This shift in policy is expected to particularly impact mechanic trainees and aircraft owners who have historically been able to perform maintenance under flexible, supervised conditions.

What Has Changed?

Previously, the FAA regulation under 14 CFR 43.3(d) allowed mechanics discretion in determining how to supervise maintenance work. This included being able to check in at various critical stages, without having to be physically present from start to finish. Such flexibility was especially valuable for owner-assisted annuals and apprentice mechanic training programs, where tasks were often monitored remotely through digital tools. However, under the Moss Interpretation, supervising A&P mechanics must now be present throughout the entire maintenance process.

This change has triggered concerns from industry stakeholders who view the ruling as an unnecessary overreach.

Industry Reaction

Many in the aviation community, including the Aircraft Owners and Pilots Association (AOPA), see this new interpretation as ill-conceived. It is feared that it will make owner-performed maintenance and mechanic training significantly more difficult—if not impossible—especially at a time already facing a severe shortage of skilled aviation mechanics.

“For more than 60 years, the rule gave mechanics the flexibility to ensure the work was done properly without full-time, in-person oversight,” said a representative from AOPA. “This change undermines that long-standing practice at a time when our industry can least afford the disruptions it may cause.”

Aviation experts, like A&P mechanic Mike Busch, have also been vocal in their opposition to this policy change. Busch has formally written to the FAA’s Regulation Law Division requesting a reconsideration of the Moss Interpretation. In his letter, co-signed by A&P/IA mechanics, shop owners, and instructors, Busch emphasized the practical and common-sense approaches that the industry has relied on for decades.

Why It Matters

The new interpretation comes at a particularly challenging time for the aviation sector. As the industry grapples with a mechanic shortage, forcing A&Ps to be physically present for every task threatens to reduce efficiency, increase costs, and limit the ability of mechanics to train the next generation. For aircraft owners, the policy could render common practices, such as owner-assisted maintenance, far more complex and costly, possibly discouraging participation in general aviation activities altogether.

Furthermore, given the already stretched resources, requiring mechanics to be present throughout the entire maintenance process could result in fewer jobs being completed on time, delaying aircraft availability and increasing operational downtimes.

AOPA’s Response and Advocacy

In response to the potential challenges this new interpretation poses, AOPA is taking action. The association has not only co-signed letters urging the FAA to reconsider, but it is also actively advocating for a return to the original, more practical interpretation of 14 CFR 43.3(d).

By engaging with the FAA at the highest levels, AOPA is hopeful that a reasonable solution can be found that balances safety with practical, industry-friendly regulations. Their goal is to ensure that both aircraft owners and mechanics can continue performing supervised maintenance tasks in a manner that supports the industry’s sustainability and growth.

Moving Forward

As the dialogue between the FAA and industry stakeholders continues, aviation enthusiasts and professionals alike are watching closely. Whether the FAA will reverse or modify the Moss Interpretation remains to be seen, but one thing is clear: the aviation community is united in its call for a more flexible, common-sense approach to supervised maintenance.

The outcome of this advocacy will undoubtedly play a crucial role in shaping the future of general aviation, mechanic training, and aircraft maintenance in the U.S.