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