After reading every post on this thread, I have come to the considered conclusion that I’m unclear how a large gov organization can make something so simple, into something so complicated.
It’s just the bureaucratic mindset. It’s a powerful force.
I got an education on this front recently when entering Mexico in a friend’s TBM. The various officials there, from various departments (army, customs, immigration, airport operations, airport management, probably others, I stopped counting) each required a bewildering and unpredictable array of inspections, documents, stamps, walking around the airport to visit the various departments multiple times, etc. They frequently disagreed with *each other*, quite amicably, about procedures and requirements. None of it felt remotely like a shakedown, and everyone was very friendly. From what I can tell, they were just doing their jobs, serving an even bigger bureaucracy, and their jobs simply give them no incentive whatsoever to rationalize or streamline the process. They were incentivized only to get stamped pieces of paper that then went… who knows where. Probably nowhere. The stamped paper was magical.
This op Lim amendment exercise is, obviously, equally pointless. There’s now a reg that says clear as day that an LSRI or LSRM can inspect an EAB. From what I can tell, the language of most op lims doesn’t even expressly prohibit this. But someone concluded this reg requires reaching into the document pockets of every EAB to extract and modify documents that purportedly… must be modified. For some reason. Because to a bureaucracy, paper is magical.
What exactly would cause the wings to fall off if this never happened? Why can’t future regulators, mechanics, etc. simply look at the date of even the contradictory op lims and understand they were written before the reg, and then go on about their day? We are not told, because that question literally never occurs to the FAA. There’s no reason it should. The paper and the process are a sufficient goal.
The key thing is that in a bureaucracy, there usually is zero incentive NOT to do this. There is no incentive to streamline the process. There is no incentive for the right hand of the FAA to talk to the left hand. There is the inevitable interplay with other regs in an ocean of regs, such that now we must first, apparently, review “the latest AD Biweekly Report,” a document that I confess I had never previously heard of.

What does that have to do with reconciling op lims with the new regs? It doesn’t matter.
We are all at the Mexican airport. Although I note that the Mexican authorities never asked for the latest AD Biweekly Report.
If there’s any good news, it’s that this process expressly requires someone to determine that your plane is airworthy. That adds at least one real person to the liability circus if the worst happens and your estate decides to sue.
