Quote Originally Posted by Marc Zeitlin View Post
If they have one, put it in. If they don't, leave it out. I understand what you're saying - that you sometimes cannot comply, intrinsically, with ALL of the listed requirements. But that doesn't imply (to me) that if you can't comply with all of them, you're exempt from all of them.
"exempt" and "not in compliance" do not have the same meaning. Omitting a regulatory requirement would be "not in compliance"

I doubt the FAA intended a rule to be applicable if by default it can force one to be "not in compliance"

You comply with the ones that are possible to comply with given the rules of EAB aircraft, which allow your mom's dog to do the maintenance on the plane (and she probably doesn't have an FAA certificate # to list [the mom or the dog]).
Mom's dog would not be able to comply with any of the mutually inclusive requirements. So in that example, we just completely ignore sections (i), (ii), and (iii) and leave the log blank! Got it!! The dog does all my EAB maintenance! That's why there are no entries!

I've seen Chief Counsel Opinions result in unintended consequences, not in a good way. Sometimes it's best to let sleeping dogs lie. Not aware of a single violation being handed out over EAB maintenance records.