Not really. That LOI simply reiterates the same guidance that has been around for decades. It only deals with the supervision side of which does not include all the work a pilot can perform under prevent mx. So it doesn't stop owner-assisted work. The issue presented was does the supervising mechanic have to be personally present at the same area as the work being performed or could he use technology like "face-time" or other technology to supervise the work. The LOI merely answer that question and nothing else new.
How, in any aviation capacity? The LOI doesn't change anything. The actual regulation (43.3) has been written that way for many years. And if you go back to CARs, it was even more restrictive. Besides how would MB even know since he's only worked on his own aircraft?
Your subject line is unsupported by the article (or even your synopsis).
Anybody can make a plane unairworthy.
Really? Opening and closing an inspection cover is easy peasy compared to replacing any cowling not requiring removal of the propeller, which is Part 43 preventative maint. New engine cowlings aren’t predrilled.
This was asked by a FSDO Manager, not a random pilot. Probably due to some shop in his area using remote supervision.
Just how many days/weeks/months must the plane go without cleaning to make your inspection valid? Suppose I washed it a day before you start?
Big deal. My life depends upon that plane operating correctly. I value my life more than your name.
And that’s why you won’t be working on my plane.
The moment the plane leaves the IA, anyone on the ramp while it's parked, or in the hangar can do anything to the plane they want and the IA has no control over that, yet the IA "put his name on that inspection". You seem to think that signature is some sort of magic spell.
It is 100% legal for an owner to completely disassemble his own plane. He can remove inspection panels, remove instruments, take the engine off, even remove the wings. Oh, sure, it's now unairworthy, but so far it's perfectly legal to do. People parting out airplanes do it all the time. Insurers do it all the time when recovering it from a landing in a field. Salvage companies. Etc.
And for the 10x100000th time… you’re wrong again. If you would have dug a bit more in the LOIs you would have found the Hochberg LOI which addresses “owner-assisted annuals” and how to sign off the work of the "assister". So if the owner performs only non-maintenance tasks, i.e., cleaning, no separate write up would even be required.
Correct. For example, 43.3(d) also applies to Part 145 CRS supervision as well. And in a repair station one certified supervisor can have up to 10 uncertified person they are over. What some are missing from this discussion in addition to the “in person” requirement is “readily available” requirement. This is the key part. And the FAA has guidance on the use of “readily” which in most cases means “without hesitation.” And that can only happen when in person.
Of the INSPECTION. It has nothing to do with the peripheral tasks required to accommodate that inspection.
Nonsense. The ia must not be even given a sandwich for lunch during the inspection unless he supervises in its making. He must oversee the slaughter of the hog for the ham sandwich, and the reaping of the wheat to make the bread.
For the simple reason most FARs provide compliance with international aviation treaties and agreements. So any deviation from those standards creates issues with those aircraft maintained as you suggest. For example, the Canadian Owner Maintained class of aircraft cannot be flown or exported outside of Canada due to not following the ICAO standard.
It does, but as noted in the LOI any tasks are to be viewed as examples of each 32 categories which doesn’t mean you can expand the number of categories. This is how the prevent mx guidance and other noted guidance has been practiced for years.
Depends on the extent of the task performed. Have personally seen certificate actions, but the more serious actions from improper prevent mx were mostly against the aircraft AWC. Suspension of the AWC was usually the result until the aircraft was reviewed by an AP, IA or DAR. However, I did hear of one AWC revocation but that was due to extenuating circumstances. Its these type issues that made me a proponent of requiring each private owner/operator to make a signed entry prior to each annual inspection the aircraft was maintained per the AWC Block 6.
