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. The rule allows for the certification of approximately 14,000 existing light-sport aircraft, 14,000 brand-new pilots, and 14,000 brand-new repairmen.

I am well aware that individual mechanics, and maintenance organizations have expressed great interest in this rule's repairman certification and shared with me their honest concerns about the possible negative impact it may have on our profession. So in this article I will attempt to give you a good briefing on the rule requirements and hopefully arrest your fears by calibrating reality.

What is a light-sport aircraft?
This new Part 1 definition is a very broad one and it states that a light-sport aircraft means an aircraft, other than a helicopter, or powered-lift that:

  1. Weights of no more than 1,320 pounds for aircraft not intended for operation on water or 1,430 for an aircraft intended for operation on water
  2. The aircraft must have a maximum airspeed in level flight of 120 knots, and a maximum stalling speed of not more than 45 knots
  3. Two seats
  4. A single reciprocating engine
  5. A fixed or ground adjustable propeller for aircraft other than a powered glider
  6. A fixed or auto-feathering propeller system if a powered glider
  7. A nonpressurized cabin, if equipped with a cabin
  8. A fixed landing gear for land operations
  9. A fixed or repositionable landing gear or hull for water operations
  10. Fixed or retractable landing gear for a glider

Now, I know what some of you are thinking. "Hey, O'Brien that definition includes J-3-cubs and Cessna 120s and other light 2-place Type Certificate (TC) aircraft. Is this rule going to put us mechanics out of a job?" The answer is no! I made sure in the rule language that TC aircraft and amateur-built certificated aircraft could not "cross over" and be certificated in light-sport category.

So nothing has changed. Annuals, Part 43 performance requirements, and ADs will still apply to the "light-sport" TC aircraft and the annual condition inspection and applicable operating limitations will still apply to amateur-built aircraft even if they meet the definition of light-sport aircraft in Part 1 to a T.

However, it is true that the rule will allow a properly certificated light-sport pilot to fly a TC light-sport aircraft like a J-3-cub or an amateur-built aircraft like a RV-4.

Again, at the risk of repeating myself, this rule will not affect existing TC and amateur-built aircraft maintenance and certification requirements. There will be no supplemental type certificate (STC) granted to older Cessna 150 in order to shave off pounds to meet this rule! There will be no exemptions given to TC aircraft in order to meet weight or speed requirements of light-sport aircraft. Furthermore, certificated light-sport repairmen are prohibited from performing maintenance or inspections on a TC or amateur-built aircraft.

How many kinds of light-sport aircraft airworthiness certificates are there? There are two: Experimental, operating light-sport aircraft, and special light-sport aircraft. An interesting part of the rule is the term, "experimental" operating light sport aircraft, "Experimental" is not considered a "category" but a "special" light-sport aircraft is considered a category by itself. To add to the confusion, both experimental and special light-sport aircraft are issued a special (pink) airworthiness certificate FAA Form 8130-7. So if you are about to work on these kinds of aircraft, first check the pink airworthiness certificate and see what kind of light-sport aircraft you are leaning against.

How many "classes" of light-sport aircraft are there? In experimental, operating light-sport aircraft there are six classes: airplane, glider, lighter-than-air, powered parachute, weight-shift, and gyroplanes. In special, light-sport category, there are five classes: airplane, glider, lighter-than-air, powered parachute, and weight-shift. Gyroplane class was dropped because both FAA and the gyroplane folks estimated that it will take a while to develop a gyroplane consensus standard; so for now they will stay in experimental.

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.

What can a light sport repairman with an inspection rating do? First off, this certificate is issued only to the owner of an experimental, operating a light-sport aircraft. This will allow the owner to perform the annual condition inspection required by his or her aircraft's operating limitations. Each FAA repairman certificate will identify his aircraft's registration number and serial number so he can't cheat and do his buddy's inspection.

What are the requirements to become a light-sport repairman with an inspection rating? As I mentioned earlier, the experimental, operating light-sport aircraft airworthiness certificate and the amateur-built airworthiness certificate are similar in form and function. But there is a major difference. The owner/operator of an experimental light-sport aircraft did not build 51 percent of the aircraft like the amateur-built repairman.

What can a light sport repairman with an inspection rating do? First off, this certificate is issued only to the owner of an experimental, operating a light-sport aircraft. This will allow the owner to perform the annual condition inspection required by his or her aircraft's operating limitations. Each FAA repairman certificate will identify his aircraft's registration number and serial number so he can't cheat and do his buddy's inspection.

What are the requirements to become a light-sport repairman with an inspection rating? As I mentioned earlier, the experimental, operating light-sport aircraft airworthiness certificate and the amateur-built airworthiness certificate are similar in form and function. But there is a major difference. The owner/operator of an experimental light-sport aircraft did not build 51 percent of the aircraft like the amateur-built repairman.

So how does the FAA ensure that the owner has the expertise to inspect his or her aircraft and make the determination if it is safe to fly? The answer is the rule requires the owner to get 16 hours of FAA-acceptable training in the class of aircraft that he or she owns.

FAA accepted training for each of the six eligible classes of light sport aircraft will focus on to how the repairman is to inspect the aircraft, not how to maintain it. How so? Remember what I said earlier, the operating limitations for these aircraft, requires an annual condition inspection, not maintenance!

Again, I will risk being accused of beating the point to death. Please remember that the 16-hour course will teach an individual how to inspect his aircraft only, not perform maintenance. This somewhat odd situation has come to be because there are no TC or any other standards for experimental light-sport aircraft. So anyone can remove and replace parts, and perform repairs and alterations on these aircraft because there is no standard of performance for the maintainer to meet.

Some of you argued that 16 hours is not long enough. Others have commented that the training for this rating is eight hours too long. The bottom line is the rule is signed. To qualify, it requires 16 hours of training on the class of aircraft that is owned by the repairman. If it turns out that the time required to train an individual to a level 3 performance level of skill is not right for all or just one particular class of light-sport aircraft, we will change it and make it right.

For your information both the inspection and maintenance rating courses are required to teach to a level 3 instructional level. This level 3 requirement is taken from Part 147 appendix a. This appendix a identifies a level 3 performance as a level where a student can perform the task by demonstrating a high level of skill. In addition, the rule requires that for each rating, each student must pass a written test with a passing grade of 80 percent.

What can a light-sport repairman with a maintenance rating do? For starters, this rating is not limited to just one aircraft like the inspection rating. This rating allows the repairman to perform for hire, annual condition inspections on experimental, operating light-sport aircraft and perform maintenance, including the required annual condition inspections on Special, light-sport aircraft. These privileges are limited to the class of aircraft that the repairman has received training on, as identified on his or her FAA repairman certificate.

Under this rating the repairman can work on and sign off manufacturer's safety directives and AD on TC products installed on special, light-sport aircraft only. The rating is limited to regular maintenance and preventive maintenance functions and does not authorize the performance of major repairs or major alterations. Why? Because the aircraft's consensus standard requires the manufacturer of the aircraft to determine what is a major repair and a major alteration. The same consensus standard requires the manufacturer to determine what additional training is required to perform those tasks to ensure that the repairman is qualified to make those major repairs or alterations.

What kind of training does a light-sport repairman with a maintenance rating need?

The FAA-accepted training is different for each "class" of special light-sport aircraft as follows:

On the apples side of the argument the A&P is trained to work on a broad spectrum of aircraft ranging from J-3-cubs to B-747-400. This FAA-required training covers hundreds of hours of training on such systems as APU repair and trouble shooting, radial and jet engine overhauls, autopilots, helicopter maintenance, fire suppression systems, controllable pitch propellers, retractable landing gear, and deicing and anti-icing systems.

On the oranges side of the argument, the light-sport repairman is trained on one particular "class" of light-sport aircraft whose very name indicates that we are dealing with an aircraft with limited design and performance capabilities.

In addition, the light-sport repairman cannot do major repairs or major alterations unless the manufacturer determines that he or she has additional training to perform the work, including engine overhauls. So what we have is a repairman who can inspect, troubleshoot, remove, and replace parts on one class of light-sport aircraft not a fleet of aircraft.

As a bureaucrat, I have to factor into the problem that I am required to meet Title 49, section 44701 of the Code of Federal Regulations. This rule mandates that the FAA set minimum, not maximum, standards for safety. So listed above are minimum training standards for light-sport repairmen. But as a mechanic I know Mr. Murphy's Law oh too well. That is why on page 304 of the preamble language to the rule I added: "FAA may amend the regulations if the numbers of training hours or subjects taught are found insufficient to ensure aviation safety."

Can an A&P perform inspections and maintenance on light-sport aircraft in both experimental and special light-sport category? The answer is yes. However, please remember that when you are working on special light-sport aircraft, instead of TC data you are held to the aircraft's consensus standard, maintenance manual, and instructions for continued airworthiness. Furthermore, on special light-sport aircraft both Part 43 and Part 65; section 65.81 General privileges and limitations still apply to A&P mechanics.

To satisfy section 65.81, you need to make sure that you can prove to an FAA inspector that you did the work on the light-sport aircraft before at an earlier date, or had been trained to do the work, or were supervised by another mechanic or repairman. If you cannot show that you did at least one of the items listed above you can always take a practical test administered by a FAA inspector to prove your ability to perform the task. If I was you, and I was planning to make some money in this new marketplace, just to be sure, I would take one of the FAA accepted courses for the class of light-sport aircraft I was interested in.

In closing, I hope that I have convinced you that the light-sport pilot rule repairman certification does not steal hard-earned rights and privileges from our A&P. In reality there will be at least 14,000 new aircraft in the marketplace that an A&P can work on.

Because of limitations on the length of this article I did not cover how the training providers for the repairman, inspection, and maintenance ratings will get their courses "accepted" by the FAA. Nor, did I cover the FAA's need for light-sport Designated Airworthiness Representatives. As soon as the FAA Orders on these subjects are signed, I will write an article covering these important subjects.

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