Thank you but that is not an official link or document I was looking for. Plz, I'd like to know how you or the posting source came to this particular Memo(?).
A little background:
I've been working closely with the FAA for 26yrs as a pilot, A&P, SW Administrator, FEMA Helibase Manager.... Memorandums within federal agencies are passed about daily for intent of other Inter-Agency personal to review for consideration. Usually if a "Memorandum" is intended for public review, it is tagged with a filling code (I'm forgetting the format off to top of my head [because they are just only that - a memorandum and holds no official Authorization, or even guidance - It moves on to the rule making phase for hand]) and made public for inspection. There are lawyers currently arguing since October about subject matter stated in the memo (hence to why this Memo came into existence in January within the Agency).
I've been advised that it is not official. However if an incident occurred within an oE extension the verbiage in the official Part can be argued (easily).
But, my personal advise is since this is still up to the local FISDO Admins interpretation (after the fact of an incorred incident), is to avoid court and lawyer fees until an official (if any comes about) Directive is filled. Talking to your local Office (which i did this morning) isn't enough until it's in an official letter-headed document.
Before I catch slack here on the forum, remember, as pilots, we have to adhere to the CFR's, not interpret them.
~j