Owner Assisted Annuals are Now Outlawed unless Supervised 100%.

[Half Fast]

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.

Yes, I know that's how the FAA has interpreted the interpretation, but it isn't what the LOI actually says. The LOI says

Even though the introductory text of subparagraph ( c) states that "[p ]reventive maintenance is limited to ​

the following work... ." (emphasis added), in view of the broader definition of preventive maintenance in​

section l. l , we believe that such limitation is not controlling. ​

It does not say that PM must fit into one of the categories; rather, it says that the limitation of Appendix A does not control whether or not a task is PM. If a task fits the PM defintion it's PM, regardless of Appendix A.

Granted, if you can argue that a task can be described as similar to something that's on the list, you'll have a much easier time convincing someone that it's PM. Most times that's practical. For example, @xenadu mentioned replacing a landing light switch. I could argue that task fits this category:

(16) Trouble shooting and repairing broken circuits in landing light wiring circuits. ​

since the switch is part of the circuit. So long as no complex disassembly and reassembly were necessary to access the switch, I think replacing it would be considered PM.

But there are other tasks that can't really be made to fit one of the App A categories but are equally simple and fit the definition well. For example, the overhead PA speaker in my Musketeer can be accessed by removing a handful of screws and the electrical connection is made with two slip-on connections. The speaker is certainly a "small standard part" and replacing it would not require anything close to a "complex assembly operation," but I don't see any category in the App A list that would cover it. Nonetheless, I'd feel comfortable replacing it if it ever failed and I'm confident the A&P-IAs that I use would agree that it fits the PM definition. I would log it as such and I'd be very surprised if that were ever challenged.

The Office of the Chief Counsel has generously allowed us lots of room here.

 

[Bell206]

Yes, I know that's how the FAA has interpreted the interpretation, but it isn't what the LOI actually says.

But that is the key part, how they interpreted it. I’m merely passing on how it has been practiced for years even before Coleal. If you want to experiment with your interpretation rock on. But you’re not the first. Just be ready with a solid reference if you ever get questioned on your PM write up. Waving only the Coleal letter in victory usually gets reversed into a white flag of surrender in the eyes of some APIAs or ASIs.

But there are other tasks that can't really be made to fit one of the App A categories but are equally simple and fit the definition well.

You have to get creative. The light switch is a classic. And so would your speaker example be using the same PM category if you look at from this angle: (16) Trouble shooting and repairing broken circuits in [any] wiring circuits. Think category not line item.

I spent many hours with my owner-assist customers showing them the outer limits of preventive mx. My take was if you couldn’t shoehorn the task into one of the 32 existing categories or couldn’t get a LOE, then you should probably view it as an owner-assist task with your mechanic.

 

[jnmeade]

Or the evapotranspiration that waters the corn, and the bees that fertilize the seed? God, I think…same as IA.

Laugh! Oh my god. What a yuck.
Evapotranspiration is the combination of evaporation (water moving from the ground to the air) and transpiration (water moving from the plant to the air). Neither process has anything to do with "watering" the corn.
Bees have nothing to do with fertilizing anything. They pollinate some plants, but corn is self-pollinating. That is, the pollen (male) from the tassels falls on the silks (female) and that is how the fertilization takes place. Corn plant pollen can drift and pollinate any nearby corn plant but of course much of it falls down and pollinates it's own female receptacles.
Better luck on your next simile.

 

[Sierra_Hotel]

Whoosh.

 

[MRC01]

I searched but didn't find this, so it looks like my post was a duplicate. I'll refer it here.

 

[idahoflier]

The uproar would appear to be over this:

"The certificated mechanic must be available, not just
to answer questions, but to notice mistakes and take over if necessary. In Blakey v.
Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 (December 10,
2004), the NTSB upheld the suspension of the respondent’s Commercial Pilot Certificate
for performing unsupervised maintenance—specifically, for performing some
maintenance tasks while in earshot of certificated mechanics, but without any mechanic
directly watching him."

The above implies that an A&P must be watching the unlicensed individual performing any work requiring a certificate at all times. This would probably effectively end any shops employing apprentice mechanics as it makes no economic sense to pay an A&P to watch an unlicensed individual performing maintenance.

How devastating is this? IDK? I believe all the individuals employed by the shop I use that are maintaining my aircraft are A&P's. However, I think one shop on my field employee several non-certificated individuals and I can see this interpretation having a major impact on their business. There is already a backlog for GA maintenance in the area. This would only make it worse...

 

[Bell206]

The uproar would appear to be over this:

There is a consensus that certain people are cherry-picking several “supporting comments” out of context and applying those comments to the whole LOI for whatever reason. Read the first/second paragraphs and the last paragraph of the LOI, then read the rest. Context is everything.

There has been a push for remote mx supervision since covid in certain circles, so this LOI shutdowns all those attempts which may have been the reasoning for the initial request. Regardless, seems the people complaining the most either have limited experience supervising mx or support remote supervision in some way. I'm with the consensus, it merely restates all supervision must be in person.