Owner Assisted Annuals are Now Outlawed unless Supervised 100%.

[Bell206]

So removing from one airplane to put in another is not maintenance, but removing one to fix it or inspect what is underneath is maintenance?

??? The context of my comments is simply the removal/disassembly tasks are included in the required Part 43 aircraft mx record which is rarely enforced at the Part 91 level. I believe you then made a comment that somehow removed boneyard parts were illegal. Not quite following how that illegal comment or the question above fit into that discussion. Perhaps an example?

in this case, while the interpretation is 20 years old, I was told as recently as about two weeks ago that as the supervisor, I only had to be reasonably available on premises.

And that’s basically the same thing I’ve heard for years especially in a Part 145 setting where one supervisor can legally have up to 10 uncertified people working under them at the CRS facility. So I believe the LOI simply verified the “in person” portion to the “readily available” portion of the rule.

 

[Doc Holliday]

Going back to the title of this thread " Owner Assisted Annuals are Now Outlawed unless Supervised 100%. " Doc, I agree with what you have pointed out and that the FAA is not going to stand behind the A&P and ensure that he is standing over the apprentice.

Just like it's always been, the apprentice needs direct supervision during their training. Once the apprentice has proven their knowledge on a particular task they can enter that in their 'Maintenance Log Book'. Then they need to present that MX Log Book to the FAA to show experience towards taking the A&P test.

My “maintenance logbook” when I got my A&P consisted of a one page letter detailing my experience.

I used that same format to sign off several A&P applicants.

YMMV

 

[Ventucky Red]

Funny... a surgeon can supervise a surgery in Timbuktu while sitting in their office in New York City... let alone actually perform some Laparoscopic procedures...

Kids in school are leaning via the internet... with the exception of labs, my kid's college experience is mostly online..

And yet the FAA wants go backwards in place of moving forward... Once again the FAA lives up to its motto -"we're not happy, until we have made you miserable.."

 

[MauleSkinner]

Funny... a surgeon can supervise a surgery in Timbuktu while sitting in their office in New York City... let alone actually perform some Laparoscopic procedures...

Kids in school are leaning via the internet... with the exception of labs, my kid's college experience is mostly online..

And yet the FAA wants go backwards in place of moving forward... Once again the FAA lives up to its motto -"we're not happy, until we have made you miserable.."

How is the FAA “go(ing) backwards” on this?

 

[Doc Holliday]

Funny... a surgeon can supervise a surgery in Timbuktu while sitting in their office in New York City... let alone actually perform some Laparoscopic procedures...

Kids in school are leaning via the internet... with the exception of labs, my kid's college experience is mostly online..

And yet the FAA wants go backwards in place of moving forward... Once again the FAA lives up to its motto -"we're not happy, until we have made you miserable.."

There are plenty of mechanics that will sign off work with never seeing the aircraft. What's the complaint?

 

[Bell206]

And yet the FAA wants go backwards in place of moving forward...

Not really. A majority of the FARs are to satisfy the requirements of international treaties and agreements. So if the FAA changes a rule that violates those agreements, the affected aircraft will lose “international status” per se. Simply look at the result of the TCCA Owner Maintained category of aircraft as they can no longer be flown or exported outside of Canada. The interesting part is the US FAR system is the most lenient of all ICAO member nations. So a better comparison would be to the CASA mx system or EASA mx system vs comparing it to an international TeleHealth rule system which also has its own issues and limitations.