider the actual needs and requirements of the aviation maintenance community and the industry it supports. The current proposal is far from accomplishing that. AOPA maintains that all that is required are a few minor changes to the certification procedures as outlined in our section-by-section analysis above and an update to the aviation maintenance training curriculum.
We appreciate the opportunity to comment on this proposal and stand ready to assist the FAA in reviewing and updating the training curriculum as necessary.
Douglas C. Macnair
Regulatory and Certification Policy
January 7, 1999


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Dear readers,
I have been trying to decide what I want this site to be, and I think I have figured it out. Using Farnam Street and Barking Up the Wrong Tree as my mentor blogs, I am going to dedicate my time to reading books/research on education and creating posts that follow the same format as the previously mentioned blogs, surmizes, opinions, mixed with big ideas from the readings. We shall see how it goes.
Most sincerely,
Benjamin J. E. Light


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- - 1 fennel bulb, thinly sliced through the root, green fronds reserved- 1 heaped tbsp roughly chopped dill
- Zest and juice ½ lemon , plus wedges, to serve- 1 tbsp olive oil
- 4 small slices rustic wholemeal bread, or two large cut in half
- 1 garlic clove, halved
- 140g cooked prawns- Handful rocket
- 1. Bring a pan of water to the boil then add the fennel slices for 2-3 mins until just tender. Drain well and toss with reserved fennel fronds, dill, lemon zest and juice, 2 tsp olive oil and seasoning.
2. Brush the slices of bread with remaining oil. Place in a hot griddle pan (or under a grill) and toast on both sides until lightly charred. Rub one side of each slice with the garlic, then divide the fennel salad between them. Top with the prawns, then the rocket and serve.
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- - 1 fennel bulb, thinly sliced through the root, green fronds reserved- 1 heaped tbsp roughly chopped dill
How To: Prawn Bruschetta
4 comments
This sounds amazing and one I can eat! I'm not a great fan of fennel but I'm sure this will taste just as lovely without it xReplyDeleteReplies
Haha yay finally! First time trying Fennel, it's not too bad but it would defo taste just as good without it!Delete
Thank you for reading and commenting☺💓
Omg what a good idea!! I love bruschetta but have never tried a prawn one!! This looks delicious and I'm not big on seafood!ReplyDeleteReplies
Oh but it's so good! Try it if you can!Delete
Thanks for reading and commenting☺💓
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Welcome to Tellen's Place's FIRST blog hop to celebrate the release of her new digital images. You've already met Edward, Ally, Jessica and some of their friends, so now you'll meet some more fabulous characters like Sylvia, Fiona & Quinn, Phoebe, Lexi & Hailey, Zoey and a few other little fun folks that have been added to Tellen Designs.
This hop will also unveil her new website: http://www.tellensplacedesigns.com/. You will find new products there – every crafter's dream: kits! If you are new to crafting or can't find the time to craft, these card kits will help you make that decision so you'll be able to give your handmade cards to your friends. Have you ever wanted to make a mini album but didn't have time? Well, that's where you'll find kits for a mini album. No more cutting out all of those tags, trying to figure out what papers to use, wondering if you should use paper bags, chipboard, or envelopes – who has the time? Well, no more worrying – you can visit http://www.tellensplacedesigns.com/ and pick up your kit today!
Here is My card I designed for the hop Please remeber to leave a comment to make sure your entered into a draw.
If you came here from Heather's Blog http://joemamainks.blogspot.com/ , then you are in the right place. If not, you should start back at the beginning at Michelle's blog so you don't miss out on anything.
All you need to do is leave a comment on each blog and you will be in a drawing for a prize. I will pick the winner of my blog on Tuesday (2/3). In fact, you will have a chance at a prize on each blog you visit and leave a comment! How cool is that? Don't forget to check back on Wednesday (2/4) at Tellen's Place to see if and what you've won! She'll have the prizes posted on her blog. I'll tell you a little secret…shhhh…she's going to be giving away some of those card kits and mini albums…so you won't want to miss this!
Thanks for stopping by and joining in on our blog hop! Your next stop is Joyce's Blog http://joynana-lovethatpaper.blogspot.com/


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KANDAHAR, Afghanistan (CP) - Canada's outgoing military commander in Afghanistan says Canadian and NATO efforts there have helped save the lives of 40,000 children.
And Brig.-Gen. Tim Grant says that's a "conservative estimate."
In an interview with The Canadian Press at the multinational base in Kandahar, Grant said he's handing his successor, Brig.-Gen. Guy Laroche, a country more "confident" than it was a year ago.
"There's 40,000 babies in Afghanistan more this year than . . . last year," said Grant, whose return to Canada is days away. "That's a big number."
He attributes the success to improvements in health care, which has led to a drop in the region's infant mortality rate.
Grant says the international community helped put a vaccination program in place and increased access to doctors, particularly for women.
Meanwhile, even as Taliban activity remains prevalent in Kandahar province, the level of confidence has surged among the city's inhabitants, he said.
"The town was empty," Grant said of Kandahar 12 months ago. "Now you go there, (it's) like Kandahar City is a successful little town.
"The shops are open, kids going to school, people have gone back to a normal life. We see farmers have returned in large numbers, thousands of people have gone back to live in their homes."
Grant appears to be using numbers from a World Bank study but Save the Children isn't quite that optimistic:
* The average Afghan household's monthly income is $6.
* Child and maternal malnutrition remains pervasive because many families do not understand basic good nutrition and unfortunately, poverty prevents the ones that do from providing healthy meals to their children and women of childbearing age.
* There is limited access to quality health care throughout the country. For every 1,000 Afghan children born, 165 die within the first year, and one quarter of all Afghan children die before their fifth birthdays – the vast majority from preventable diseases.
* Women have little access to reproductive health services; the maternal mortality rate for Afghan women is one of the world's worst.
* Access to quality education is limited, especially in rural areas. Although an estimated 6 million children are enrolled in school, attendance is uneven and drop out rates are high. Many millions of children are not enrolled in school at all.
* Although landmine education programs have been very successful in helping prevent disability, maiming and death, Afghanistan is still one of the world's most heavily mined countries.
And here's the latest reality check via UNICEF:
The United Nations Children's Fund is urgently appealing for $7 million for emergency assistance for tens of thousands of women and children in Afghanistan. UNICEF says a combination of insecurity, natural and man-made-disasters is putting many of Afghanistan's most vulnerable people at risk. Lisa Schlein reports for VOA from Geneva.
No time is a particularly good time for the people of Afghanistan. But, over the past six months, they have been going through a particularly difficult period.
The year started with a large number of early and unexpected flash floods that forced many people to leave their homes. The country continued to reel from other natural and man-made disasters such as heavy snowfalls, landslides, disease and, of course, armed conflict.
The U.N. Children's Fund reports the security situation in the country is deteriorating. It notes that fighting between the Taleban and Government and Coalition forces is spreading to more areas. It says civilians on both sides are victims of armed conflict. Thousands have been made homeless.
UNICEF Spokeswoman, Miranda Eeles, says as of May, about 41 percent of Afghanistan's districts have become no-go areas for the United Nations and this is hampering the delivery of aid.
"There are more than one-point-three million Afghan refugees living in Iran and a lot of those are being deported back to the country," Eeles said. "We also see an increase in school incidents and threats against students. We have pretty bad results when it comes to things like infant mortality rates. One child out of every four does not survive his or her fifth birthday. So, in general, it is not only the security situation, it is a whole host of problems that the country is experiencing."
UNICEF reports seven percent of children under five suffer from acute malnutrition and 54 percent are chronically malnourished.
Eeles says two million children of primary school age are out of school. About 1.3 million of them are girls. She says parents are fearful of sending their children to school because of the many threats made against students and teachers. Girls have been especially targeted by the Taleban which believes girls should not have an education and that they should be at home.
"Thirty one attacks have been reported against schools in the first six months," Eeles said. "We have had schools being torched. There are also explosions and there have also been deliberate attacks on girl students and women teachers. This has resulted in at least four deaths and six injuries. In the four southern provinces of Helmand, Kandahar, Uruzgan and Zabul, out of a total of 740 schools, it is estimated that around 262 of them are no longer providing education services to students."
The moral of this story: Always look beyond the sound bite numbers trotted out by military and government spokespeople from war zones.


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Last night, we were getting our little girl ready for bed when hubby turned to me and said, "If I was still in the church, she would be learning to pray right about now." WTF? She's not even two yet!
The idea of teaching P to get down on her knees and recite some silly poem to the heavens, all in an effort to ingratiate herself to a brutal and inconsistent father in heaven (when she has a wonderful father right here on earth) is infuriating to me.
I have heard the argument made that teaching your kids to be atheist is no different than teaching them to have faith. You are indoctrinating them, either way. This is something I have struggled with because while I want P to think critically and rationally, I don't want to force her to be a non-believer. I can say though, that I have never sat her down and told her anything about religion. Do you know why? Because she's a baby! The idea that you would intentionally set out to introduce a supernatural being into a child's reality before they have the skills or development to question it is sick and twisted. It's taking advantage of a primed and vulnerable mind and it's no wonder it is so difficult and painful for adults to leave the church when their faith is so deeply rooted in their infant brain.
I remember reading my hubby's baby book not too long ago and feeling physically ill when I read this message from my MIL: "Brian received a gift of one dollar today and when I asked him what he was going to spend it on he told me he was going to save it for his mission, – Age 2"
Holy fuck.


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Among those testifying in favor of the measure was Houma-Thibodaux's Catholic bishop, Shelton Fabre
BATON ROUGE -- Legislation that would abolish the death penalty in Louisiana is advancing to the Senate for consideration.
Senate Bill 51, sponsored by New Orleans Democrat Sen. J.P. Morrell, passed out of the Senate Judiciary C Committee on a 4-1 vote today.
"Life in prison without possibility of parole is in itself a death sentence," Morrell said.
The move comes a day after the Louisiana Supreme Court ruled Allen Robertson Jr. is not intellectually disabled and is to remain on death row. The Baton Rouge man known as "Lil Boo" was sentenced to die in 1995 for stabbing an elderly couple to death 27 years ago.
East Baton Rouge Parish District Attorney Hillar Moore III supported the court's decision.
The U.S. Supreme Court ruled in 2002 that intellectually disabled defendants cannot be executed.
Louisiana allows the possibility of a death sentence for those convicted of first-degree murder, as well as in cases of first-degree rape of victims under the age of 13. A death sentence is mandatory for the crime of treason. Louisiana is one of 31 states in the U.S. to allow the death penalty.
Morrell said in the hearing that it's becoming increasingly hard and expensive to carry out the death penalty.
Sen. Dan Claitor, R-Baton Rouge, raised concern about the cost of sentencing criminals to life sentences instead of to death, but Morrell said the state could face millions if convicts are wrongfully killed.
Houma-Thibodaux Bishop Shelton J. Fabre testified on behalf of the Louisiana Conference of Catholic Bishops as a "pastor of souls." He said the death penalty perpetuates the cycle of violence and a "culture of death," and said he felt the bill was crucial to promoting a "culture of life" in Louisiana.
"The Catholic Church considers the death penalty an offense against the sanctity of life," Fabre said. "Therefore, the use of the death penalty is unnecessary and unjustified in our time."
Sen. Mack "Bodi" White, R-Baton Rouge, the only vote against SB51, said he didn't believe the measure would curb violent crimes.
A bill to end the death penalty in the House was killed last year.
If approved by the full Senate, the bill would head to the House for consideration. The bill would apply to crimes committed after Aug. 1.
How they voted:
For: Regina Barrow, D-Baton Rouge; Dan Claitor, R-Baton Rouge; Fred Mills, R-Parks; and Troy Carter, D-New Orleans.
Against: Bodi White, R-Central.


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Content warning: This story contains descriptions of graphic violence.
A Saskatoon family is airing their frustrations with the justice system four years after a little boy survived a gruesome stabbing committed by his mother.
The boy, his father and his older brother spoke with Gormley Thursday. A court order protecting the identity of the victim prevents any of their names from being published.
Details of the March 2013 events came out during a sentencing hearing at Saskatoon Court of Queen's Bench in April 2016.
The boys were staying at their mothers' home. Their father came to pick the boys up and found their mother in an agitated state. She forbade him to enter the home and locked the door. He eventually called police.
Meanwhile, inside the house, the mother had taken her youngest son, then six years old, into the bathroom where she used a knife described as being between 30 and 36 centimetres long to stab him several times in the abdomen and cut him across the throat.
She then turned the blade on herself, slashing her wrists and stabbing herself several times in the stomach.
The boy's older brother, then 11 years old, unlocked the front door for police. The boy and his mother were both taken to hospital. The mother was eventually charged with attempted murder.
In an interview with Gormley aired Thursday, the boy's father said he felt the system first let his family down when a judge decided to grant the woman bail. From there, the case dragged on as the woman and her lawyer filed numerous motions requiring the Crown to respond.
"The judge made the decision and so, her dad posted the bond, and then she was allowed to remain out of prison for basically three-and-a-half years before all this got sorted out," he said.
Both boys and their father said they lived in constant worry while the woman was on bail.
The boys' father said it got worse when the woman's parents split up, requiring her and her dad to move.
That's when he said he got a call from a Crown prosecutor informing him they'd chosen a residence just five blocks from where the boys were living.
"This was the first real eye-opener for how unprepared our justice system is to deal with this stuff," he said.
Ultimately, the woman was allowed to live at the new address.
The boy's father said he then learned the conditions of her house arrest weren't what he'd thought. He said this came after a friend saw the woman out shopping, prompting him to file a police report.
"It was finally explained to myself and my family that she actually has … in excess of 10 hours a week of various personal things she was allowed to do," he said, adding this time was in addition to any appointment she might make for things such as doctor's visits or meetings with her lawyer.
He said he also wasn't told when the woman had her electronic monitoring anklet removed and was never informed the anklet didn't provide authorities with her exact location, but only informed them if she left her residence.
The lengthy wait for a sentence came to an end when the woman pleaded guilty to a lesser charge of aggravated assault.
But again, they boy's father said the system failed to account for victims' rights to feel safe.
Originally set to be sentenced in March 2016, the woman applied for, and was granted, a delay in order to attend her grandmother's 95th birthday celebration.
The boy's father said the decision left him shocked and inflicted more suffering on himself and his sons.
"She was actually allowed out for an additional 40-some days. Under house arrest. After she had pled guilty to aggravated assault on a six-year-old child. To attend a birthday party. Another in a long line of the system letting us down. Of the system not caring for the victims," he said.
The woman is now about 18 months into her sentence. The boy's father said he since learned she was transferred to a minimum security healing lodge, despite being Caucasian with no known Indigenous ancestry.
Since then, the boy's father said he learned the woman had applied for, and been granted, a transfer to another minimum-security facility in Edmonton.
Ultimately, the boy's father said his biggest concern was with the way the justice system handles mental health.
Following her arrest, a pair of psychiatrists found the woman fit to face a criminal trial. However, the doctors' reports noted she suffered from depression, anxiety and post-traumatic stress disorder. The doctors also said it was likely she'd been left with a brain injury after being struck by a drunk driver some years before the stabbing.
Prior to agreeing to her plea to the charge of aggravated assault, the Crown noted the woman's mental health issues left significant doubt about securing a conviction to the original charge of attempted murder.
Despite all this, the boy's father said that, to his knowledge, the woman has never undergone a full psychiatric assessment of the kind that could have seen her committed to a mental health facility.
"Unless you are serving a life sentence. they can't force a full-blown psych assessment," he said, adding he didn't feel sending her to a regular prison was the way to protect him and his sons, as she will be entitled to statutory release after two-thirds of her sentence.
"It felt like it was the easy way out for her and the system just opened the door and said, 'Here you go.' Five-and-a-half years in prison, which actually isn't five-and-a-half years,' and then she gets out. No one is bothering to look at the mental health side of this," he said.
He said this leaves him concerned about what will happen when the woman gets out and has made it difficult for him, his sons and his new partner to plan their futures.
"It's clear, clearer than crystal clear can be, that there are mental health issues. She needs to be assessed. Because there will come a point where she's released, and the system has nothing to say about what she does, where she goes, how she does it," he said.
Both boys, now 10 and 15, told Gormley they have no desire to have any further contact with their mother, but said they feared she would try to make contact, describing her as "relentless."
Their father said he's also concerned, and hasn't found the police response to his worries to be of any comfort.
"The line that the police keeps giving us is, 'Call us if something goes wrong.' Does someone actually have to be bleeding, if she's on the front lawn and she's not supposed to be there, because we have a restraining order — is that enough?
The system has let us down so many times, I don't feel like we're protected by the system. They're certainly not doing their job with her in the institution, when she gets out, who knows?"
— With files from 650 CKOM's Bryn Levy.


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Munawwar Hassan urges government and Taliban to declare ceasefire
MANSOORA: Chief of Jamaat-e-Islami (JI) Syed Munawwar Hassan has expressed hope that Pakistan Army and government would agree to halt military operation in tribal areas and Taliban will stop any further actions, ARY News reported.
While addressing to the participants of Seminary in Mansoora on Sunday, Syed Munawwar Hassan said that neither anyone succeeded in changing the Islamic identity of Pakistan in past nor anyone will be able to do so.
Chief of Jamaat-e-Islami anarchist elements will not miss any chance to sabotage the negotiations process with Taliban; therefore government should not blame Taliban for every act of terrorism.
Munawwar Hassan advised Taliban and government to realize the sensitivity of the situation and keep confidence among each other.
He asked both the parties to announce ceasefire at earliest as whole Muslim world along with Pakistani nation are keeping eye on peace talks.


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text: Atkins Rahman ( Thakrit undergrowth date ) as the new chief ranger led police patrol . Ordination ceremony into the wild cliffs of the village of Mist . Atkins stated that the home invasion conserved. Would have been arrested and everyone was frightened with only the stars ( sweetly divine royal palm ) plantation owners the stars who dared argue that locals do eat here before officially be declared a sanctuary. Atkins insisted that he had done everything according to the law. They argue even before it is closed. It fires up the village. After the fire burn down the stars found evidence of arson. The stars are firmly convinced that the forest fire burned the villagers .


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Why European countries are scrapping diesel cars
New measures are being introduced across Europe to combat the use of diesel cars in their cities.
Whilst diesel cars are known for their fuel efficiency, they also produce harmful emissions. This is why many European countries are now introducing a number of regulations on diesel cars, including fees for driving in capital cities and hefty fines for car makers found to be cheating on emissions tests.
Learn more about how diesel cars harm the environment and what Europe is doing to tackle it here.
Photo courtesy of MIT Tech Review
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We keep hearing about strong, confident readers who have failed the government's new Year 1 phonic screener. Is it that our six year olds haven't mastered the art of reading readiness (the point at which a person is ready to learn to read) or is the government assessing the wrong skill?
The first thing to say is that parents shouldn't be getting panicked by these results. It's important to remember that the screener isn't a reading test; it is a measure of how well children can decode words using synthetic phonics.
This synthetic phonics system of learning to read is relatively new. The initiative started in Clackmannanshire, Scotland about 15 years ago and has only been used nationwide for around five years and therefore is an unknown approach to most parents of school age children. Don't get me wrong, this is a fantastic tool for our children to master and I see the results of this on a daily basis. All reception age children attending Explore Learning centres work on phonics and this is the best platform for launching into reading. It gives them the confidence very early on to read phonetically spelled words. This is, however, one of many skills that children need to use when reading the English language.
Once a child has learnt this 'Basic Code' of synthetic phonics, they also need to learn the 'tricky' words that don't fit (of which there are many!) For this, children use their visual memory and also start to look out for context clues. For children that have moved beyond the stage of just reading phonetically and are tackling tricky words I believe the new government test can be particularly challenging. The nonsense words appear odd and children may try and make a 'real' word out of them thus pronouncing them incorrectly. Ironically those that move quickly ahead in the system could fail to measure up to the new test.
So if a child has 'failed' to decode a number of nonsense words, should the school and in turn the child, get a black mark against them? What is the end result we are looking to achieve? Surely it's for children to be able to read confidently and with understanding.
The synthetic phonics system helps with the first steps of reading and spelling. Our children then need to spend time reading with understanding, building a wider vocabulary. If a child can do this then is it right that they should have to re-sit the test the following year? And what about children who have learnt to read before starting school? Should they go back and revisit the code simply for a test rather than progressing in their reading development? Are we going to find that parents and the school prioritise practising a skill that the child should really be moving on from?
The phonics screener is relevant but it needs to be measured alongside a more traditional reading assessment to ensure that our children, those that are reading well already, are not unnecessarily held back on a skill that gives them limited use in the English language. I would argue that for children already reading before they start school that the screener needs to happen sooner, not later. Able readers could sit the screener at the end of reception instead whilst they are still relying on their phonic knowledge for decoding in reading. Then they should move on. After all, unlike Finnish which has one of the most phonetic writing systems, English is definitely not a phonetic language.
A language that is phonetic means that you can look at the written word and know how to pronounce it or you can hear a word and know how to spell it. The English language is over 1000 years old and has the wrinkles to prove it! It doesn't follow a set pattern and is focusing too much on the phonetic code alone, then children will find this wonderful language a challenge. Some things we just have to learn using our knowledge and understanding of context. So let's make sure the balance is right - otherwise how else would we know how to say though, through, cough, rough, plough, ought, borough?!


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Direction Island
Longing to escape to a deserted island? On Direction Island, seclusion is guaranteed since the only structure on the island is a beach cabin which sleeps six. Totally self-sufficient and only accessible by private vessel or charter boat, the island doesn't even have a jetty. There won't be a soul in sight except for your travelling companions. This truly is for the adventurous, and with your own private beaches and coral reef to explore, the snorkelling, diving and fishing opportunities are sensational. Don't forget to bring all your own linen and food, unless you're planning on catching it.
Contact information
Direction Island; (08) 9184 6444


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I have made changes to the RSS feed for this site.
The main change is the ability to read the entire entry from the feed itself (full post) instead of excerpts. It will still show the last 10 entries but will have the posts in their entirety.
I have also added CDATA to the feed, so it will be slightly formatted (paragraphs, images, etc.).
Just some slight improvements to help the folks who visit the site through a feed-reader.


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How to adding your favorite image to a folder?
Dear friends here I have a very useful and interesting tip for you. Sometimes you have to face some problem to distinguish the folders because in standard configuration of window explorer each folder seems closely the similar to others.
If you want to explore your folder in windows explorer's thumbnail view and make these folders are prominent then it is easier to distinguish using text name, for example you're download audio files or digital photos. But if you want to add image to a folder to distinguish with others then you should choose that folder which you want to decorate.
First go to any folder you want to customize then right click within that folder and select "customize This Folder" then Select Customize tab and click on "Choose Picture" button to add favorite image.
The image which you want to use navigates to that image and then clicks "Open" to view a sample of the picture inside the folder icon. Click on Ok button, if you are satisfied from that image .If you are not satisfied then choose another image.
Now at the end, go to View menu to display the folder in Explorer's thumbnail with image.


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Your kitchen is a place where you create some of the most amazing meals for friends and your loved ones. You take pride in being able to do what you do on a regular basis, which is why you also care about how clean the area is as a whole.
Many people take the time to wipe down their stove, counter tops, kitchen table, fridge and other structures, but they often overlook their kitchen cabinets. For many people, they don't see the point in wiping down their kitchen cabinets. Even though you might not think it matters, it does.
How many times have you heard the phrase that not all products are created equal? Just because a product is meant to clean and polish your wood, that doesn't mean it is the right product for you to use.
You want something that is going to get the job done, but you also want something that isn't going to throw a bunch of chemicals in the air for you to have to breathe day in and day out. Quality products are important for your health and your home, which is why many people are turning to beeswax as a solution to end all of their worries.
For those who have wood in their homes, protecting it is of the utmost importance. You don't want to have wood that is chipping, peeling or flaking apart. You want to make sure it looks as brilliant today as the day you brought it home from the store.
One of the worst things you can do when caring for your wood is to use a product that isn't intended for it. You can actually do more damage than what you might think when you use products that aren't made for wood. Enlisting the proper wood cleaning and restoration and protection products can go a long way in caring for your item.
For those who have wood in their homes, protecting it is of the utmost importance. You don't want to have wood that is chipping, peeling or flaking apart. You want to make sure it looks as brilliant today as the day you brought it home from the store.
One of the worst things you can do when caring for your wood is to use a product that isn't intended for it. You can actually do more damage than what you might think when you use products that aren't made for wood. Enlisting the proper wood cleaning and restoration and protection products can go a long way in caring for your item.
Cleaning wood floors involves more than just wiping the floors with some water and a mop. You need a specialized product that was designed for cleaning wood. When you use a product that cuts through all of the contaminants and bacteria on your floor, you can put your mind at ease that everything is safe and secure for your child.
Being able to relax in the fact that you used a product that actually did what it was supposed to is one of the best feelings in the world as a parent. Take the time to look into one of the best cleaning products in the industry today and experience the difference in your home.
Rust stains can be one of the most difficult stains to remove because of the multiple oxide particles contained in the stain. Some treatments can actually make the stain worse than what it was. You end up setting the stain in instead of removing it.
If you use a little modern know-how and elbow grease, you can get rid of the stain and restore your surface back to its original luster. A rust stain remover can go a long way in getting rid of the stain, but you have to use the right product to get the job done.
The problem that people run into in the bathroom are those nasty water spots that buildup on shower doors and faucets. Since 85% of the country experiences hard water problems, this is almost a problem that is unavoidable. Finding the right cleaning product that is recommended by cleaning professionals and even Handyman Magazine.
Check out this article written by the Las Vegas Review Journal and see what they had to say about the effectiveness of the Bring It On Cleaner. Use this product to clean shower doors, windows, tile and grout, tubs, sinks, faucets and drains, stone and brick, and so many more uses.
Touch of Oranges Wood Cleaner and Re-conditioner is a moisturizing cleaner made with orange oil. Protects against drying and cracking and contains no silicone or wax which can cause buildup. It hides minor scratches on wood, is gentle on hands and has a pleasant orange fragrance. Use for dusting all wood surfaces.
Follow up with Touch of Beeswax Wood Preserver, this product restores and renews all types of wood finishes with beeswax, Carnauba wax and orange oil. Beeswax
What type of flooring do you have in your home? Are you worried about whether you are actually cleaning the surface of your floor? Do you have people in the home with allergies and asthma? You might not be aware that your wood floors can harbor any number of different contaminants and pollutants. Failing to clean the floor properly is only going to leave the grime, residue, dirt, dust and debris behind. If you are going to clean your wood floors, you want to make sure you are spending your time wisely.
Grabbing a bucket of water and a mop isn't going to get the job done. All you are going to do is spread the
The problem that many homeowners have in the bathroom and kitchen is the amount of mineral spots and stains that accumulate on shower doors, faucets and windows. No matter where you are in the country you will most likely experience some type of hard water at some point.
The key is to find the right product that will remove mineral buildup on almost any surface. Now finding the right product is not always that easy, because of the amount of products that are on the shelves today. The product that I have had the most success with is called the Bring It On Cleaner Hard Mineral Remover.
The problem with wood burning fireplaces is that overtime your fireplace glass begins to darken from the smoke residue. After a while you cannot even see the flames and loose the ambiance of the fire. This is an ongoing problem throughout the winter, so you need to find a fireplace glass cleaner that will remove the dark residue from the glass doors.
Fire glass cleaners are a dime a dozen, they claim that there's a specific product out there for only this application. In reality I have stumbled on a product that will not only clean my fireplace glass, but will clean my shower doors outside windows sinks and much more.
Do you have a grease or cooking oil stain on your granite countertop? The Problem is, how to clean stains on granite? Perhaps you spilled some oil or grease or your kids left a pizza box on the granite overnight. Common Problem!
You can easily remove oil from granite counter tops using a high-powered oxygen bleach. The key is to just have patience as the cleaning process could span a few days depending upon the density and porosity of the granite.