Light-Sport Repairman: Details on the new ruling

On July 16, 2004, FAA Administrator Marion C. Blakey signed the long-awaited light-sport aircraft rule.

What are the requirements for experimental, operating light-sport aircraft?
The experimental, operating light-sport aircraft airworthiness certificate is designed for pleasure/personal flying only. So the inspection requirements are similar to those inspection requirements for amateur-built aircraft. In other words, both experimental aircraft's operating limitations require the owner to perform an annual condition inspection once a year and comply with their own operating limitations.

Remember, that both the light-sport aircraft and amateur-built rules only speak to inspection: not repairs, alterations, or even preventive maintenance. This is because an "Experimental" airworthiness certificate is issued to an aircraft that meets no known FAA-approved design standard. So there is no rule on the books that requires a certificated mechanic or repairman to perform regular old maintenance, repairs, and alterations to a known standard. In fact, anyone can do maintenance on these aircraft as Part 43 and Part 65 rules do not apply.

But to perform the annual condition "inspection" as identified in the aircraft's airworthiness certificate's operating limitations, that inspection must be performed by an A&P mechanic, or a light-sport repairman, or appropriately rated repair station. The FAA wants a certificated person, once a year, to determine if these experimental aircraft are safe to fly.

What are the requirements for special light-sport aircraft?
A special, light-sport aircraft is also issued a pink or special airworthiness certificate that is issued to an aircraft used for hire, such as for flight training, towing, and rental. Because the owner/operator of these aircraft can hold out to the public, a different set of maintenance requirements apply. For example, the aircraft must be maintained to an industry-developed consensus standard as defined in Part 1.

This consensus standard includes maintenance and inspection procedures, identification and recording of major repairs and major alterations, and continued airworthiness. In addition, all maintenance performed on Special, light-sport aircraft must be performed in accordance with Part 43, with the exception of sections 43.5(b), 43.9(d), Appendix A and Appendix B which deals with the identification and recording of major repairs and major alterations. That means no Form 337. So why is the Form 337 not used? Well, it's because the light-sport manufacturer's consensus standard is considered acceptable data only, and not approved data like a TC. If you recall, the Regulations 101 course from A&P school, taught that the Form 337 documents only "FAA-approved" major repairs and major alterations."

Now let's rehash the subject a bit more.

First, the light-sport aircraft consensus standard (think type design) is acceptable data only.

Two, the light-sport manufacturer is going to identify major repairs and major alterations for his aircraft.

Three, the manufacturer dictates who is qualified to perform major repairs and major alterations to his aircraft and the paperwork goes back to him.

So there is nothing left for the FAA to approve. So saying that, since there is no approved data for these aircraft, and no description of major repairs or major alterations, now you can see why the Form 337 is not required.

Here's another item that you might find interesting. The rule requires that any Airworthiness Directives (AD) against any FAA approved product that is installed on these Special, light-sport aircraft must be complied with. In addition, any safety directive issued by the aircraft's manufacturer in accordance with the consensus standard must also be complied with. Compared with amateur-built aircraft, the maintenance requirements are tightened up quite a bit for Special, light-sport aircraft.

How many light-sport repairmen certificates are there?
There is only one certificate, repairman light-sport, but there are two ratings: inspection and maintenance. To be eligible, besides completing the required training, an applicant must be 18 years old, a U.S. citizen or a citizen of a foreign country lawfully admitted for permanent residence in the United States, and able to read, speak, write, and understand English.

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