While I have a long-standing profound respect for Mike Busch, he and I have disagreed on several occasions, and I do not agree with his position in this case. The thrust of the article centers on Mike's argument against the Chief Legal Counsel interpretation, and all due respect to Mike Busch, his argument is self-serving and does not reflect the reality of the industry, including maintenance/repair organizations, repair stations, etc. Mike's business, Savvy Aviation, centers on counseling aircraft owners remotely (as well as books, audio tapes, and other products and services). Mike's services have significant value, meaning retaining his services, counsel, and publications is buying a lot of understanding and experience. It's a good investment. However, his assertion that remote supervision is a common component of MRO services is misplaced. It is not. Moreover, his aassertion that the Legal Counsel interpretation puts an undue burden on repair stations by requiring them to employ supervisory mechanics is not correct.

It is true that repair stations can and do employ non-certificated mechanics, but it must be understood that when working under a repair station certificate, it is not common to sign off work under one's own mechanic certification. Rather, the repair station certificate is the umbrella certification that's used to sign off the work. I may work for a repair station (and have), but most of the time if I sign off a repair, alteration, modification, or inspection, I would not use my mechanic certificate number on the paperwork, but the repair station certificate number, and my name, as an authorized employee under that certificate. Likewise, one may be an inspector in a repair station without working under one's own inspection authorization (IA): the authorization to inspect is grated under the authority of the repair station, and an inspector working for that repair station must meet all of the criterial applicable to that repair station authorization, including the training, testing, qualification, experience, drug testing, etc. The approved acceptable tools, methods, and techniques must be used, and in many cases, certified, tested, and logged equipment, tested and maintained under the repair certificate holder, must be used.

The notion that repair stations are simply a collection of unqualified, unapproved apprentices that get approvel telephonically or via an internet connection, is ridiculous. Apprentice mechanics do work in repair stations, but always under the close supervision of experienced and qualified mechanics (certificated or otherwise, and all ultimately work under authorized personnel under the repair station certificate. I can't imagine supervising a mechanic, or someone doing maintenance duties, simply by an internet connection or telephone call.

Busch is correct that it's not reasonable that a supervising mechanic hovers over the work 100% of the time, without blinking. There is a difference, however, between the owner-assisted annual, for example, where the owner might open the airframe and close it (fairings, covers, inspection plates, etc, and something far more involved such as directing a cylinder replacement remotely. It's not sufficient that a mechanic simply justify his remote observation by saying "I'm ultimately responsible, so it's up to me if I do it online. The regulation requires the mechanic to have a more direct role, and the FAA expects it. This is not unreasonable. I have no problem enlisting an owner to open inspection panels. I have no intention of telling an uncertificated mechanic or owner to do a cylinder change remotely, and then sign it off after that irresponsibly indirect level of supervision or control. No way. The idea that repair stations will suffer as a result of this interpretation is overblown and misplaced.