Otter said:FAA Handboks are guidance. However, trying to have the argument with a inspector that it is not rule willl not get you anywhere. The handbooks tell them how to complete their job. Thus unless you submit in a fashion that lines up with the handbook and they can see the way to the next step, you will get nowhere.
Down side is very simple items can be a real death march when the guidance in followed to the letter. The certification process, adding of new aircraft or privileges to a certificate holder (especially those with validation testing) or initial issuance to a applicant certificate is the slowest and most frustrating regarding the handbooks.
Upside, if you submit in accordance with the rule and guidance, they really cant say no....unless you have acted like a tool, and now they dont like you, then they will have to give it to eventually, but they can make sure the delay is murder.
Unfortunately just about each item in the quidance has an out. It allows the POI to use his judgement. It is most likely due to the instruction they get from the FAA Academy. The original intention of the wording was to allow the POI to deal with situations that were well outside the norm. But they are using them to fulfill their own personal ideas and predgeses(sp).