The Coleal LOI recommended revising AC 43-12A. The FAA never did that. IMO that has allowed a situation to persist where the plain language of the regulation appears to be different than the enforceable meaning. Pilots should not have to search for legal interpretations to understand the core intent of a regulation. The FAA should fix that.
While I agree from a philosophical standpoint, from a practical standpoint I fear that any "fix" from the FAA will result in things being more restrictive. The FAA has no real motivation to do anything other than tighten restrictions, as there is no down side to doing so and no up side to loosening them.
IANAL, but I spent a lot of years writing, reading, and interpreting proposals, specs, SOWs, and contractual documents as a defense contractor, and I know you've done the same. We always treated appendices as informational, not binding parts of a spec or contract, so if there's a conflict the main document takes priority. I may be wrong (and often am), but it seems to me this is a similar situation, and the Coleal LOI implies as much when they wrote that the
definition of PM is controlling, not the list.
The actual regulation that enables a pilot to do PM on his own aircraft is 14 CFR 43.3(g). That paragraph uses the term "preventive maintenance" and the regulatory definition of the term is included in 14 CFR 1.1. Nothing in the actual regulation invokes the list in the Appendix. The AC is, of course, advisory, not regulatory.
The document heirarchy is then 14 CFR 43.3(g) > 14 CFR 1.1 > Appendix A(c) > AC 43-12A. In event of conflicting language, the regulatory statement and definition take precedence over an appendix and certainly over an advisory circular. I believe that's pretty much how FAA legal looked at the situation, and that's why they recommended that the AC be corrected.
I suspect the FAA didn't like that answer and so they never bothered to follow through with the AC.
You're quite right that pilots shouldn't have to search all this out. From the FAA's standpoint, though, if pilots don't dig into it they'll limit themselves to the appendix list, and that's pretty much what the FAA would prefer anyway, so why would they bother to fix it?