If you're like me and have been doing "owner assisted/supervised" maintenance and or annuals on your plane, then this narrative is one you should read closely!

From Mike Busch of Savvy Aviation

24 September 2024

Recently, the FAA Rulemaking Law Division issued a new legal interpretation - the
"Moss Interpretation" - that could profoundly affect the ability of mechanic trainees and aircraft owners to perform maintenance under the supervision of an A&P mechanic. This new interpretation requires that supervising A&Ps be physically present for the entire maintenance process from start to finish, removing the flexibility to conduct strategic check-ins at key stages and prohibiting the use of reliable tools like video, photos, or other electronic methods to monitor progress.

For many of us in the aviation community, this is a wrongheaded policy change. It could make owner-assisted annuals, owner-performed maintenance, and the training of apprentice mechanics difficult or impossible at a time when we're already facing a severe mechanic shortage.

Why This Matters

For over 60 years, the original rule on supervised maintenance, 14 CFR 43.3(d), gave mechanics the flexibility to determine how best to ensure the work is done properly. But this new interpretation takes away that flexibility, forcing full-time, in-person supervision that isn't always necessary. In a time when our industry is already stretched thin, this change could cause significant disruptions.

WHAT SAVVY IS DOING TO HELP

While this interpretation has just come to light, we recognize its potential impact on the general aviation community. Mike Busch has written a formal letter to the FAA'S Regulation Law Division requesting a reconsideration of this ruling. Our letter, co-signed by A&P/lAs, shop owners, and instructors, asks the FAA to return to the practical, common-sense interpretation we've relied on for decades.

In addition, AOPA is actively advocating on this issue at the highest levels of the FAA.
We're hopeful that by working together, we can encourage the FAA to adopt a more reasonable approach that benefits aircraft owners and mechanics alike.

Savvy's Request for Reconsideration of the "Moss Interpretation" is HERE

AOPA article "New FAA Interpretation Could Devastate GA"

15 October 2024 NEWS FLASH

FAA Issues Temporary Legal Stay of "Moss Interpretation"