AskBob on Thu, 03/12/2009 - 12:01
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For those that are still interested in following this topic, here is an interesting response from ARSA to the FAA Memo we have been discussing sent to me by Adam.
When Current Is Past
In December 2008, the FAA's Office of Chief Counsel, Regulatory Compliance Division issued an interpretation of 14 CFR section 91.409(f)(3) that "a current inspection program recommended by the manufacturer" means the one that the registered owner chose at a point in time, not current as of "today". This has created confusion among maintenance providers as to which program they should be using on "current" inspections (those being done today). With the help of a member's law firm, Hogan & Hartson, L.L.P., ARSA requested guidance on exactly what program the maintenance provider should be using when the operator did not clearly "choose" one as required by 14 CFR section 91.409(f).
The December 2008 interpretation may be found here.
ARSA's request for guidance can be found here. (http://www.arsa.org/files/ARSA-91-409%28f%29%283%29122008Interpretation-...)