The FAA has issued a stay of the “Moss Interpretation” of 14 CFR § 43.3(d), following significant opposition from aviation industry leaders.
This controversial legal interpretation, issued on Sept. 3, 2024, redefined supervision requirements for uncertificated mechanics, mandating the physical presence of certificated supervisors throughout all work — a move that critics argued was impractical and disruptive.
Industry Pushback
A coalition of 16 aviation organizations, including the Aircraft Owners and Pilots Association (AOPA), Experimental Aircraft Association (EAA), and the General Aviation Manufacturers Association (GAMA), led a unified effort to oppose the interpretation. They argued that the new mandate:
Harmed Workforce Development: Training uncertificated mechanics would become unfeasible, stalling their path to obtaining A&P certification.
Disrupted Maintenance Practices: It would eliminate owner-assisted annual inspections, a practice valued by aircraft owners for its educational and cost-saving benefits.
Economically Unsustainable: Repair stations would face prohibitive costs in maintaining constant on-site supervision.
A separate effort, spearheaded by Savvy Aviation, included a detailed letter signed by industry professionals, asserting that the interpretation misread existing regulations and ignored established practices.
FAA’s Stay
The FAA’s stay provides temporary relief to repair stations, mechanics, and aircraft owners while the agency reviews the policy.
Industry groups have committed to working with the FAA to develop a more practical interpretation that balances safety with modern technological and workforce realities.
