MOSAIC Repairman Certificate classes

[RNB]

I attended an EAA meeting today with two members of the local FSDO FAAST team presenting on Mosaic. When discussing the updated LSRM/I stuff I asked about the need for new operating limitations. They said they had been asked about this recently and their read of things was that the operating limitations statement about suitably licensed mechanic covered things. They said they were the most knowledgeable of local FSDO staff on Mosaic. I relayed some of the "gist" of conversations here, they thought if new Op Lims were required that the FAA would not reissue 10,000+ and would likely have a lawyer issue an opinion that covered things.

The presentation seemed to be something that the FAA put together with forward facing slides and hidden additional information for the presenter.

I took a screen shot of the presenter contact info if anyone has further specifics. First guy on the list spoke the most. He asked me to let him know if I learned more.

It was a great program.

 

[Ironflight]

I attended an EAA meeting today with two members of the local FSDO FAAST team presenting on Mosaic. When discussing the updated LSRM/I stuff I asked about the need for new operating limitations. They said they had been asked about this recently and their read of things was that the operating limitations statement about suitably licensed mechanic covered things. They said they were the most knowledgeable of local FSDO staff on Mosaic. I relayed some of the "gist" of conversations here, they thought if new Op Lims were required that the FAA would not reissue 10,000+ and would likely have a lawyer issue an opinion that covered things.

The presentation seemed to be something that the FAA put together with forward facing slides and hidden additional information for the presenter.

I took a screen shot of the presenter contact info if anyone has further specifics. First guy on the list spoke the most. He asked me to let him know if I learned more.

It was a great program.

Well FAA HQ generally over-rules FSDO opinions, and HQ is changing the wording of the existing Operating Limitations because they believe it doesn’t cover the MOSIAC rule. I doubt anyone has had the last word on this - but just because you heard one or two FAA guys say something doesn’t make it the official interpretation. I have heard some REALLY incorrect statements from FAA FAST guys when it comes to experimentalist over the years.

YMMV

 

[Mel]

Well FAA HQ generally over-rules FSDO opinions, and HQ is changing the wording of the existing Operating Limitations because they believe it doesn’t cover the MOSIAC rule. I doubt anyone has had the last word on this - but just because you heard one or two FAA guys say something doesn’t make it the official interpretation. I have heard some REALLY incorrect statements from FAA FAST guys when it comes to experimentalist over the years.

YMMV

AMEN!

 

[N8DAV8R]

Well FAA HQ generally over-rules FSDO opinions, and HQ is changing the wording of the existing Operating Limitations because they believe it doesn’t cover the MOSIAC rule. I doubt anyone has had the last word on this - but just because you heard one or two FAA guys say something doesn’t make it the official interpretation. I have heard some REALLY incorrect statements from FAA FAST guys when it comes to experimentalist over the years.

YMMV

Right...we even saw it here on this forum with some early interpretations that were shared. In that case the FAA person did not understand the question correctly.

If I wanted/needed to rely on the presenters conclusion, I would have at least asked them to put it in writing. The difference between a mechanic and a repairmen is not a grey area in the FARs.

 

[j4cbo]

In summary, as I interpret this, I suggest the following:
1) As worded in the example, EAB Ops Limits provide inclusive examples of who may perform the conditional inspection, not an exclusive list of who must.

2) The MOSAIC NPRM makes clear the FAA’s intent to expand who may conduct that inspection via the creation of FAR 65.109.

3) The privileges of an LSR-I and LSR-M clearly state they are qualified (as appropriate to their rating)

I'm not a lawyer (I didn't even stay at a Holiday Inn last night) but I agree with this.

To add some more weight to it, consider limitation #19 found on page D-16 of 8130.2K. This operating limitation is issued for other types of experimental aircraft, certificated under 21.191(a), (b), (c), (d), (e), (f), & (h), which is to say, R&D, flight test, crew training, exhibition, air racing, market survey, and primary category kit-built aircraft, but notably not issued to E-ABs (21.191(g)) which get #18 instead. Limitation #19 says "Only FAA-certificated repair stations, FAA-certificated mechanics with appropriate ratings, or a manufacturer as authorized by § 43.3 may perform inspections required by these operating limitations." This is clearly an exclusive list.

On the other hand, limitation #18 issued to E-ABs omits the word "only". If it said "only", we'd be out of luck.

A key rule in jurisprudence is that every word has meaning. The FAA must have meant something by putting the word "only" in limitation #19 and not in #18; the only reasonable interpretation is that the list in #18 is inclusive (these people are granted permission by this operating limitation; other people may be granted permission in other ways) and the list in #19 is exclusive (anyone not on the list is excluded).

 

[mr.sun]

My EAB is owned by my LLC which is entirely owned by myself. I have been doing owner assisted annuals with an A&P for almost 20 years. Can I take the 3 day course to do these myself? If not, what can I do?

 

[RV-9erA]

I took a refresher motorcycle operator course, they ended it by saying, "You are now trained in operating a 250cc motorcycle within a parking lot! All other learning is on you."

How absolutely true that is! And yes -- it certainly applies to "a license to learn" after becoming an A&P.

 

[RNB]

My EAB is owned by my LLC which is entirely owned by myself. I have been doing owner assisted annuals with an A&P for almost 20 years. Can I take the 3 day course to do these myself? If not, what can I do?

I dont know about LLC, suspect it has been discussed upthread or elsewhere.

As to what else you can do? Take the 2 week class or move the plane out of the LLC.

 

[FORANE]

My EAB is owned by my LLC which is entirely owned by myself. I have been doing owner assisted annuals with an A&P for almost 20 years. Can I take the 3 day course to do these myself? If not, what can I do?

According to the Carpenters who run the Rainbow Aviation course, yes you can. Of course the other requirements apply: you must also get your LSRI certificate and update the op lims.

 

[Dugaru]

I'm not a lawyer (I didn't even stay at a Holiday Inn last night) but I agree with this.

To add some more weight to it, consider limitation #19 found on page D-16 of 8130.2K. This operating limitation is issued for other types of experimental aircraft, certificated under 21.191(a), (b), (c), (d), (e), (f), & (h), which is to say, R&D, flight test, crew training, exhibition, air racing, market survey, and primary category kit-built aircraft, but notably not issued to E-ABs (21.191(g)) which get #18 instead. Limitation #19 says "Only FAA-certificated repair stations, FAA-certificated mechanics with appropriate ratings, or a manufacturer as authorized by § 43.3 may perform inspections required by these operating limitations." This is clearly an exclusive list.

On the other hand, limitation #18 issued to E-ABs omits the word "only". If it said "only", we'd be out of luck.

A key rule in jurisprudence is that every word has meaning. The FAA must have meant something by putting the word "only" in limitation #19 and not in #18; the only reasonable interpretation is that the list in #18 is inclusive (these people are granted permission by this operating limitation; other people may be granted permission in other ways) and the list in #19 is exclusive (anyone not on the list is excluded).

I am a lawyer, I agree with you, and I don’t even think it’s a particularly close question. Although it’s probably sheer luck that the relevant wording for EABs works with MOSAIC.

On the other hand, the FAA has screwed up equally easy things before, while ignoring real contradictions.

We’re reliably told above that for some reason actual FAA lawyers—the people whose views count (mine don’t)—have convinced themselves that they need to change thousands (?) of op limits due to this (non) problem, so I’d definitely wait for clarification before signing off on a CI as a newly minted LSRI.

 

[RWoodard]

I am a lawyer, I agree with you, and I don’t even think it’s a particularly close question. Although it’s probably sheer luck that the relevant wording for EABs works with MOSAIC.

On the other hand, the FAA has screwed up equally easy things before, while ignoring real contradictions.

We’re reliably told above that for some reason actual FAA lawyers—the people whose views count (mine don’t)—have convinced themselves that they need to change thousands (?) of op limits due to this (non) problem, so I’d definitely wait for clarification before signing off on a CI as a newly minted LSRI.

I, too, am a lawyer and I agree with Dugaru. I’m not doin’ nuthn’ until I hear a real answer directly from the FAA Office of Legal Counsel or equally [un]reliable source!

As for the question of having an airplane in an LLC, I’d say as it stands now and without words directly from the FAA that beneficial ownership is sufficient, I’d say you have to have the credentials from the full 15 day class. I’m a bit bummed by this as 2 out of 3 of my planes are currently in an LLC. I may end up moving them to solely in my name if this isn’t rewritten or reinterpreted.

 

[Tooch]

It seems to me the FAA would want to save a lot of work so as to not have to redo thousands of operating limits. Let's hope so.

 

[Dugaru]

It seems to me the FAA would want to save a lot of work so as to not have to redo thousands of operating limits. Let's hope so.

You would think, especially since they plainly don’t have to change the op limits. I wish I were more hopeful.

 

[RNB]

OK, the Gubmint is back open, any guesses when the facts of this whole situation will be known/published?

 

[Mel]

OK, the Gubmint is back open, any guesses when the facts of this whole situation will be known/published?

I would never try to guess on Government timelines! Hopefully soon.

Supposedly Order 8130.2l has been written. Now they just need to get it published. and HOPEFULLY it's nothing like 8130.2k was originally.

 

[torquen]

I sent an email to my local FISDO office just before the shutdown. This morning I received a message back. Looks like they don’t quite have the required course of action in place yet so the FISDO can follow. Below is the email back. I’m happy that I received a response that he will be looking into this.


I've done some research on this, and I've reviewed the amendatory instruction 66 for inclusion of the newly implemented 14 CFR §65.109 which expands your privileges under your existing light sport repairman certificate effective October 22nd, 2025. I've also reviewed your existing operating limitations for the subject aircraft. The next step I'm taking is reaching out to our AIR-632 office internally to see if they have any specific procedures or verbiage I need to include in any amended operating limitations I issue for your aircraft to allow usage of your LSA repairman certificate to conduct the condition inspection, as they have not released any notices for FAA order 8130.2K, which is our order containing procedures for issuance of airworthiness certificates, that provide guidance on how I should do that for amendments due to MOSAIC implementation. Please be aware that things are a bit hectic right now with everyone returning from the government shutdown, so I don't know if I'll get a response quickly, but I will make sure we get you taken care of.

Thank you,

 

[Ironflight]

I was in Oshkosh last week attending some committee meetings, and confirmed with the Government Liaison guys that we all just have to be patient. Order 8130.2(L) is essentially ready to be released, and should have the updated verbiage for the Ops Lims. They confirmed that the FAA lawyers interpretation is that the Ops Lims have to be updated to reflect what is now in MOSAIC (it makes no difference how YOU want to interpret it, its the FAA Lawyers interpretation that counts….). The experts at the FAA who were behind MOSAIC are just as frustrated with this interpretation it seems, but we live in a world of rules, so maybe one of them will come up with a memo….we’ll see.

 

[Majorpayne317641]

FYI for anyone trying to apply for an LSR-I for EAB under MOSAIC it is all under a pause until the FAA figures out how to update their forms to start issuing certificates. If you contact your FSDO they will respond that they cannot process certificates for this new rating until further notice. I also confirmed this with Rainbow aviation that is plugged into many FSDOs.

 

[jherzog]

I was in Oshkosh last week attending some committee meetings, and confirmed with the Government Liaison guys that we all just have to be patient. Order 8130.2(L) is essentially ready to be released, and should have the updated verbiage for the Ops Lims. They confirmed that the FAA lawyers interpretation is that the Ops Lims have to be updated to reflect what is now in MOSAIC (it makes no difference how YOU want to interpret it, its the FAA Lawyers interpretation that counts….). The non-payers at the FAA who were behind MOSAIC are just as frustrated with this interpretation it seems, but we live in a world of rules, so maybe one of them will come up with a memo….we’ll see.

Thank you Paul. Was there any discussion regarding LLC-owned EABs and whether the owner of the LLC might be considered the aircraft owner for purposes of the LSA maintenance and inspection certificates?

 

[Majorpayne317641]

Thank you Paul. Was there any discussion regarding LLC-owned EABs and whether the owner of the LLC might be considered the aircraft owner for purposes of the LSA maintenance and inspection certificates?

Maintenance certificate allows you to work on and inspect anyone’s EAB and for compensation.

 

[Ironflight]

Thank you Paul. Was there any discussion regarding LLC-owned EABs and whether the owner of the LLC might be considered the aircraft owner for purposes of the LSA maintenance and inspection certificates?

Not discussed.

 

[jherzog]

Maintenance certificate allows you to work on and inspect anyone’s EAB and for compensation.

Correct -- should have limited my question to the inspection certificate, thanks.

 

[RNB]

FYI for anyone trying to apply for an LSR-I for EAB under MOSAIC it is all under a pause until the FAA figures out how to update their forms to start issuing certificates. If you contact your FSDO they will respond that they cannot process certificates for this new rating until further notice. I also confirmed this with Rainbow aviation that is plugged into many FSDOs.

Argh!

 

[FORANE]

FYI for anyone trying to apply for an LSR-I for EAB under MOSAIC it is all under a pause until the FAA figures out how to update their forms to start issuing certificates. If you contact your FSDO they will respond that they cannot process certificates for this new rating until further notice. I also confirmed this with Rainbow aviation that is plugged into many FSDOs.

Argh!

But, when I contacted my FSDO they said they would put me in the queue. My FSDO said they currently had 4 and were pressuring their superiors for guidance on this before it gets too far behind.

 

[Dugaru]

The experts at the FAA who were behind MOSAIC are just as frustrated with this interpretation it seems,

No doubt because the interpretation is entirely silly. This whole thing is like watching a slow motion bureaucratic train wreck, with someone causing it by throwing a switch that didn’t need to be thrown.

Ah well, I’ve seen worse lawyering.

I wonder if they’re also going to fix the current op lims “problem” with sport pilots flying experimentals, which, though also entirely silly, at least has some basis in the text? I’m guessing not.

 

[torquen]

My fisdo sent out another message today for an update.


I heard back from our AFS-320 branch internally (this branch is responsible for rulemaking in Flight Standards), which is one of the offices I reached out to for information about your inquiry. You and I were correct in our interpretation of the new MOSAIC rules, in that your operating limitations for your EAB will need to be revised in order to allow you to perform the annual condition inspection using your LSA repairman certificate under the new §65.109 rule. However, at this time, there is no guidance available for FSDOs to amend the operating limitations, and as such, I am unable to do so. That being the case, I was told that until said guidance becomes available, stakeholders such as yourself will have to continue having their conditional inspections performed as indicated in their operating limitations (so, an A&P or the EAB Repairman). The original intent was for this guidance to be available to FSDO inspectors to coincide with the implementation of the new rule in October, but the timelines were delayed by the government shutdown, and the responsible offices are working to catch up. My apologies for the inconvenience.

Please feel free to reach out if you have any other questions.

 

[gasman]

My fisdo sent out another message today for an update.

However, at this time, there is no guidance available for FSDOs to amend the operating limitations, and as such, I am unable to do so. That being the case, I was told that until said guidance becomes available, stakeholders such as yourself will have to continue having their conditional inspections performed as indicated in their operating limitations (so, an A&P or the EAB Repairman). The original intent was for this guidance to be available to FSDO inspectors to coincide with the implementation of the new rule in October, but the timelines were delayed by the government shutdown, and the responsible offices are working to catch up. My apologies for the inconvenience.

Please feel free to reach out if you have any other questions.

OH-NO!!

 

[Dugaru]

You and I were correct in our interpretation of the new MOSAIC rules, in that your operating limitations for your EAB will need to be revised in order to allow you to perform the annual condition inspection using your LSA repairman certificate under the new §65.109 rule.

It’s depressing but strangely fascinating to watch in real time as this non-issue turns into an actual problem that will affect people’s daily lives, all based on an interpretation that makes zero sense.

 

[torquen]

It’s depressing but strangely fascinating to watch in real time as this non-issue turns into an actual problem that will affect people’s daily lives, all based on an interpretation that makes zero sense.

It’s literally how the government works. Pass something, lawyer says no and stops it. Lawyers have way to much say in everything these days.

 

[Dugaru]

Pass something, lawyer says no and stops it. Lawyers have way too much say in everything these days.

They also respond to demand. A lot of non-lawyers are apparently convinced there is a legal problem here, when there is none.

 

[RV-9erA]

No doubt because the interpretation is entirely silly. This whole thing is like watching a slow motion bureaucratic train wreck, with someone causing it by throwing a switch that didn’t need to be thrown.

Ah well, I’ve seen worse lawyering.

I wonder if they’re also going to fix the current op lims “problem” with sport pilots flying experimentals, which, though also entirely silly, at least has some basis in the text? I’m guessing not.

In my RV-9A Operational Limitations, issued in 2004 as part of the airworthiness certificate itself, there is a specificacly and formally worded paragraph for performing condition inspections, which states "Repairman or A&P" shall perform condition inspections. In saying this, I think it's okay to have that expanded to LSRI and LSRM people. However, I can also see why the Operational Limitations for an EAB would need to be changed to add these two new maintenance types. We must also remember that an EAB references the "manufacture" as the original builder's name, and that's what the Ops lims apply to.

 

[Dugaru]

In my RV-9A Operational Limitations, issued in 2004 as part of the airworthiness certificate itself, there is a specificacly and formally worded paragraph for performing condition inspections, which states "Repairman or A&P" shall perform condition inspections. In saying this, I think it's okay to have that expanded to LSRI and LSRM people. However, I can also see why the Operational Limitations for an EAB would need to be changed to add these two new maintenance types. We must also remember that an EAB references the "manufacture" as the original builder's name, and that's what the Ops lims apply to.

Does it actually say “shall”?

 

[RV-9erA]

Does it actually say “shall”?

It actually says "must be" -- just looked at mine last week out of curiosity. They appear to be using an FAA boiler-plate form and probably have for some time now. But, I understand that some older Op Lims are not as standardized -- mine was issued in 2004. However, the FAA is the final word on that, and I would be careful not to sign-off on any CI's until that time since the airplane would technically not be airworthy unless the ops lims were expanded.

The actual paragraph:

"This aircraft must undergo a condition inspection within the preceding 12 calendar months to be found in a condition for safe operation. This inspection is the equivalent of an annual inspection for type-certificated aircraft and must be performed by an FAA-certificated repairman (part 65.104 for amateur-built aircraft), a mechanic with an airframe and powerplant rating, or an appropriately rated repair station. The inspection's scope and detail must be in accordance with Appendix D to Part 43, and the results must be recorded in the aircraft's maintenance records with a specific certification statement"

 

[Mel]

In my RV-9A Operational Limitations, issued in 2004 as part of the airworthiness certificate itself, there is a specificacly and formally worded paragraph for performing condition inspections, which states "Repairman or A&P" shall perform condition inspections. In saying this, I think it's okay to have that expanded to LSRI and LSRM people. However, I can also see why the Operational Limitations for an EAB would need to be changed to add these two new maintenance types. We must also remember that an EAB references the "manufacture" as the original builder's name, and that's what the Ops lims apply to.

I just went back through several examples of Op Lims issued in 2004. Been doing this since 1999 and I have never seen the above statement.
All Op Lims list the authority by which the repairman must be authorized. (part 65.104, etc.)

 

[RV-9erA]

I just went back through several examples of Op Lims issued in 2004. Been doing this since 1999 and I have never seen the above statement.
All Op Lims list the authority by which the repairman must be authorized. (part 65.104, etc.)

The actual wording is in my subsequent post. But, it seems like you're "splitting hairs" here and going off topic with respect to the LSRI and LSRM question.

 

[Mel]

The actual wording is in my subsequent post. But, it seems like you're "splitting hairs" here and going off topic with respect to the LSRI and LSRM question.

Yep! I'll be backing out of this. Good luck.
As a last word, I'll bet that these op lims were issued by an ASI, and not a DAR. Faa guys often reword things as opposed to what the Order actually says.

 

[RV-9erA]

Yep! I'll be backing out of this. Good luck.
As a last word, I'll bet that these op lims were issued by an ASI, and not a DAR. Faa guys sometimes reword things as opposed to what the Order says.

Yes -- it was a Seattle FAA MIDO guy for the Airworthiness visit, and a Seattle FAA FSDO guy for the Repairman's visit -- both were very thorough visits! They also do the Boeing inspections on the same airfield (Paine Field in Everett WA).

 

[Dugaru]

It actually says "must be" -- just looked at mine last week out of curiosity. They appear to be using an FAA boiler-plate form and probably have for some time now. But, I understand that some older Op Lims are not as standardized -- mine was issued in 2004. However, the FAA is the final word on that, and I would be careful not to sign-off on any CI's until that time since the airplane would technically not be airworthy unless the ops lims were expanded.

The actual paragraph:

"This aircraft must undergo a condition inspection within the preceding 12 calendar months to be found in a condition for safe operation. This inspection is the equivalent of an annual inspection for type-certificated aircraft and must be performed by an FAA-certificated repairman (part 65.104 for amateur-built aircraft), a mechanic with an airframe and powerplant rating, or an appropriately rated repair station. The inspection's scope and detail must be in accordance with Appendix D to Part 43, and the results must be recorded in the aircraft's maintenance records with a specific certification statement"

I’d agree that, assuming a reg can’t override Op Lims, yours definitely need to be changed before an LSRI or LSRM can do the CI. The ones I’ve seen, which have permissive rather than mandatory wording, don’t.

 

[RV-9erA]

I’d agree that, assuming a reg can’t override Op Lims, yours definitely need to be changed before an LSRI or LSRM can do the CI. The ones I’ve seen, which have permissive rather than mandatory wording, don’t.

Since I do all the CI's on the airplane I built, I don't see any need to have them changed.

Can you provide an example of a recent Op Lims (2000 or newer) that is more permissive than mine, and how does your RV-9A Op Lims read?

It's been a well know FAA regulation for years that either a Repairman who built the EAB or an A&P performs the CI on an EAB.

 

[Tooch]

I just took the course last weekend. This came up of course and an email was sent to all that attended.

Quote "the following is directly from the FAA Aviation Maintenance division (the folks who wrote the maintenance portion of MOSAIC and who are implementing ) Also note- this is not a job the FAA wants- they meet with FAA Legal and discussed all options and determined you MUST comply with your op limits

AGC has stated that a revision to the operating limitation would be required to permit a light-sport repairman to do the annual condition inspection in this case, the intent of this operating limitation is to state specifically who can perform the annual condition inspection on these aircraft, since without such a limitation ANYONE could perform the inspection.
The idea that the use of the word “may” would mean that any operating limitation would be optional or changed, does not align with the regulatory requirement to comply with operating limitations prescribed by the FAA (see 91.9(a)).

While FAA order 8900.1 defines the terms “should” and “may”, those definitions are limited to the order itself and should not be applied to operating limitations."

So mine will have to be changed. So I called my local FISDO yesterday. They are going to get back to me after the holiday to schedule an appointment. They sounded like it was no big deal to change the limitations. Yeah, we may have to wait a bit but I think this is not as big of a deal as we are making it. IMHO

 

[RNB]

I just took the course last weekend. This came up of course and an email was sent to all that attended.

Quote "the following is directly from the FAA Aviation Maintenance division (the folks who wrote the maintenance portion of MOSAIC and who are implementing ) Also note- this is not a job the FAA wants- they meet with FAA Legal and discussed all options and determined you MUST comply with your op limits

AGC has stated that a revision to the operating limitation would be required to permit a light-sport repairman to do the annual condition inspection in this case, the intent of this operating limitation is to state specifically who can perform the annual condition inspection on these aircraft, since without such a limitation ANYONE could perform the inspection.
The idea that the use of the word “may” would mean that any operating limitation would be optional or changed, does not align with the regulatory requirement to comply with operating limitations prescribed by the FAA (see 91.9(a)).

While FAA order 8900.1 defines the terms “should” and “may”, those definitions are limited to the order itself and should not be applied to operating limitations."

So mine will have to be changed. So I called my local FISDO yesterday. They are going to get back to me after the holiday to schedule an appointment. They sounded like it was no big deal to change the limitations. Yeah, we may have to wait a bit but I think this is not as big of a deal as we are making it. IMHO

The key thing I and likely everyone is looking for is for the first one to be changed and/or some click here link on a FAA site to get this done. Until then, it is all just hopium.

 

[Dugaru]

The idea that the use of the word “may” would mean that any operating limitation would be optional or changed, does not align with the regulatory requirement to comply with operating limitations prescribed by the FAA (see 91.9(a)).

Would love to see the legal reasoning behind this “does not align with the regulatory requirement” claim (whatever it means).

If the op limits identify two categories of persons who “may” do the CI, and a reg then simply adds two more, how exactly am I out of compliance with 92.9(a) when one of the new categories does the CI?

Only the FAA’s views count, obviously. But they are inexplicably making work for themselves (and everyone else) with respect to any ops limits that use the “may” language.

 

[Dugaru]

Since I do all the CI's on the airplane I built, I don't see any need to have them changed.

If you ever sell it, having language permitting an LSRI or LSRM to do the CI would probably be valuable. Like so many things in life, it won't matter if you never sell.

Can you provide an example of a recent Op Lims (2000 or newer) that is more permissive than mine, and how does your RV-9A Op Lims read?

Here's one somebody posted here, although I don't actually know the date. I'll grab mine when I'm next in the hangar.


FWIW, the FAA seems to think this is typical language:

Currently, operating limitations issued to EAB aircraft provide that an appropriately rated mechanic, a repair station, or the holder of a repairman certificate (experimental aircraft builder) issued in accordance with § 65.104 may perform a condition inspection on an EAB aircraft.

(MOSAIC Final Rule p. 431) (emphasis added). Although to be sure, I'm not going to suggest the FAA actually surveyed existing op lims before making this statement. Your op limits indicate there is quite a bit of variation out there....

I guess we just get to sit back and watch the red tape descend. I plan to do my part: I solemnly swear I will not make the problem worse by writing the FAA counsel to ask how sport pilots can fly EABs consistent with their operating limits.

 

[RV-9erA]

An observation on the word "may" -- unlike "type certified" aircraft that specifically require an A&P IA to sign-off annual inspections, the FAA relaxes the annual condition inspection requirements for EAB aircraft to either appropriately rated mechanic (A&P), repairman experimental builder (part 65.104) or appropriately rated "repair station" (FAA designated). So, I think the word "may" reflects the "relaxed requirement" while fully meaning repairman part 65.104, appropriately rated mechanic" (A&P) or FAA designated repair station (i.e. instead of being limited to only an A&P IA, you "may" now use a repairman part 65.104, appropriately rated mechanic" (A&P) or FAA designated repair station), which is one of the great benefits of building and/or owning an EAB. So, expanding this to LSRI or LSRM under MOSAIC should also be another great step forward, assuming EAB aircraft are kept in "a condition for safe operation", which is also included in most Op Lims.

 

[kevinb73]

Since the government reopened, I've been waiting for a call back from the FSDO to get the LSRI certificate (I took the 2 day class last month), and to ask about the Operating Limitations issue. They just called me back and told me this:

1. They just received an internal FAA email today saying "Do not issue any light sport repairman certificates at this time". He said they were to reject any applications until the FAA releases a new version of the 8610 form.
2. He said that I will need the operating limitations changed to allow the LSRI to do the condition inspection, but they can't do it until their internal system has the updated language that they can select. He said they cannot change anything in the paragraph about inspections until then.

It's really disappointing because I am out of annual right now, and it looks like I'll need to pay for an A&P to do it one more time.

 

[docjjrmd]

Since the government reopened, I've been waiting for a call back from the FSDO to get the LSRI certificate (I took the 2 day class last month), and to ask about the Operating Limitations issue. They just called me back and told me this:

1. They just received an internal FAA email today saying "Do not issue any light sport repairman certificates at this time". He said they were to reject any applications until the FAA releases a new version of the 8610 form.
2. He said that I will need the operating limitations changed to allow the LSRI to do the condition inspection, but they can't do it until their internal system has the updated language that they can select. He said they cannot change anything in the paragraph about inspections until then.

It's really disappointing because I am out of annual right now, and it looks like I'll need to pay for an A&P to do it one more time.

Sounds like bureaucracy not liking that their cheese moved. The ship of state is large and changing direction requires a lot of energy to overcome inertia.

 

[Aviator]

Since the government reopened, I've been waiting for a call back from the FSDO to get the LSRI certificate (I took the 2 day class last month), and to ask about the Operating Limitations issue. They just called me back and told me this:

1. They just received an internal FAA email today saying "Do not issue any light sport repairman certificates at this time". He said they were to reject any applications until the FAA releases a new version of the 8610 form.
2. He said that I will need the operating limitations changed to allow the LSRI to do the condition inspection, but they can't do it until their internal system has the updated language that they can select. He said they cannot change anything in the paragraph about inspections until then.

It's really disappointing because I am out of annual right now, and it looks like I'll need to pay for an A&P to do it one more time.

I am in the same predicament. I am doing the CI now and waiting for the "new" language .....
I have the LSRI-A certificate.

 

[Ironflight]

Sounds like bureaucracy not liking that their cheese moved. The ship of state is large and changing direction requires a lot of energy to overcome inertia.

Well….a LOT of paperwork piles up on a desk - especially at an agency that is already underfunded for the work it is tasked to do - in a month. And let’s face it - the priority at the FAA is commercial - passenger and freight - safety and regulation, not taking care of the 0.14% of the US population that have pilot licenses, so we wait on them getting done with the high priority stuff. I do DAR work for a company that provides aggressor aircraft to Navy Fallon and USAF Nellis operations, and we’re waiting on someone at the FSDO to stamp a maintenance program document so I can inspect an F-5 and get it flying…and that’s for a military contractor who has phone numbers for folks in Washington! Us private operators…..well….

My understanding is that the next version of 8130.2 (with the correct language for MOSAIC) was ready for release when the shutdown happened, and they are probably just trying to dig down to it to get it out.

 

[Dugaru]

He said that I will need the operating limitations changed to allow the LSRI to do the condition inspection

Was he able to explain WHY? That could be fun to hear, depending on what your operating limitations say.

 

[Mel]

Was he able to explain WHY? That could be fun to hear, depending on what your operating limitations say.

Because current Operating Limitations do not allow it. Current op lims state:

"An experimental aircraft builder certificated as a repairman for this aircraft under §65.104, or an appropriately rated FAA-certificated mechanic, may perform the condition inspection required by these operating limitations. (18)"

Wording says that a repairman certificated under §65.104 may do it. It also says that an A&P may do it. It does NOT say that a repairman certificated under §65.107 may do it!