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Mosaic Rule and Repairman Certificate

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SATCFI

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I didn't build my RV-6A but would like to be authorized to conduct and sign off the annual condition inspection. The proposed MOSAIC rule allows non-builder owners of experimental aircraft to take a 16 Hour Repairman's course after which they would be authorized to do the annual condition inspection.

Does anyone have any insight on where I could take this course? Seems with this new rule, a new Van's cottage industry might spring up.
 
Could someone point me to where it says that Eab is included "expanded" in mosaic for being able to get a repairman/inspection cert to conduct yearly condition inspections.
 
pr1malr8ge said:
Could someone point me to where it says that Eab is included "expanded" in mosaic for being able to get a repairman/inspection cert to conduct yearly condition inspections.
Click to expand...
"Pointed" to the rule below. Look for EAB. Mid 400s.

Are you just in disbelief even though It's posted in at least a couple threads here? It's and not that hard to find in the rule. If you expect to get the cert and do inspections you're going to have to be able to find things in the regs.

 
N8DAV8R said:
"Pointed" to the rule below. Look for EAB. Mid 400s.

Are you just in disbelief even though It's posted in at least a couple threads here? It's and not that hard to find in the rule. If you expect to get the cert and do inspections you're going to have to be able to find things in the regs.

Click to expand...

U so friendly today
p.430 seems to get into the weeds on this
 
N8DAV8R said:
"Pointed" to the rule below. Look for EAB. Mid 400s.

Are you just in disbelief even though It's posted in at least a couple threads here? It's and not that hard to find in the rule. If you expect to get the cert and do inspections you're going to have to be able to find things in the regs.

Click to expand...
I'm sorry I just came across this and hadn't had a chance to look into it at the time I posted asking for it. I have since found it and am ecstatic on this change.
 
Hey sorry—I posted a separate thread I should stay here.


I’ve been trying to wrap my head around the LSRM stuff in the new MOSAIC rule. At first I thought it had to be the 120-hour course to do condition inspections on EABs, but reading through this thread, it’s starting to sound like maybe the 16-hour course covers more than I thought?

What’s tripping me up is the difference between the Sport Pilot flying privileges expanding under MOSAIC, versus what the repairman certificate actually allows for maintenance. It feels like a lot of that’s getting blurred together.


Maybe I’m just making it more complicated than it is—but curious if anyone’s looked closely at how that breaks down.

Thank Matt
 
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mr_matt said:
Hey sorry—I posted a separate thread I should stay here.


I’ve been trying to wrap my head around the LSRM stuff in the new MOSAIC rule. At first I thought it had to be the 120-hour course to do condition inspections on EABs, but reading through this thread, it’s starting to sound like maybe the 16-hour course covers more than I thought?

What’s tripping me up is the difference between the Sport Pilot flying privileges expanding under MOSAIC, versus what the repairman certificate actually allows for maintenance. It feels like a lot of that’s getting blurred together.


Maybe I’m just making it more complicated than it is—but curious if anyone’s looked closely at how that breaks down.

Thank Matt
Click to expand...
It is my understanding that the 16hr course + FSDO issued repairman cert will allow you to sign yearly CIs on an EAB/LSA that you own. From what I have read [this is for everyone's reference] That even if you don't own an EAB at this moment, you can take the 16hr course and gain a completion certificate that never expires. At anytime after the course you become a verifiable owner of an EAB/LSA [*ownership must be in your name and NOT in an LLC] you can then go to your local fsdo and apply for the repairman certificate for that aircraft and at anytime after any other EAB/LSA that you purchase [*ownership must be in your name and NOT an LLC] can be added to your repairman certificate. The 120hr course is so that you can work on and sign CIs for any EAB/LSA regardless of ownership.

I do hope what I type is correct. If not please correct me so as I can alter/change/delete if needed. *e1 added LLC as not qualified
 
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pr1malr8ge said:
It is my understanding that the 16hr course + FSDO issued repairman cert will allow you to sign yearly CIs on an EAB/LSA that you own. From what I have read [this is for everyone's reference] That even if you don't own an EAB at this moment, you can take the 16hr course and gain a completion certificate that never expires. At anytime after the course you become a verifiable owner of an EAB/LSA you can then go to your local fsdo and apply for the repairman certificate for that aircraft and at anytime after any other EAB/LSA that you purchase can be added to your repairman certificate. The 120hr course is so that you can work on and sign CIs for any EAB/LSA regardless of ownership.

I do hope what I type is correct. If not please correct me so as I can alter/change/delete if needed.
Click to expand...
Hey, thanks great input I’ll research that now. I hadn’t thought of that.

Matt.
 
Also a small point of clarification. If the airplane you are trying to get the cert for is in an LLC, you can not apply for it as the cert holder technically doesn't own it. You have to get the 120hr course if you elect to keep it in the LLC. Then you can do any eab whether owned or not
 
I think the following comments make it clear that the FAA only expanded the repairman certif to include condition inspections on EAB aircraft that the holder to the repairman certif built.

Comment page 432-433:
When an EAB aircraft is sold by the original builder, the builder’s
repairman certificate (experimental aircraft builder) privileges are still valid for the
aircraft (by make, model, and serial number); however, the new owner does not have the
option to get a repairman certificate (experimental aircraft builder) because the new
owner is not the builder of the aircraft. This results in the new owner lacking eligibility
for a repairman certificate (experimental aircraft builder) and having to obtain the
services of a certificated mechanic or repair station to perform the required condition
inspection on their EAB aircraft.

FAA agrees with commenters’ suggestions and finds there is a safety benefit in
permitting additional properly trained and certificated repairmen to perform condition
inspections on EAB aircraft because it will be easier for owners to find qualified
personnel to conduct required inspections. Therefore, this final rule expands the
privileges of a light-sport repairman certificate under § 65.109 to allow a certificate
holder, with either rating (inspection or maintenance), to perform the annual condition
inspection on an EAB aircraft issued an experimental airworthiness certificate under
§ 21.191(g).

The changes adopted in § 65.109(a) and (b) of this final rule do not impose
additional restrictions but rather expand the privileges of a light-sport repairman.
Specifically, § 65.107(c) will allow a light-sport repairman with an inspection rating to
perform the annual condition inspection on an EAB aircraft that is owned by the
repairman and that is in the same category of aircraft for which the certificate holder was
trained.271 In addition, § 65.109(b) will permit a light-sport repairman with a maintenance
rating to perform the annual condition inspection on an EAB aircraft that is in the same
category of aircraft for which the certificate holder was trained.

Footnote 279:
An individual who shows to FAA evidence of building the major portion of an aircraft are eligible to
obtain a repairman certificate (experimental aircraft builder), with privileges limited to the aircraft that
person has built. FAA considers these individuals to have demonstrated acceptable knowledge of the
aircraft and able to perform a condition inspection because the individual built the major portion of an
aircraft that was found safe for flight by FAA and subsequently issued an airworthiness certificate.
 
talon167 said:
I think the following comments make it clear that the FAA only expanded the repairman certif to include condition inspections on EAB aircraft that the holder to the repairman certif built.

Comment page 432-433:
When an EAB aircraft is sold by the original builder, the builder’s
repairman certificate (experimental aircraft builder) privileges are still valid for the
aircraft (by make, model, and serial number); however, the new owner does not have the
option to get a repairman certificate (experimental aircraft builder) because the new
owner is not the builder of the aircraft. This results in the new owner lacking eligibility
for a repairman certificate (experimental aircraft builder) and having to obtain the
services of a certificated mechanic or repair station to perform the required condition
inspection on their EAB aircraft.

FAA agrees with commenters’ suggestions and finds there is a safety benefit in
permitting additional properly trained and certificated repairmen to perform condition
inspections on EAB aircraft because it will be easier for owners to find qualified
personnel to conduct required inspections. Therefore, this final rule expands the
privileges of a light-sport repairman certificate under § 65.109 to allow a certificate
holder, with either rating (inspection or maintenance), to perform the annual condition
inspection on an EAB aircraft issued an experimental airworthiness certificate under
§ 21.191(g).

The changes adopted in § 65.109(a) and (b) of this final rule do not impose
additional restrictions but rather expand the privileges of a light-sport repairman.
Specifically, § 65.107(c) will allow a light-sport repairman with an inspection rating to
perform the annual condition inspection on an EAB aircraft that is owned by the
repairman and that is in the same category of aircraft for which the certificate holder was
trained.271 In addition, § 65.109(b) will permit a light-sport repairman with a maintenance
rating to perform the annual condition inspection on an EAB aircraft that is in the same
category of aircraft for which the certificate holder was trained.

Footnote 279:
An individual who shows to FAA evidence of building the major portion of an aircraft are eligible to
obtain a repairman certificate (experimental aircraft builder), with privileges limited to the aircraft that
person has built. FAA considers these individuals to have demonstrated acceptable knowledge of the
aircraft and able to perform a condition inspection because the individual built the major portion of an
aircraft that was found safe for flight by FAA and subsequently issued an airworthiness certificate.
Click to expand...
Note that § 21.191(g) only applies to the person who built the EAB aircraft:
(g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.
 
And I'm not sure of your question, but with the short course, you have to own it, if you sell it, you don't own it any longer and can't do the conditional on it
 
My point is the original post is incorrect. MOSAIC does not permit a person who owns an EAB, but did not build the EAB, to get a repairman certificate that will permit the non-builder owner to perform the annual inspection. MOSAIC only extends that privilege to original builders who own the aircraft they built that receive the requisite training.
 
talon167 said:
Note that § 21.191(g) only applies to the person who built the EAB aircraft:
(g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.
Click to expand...
talon167 said:
My point is the original post is incorrect. MOSAIC does not permit a person who owns an EAB, but did not build the EAB, to get a repairman certificate that will permit the non-builder owner to perform the annual inspection. MOSAIC only extends that privilege to original builders who own the aircraft they built that receive the requisite training.
Click to expand...

You are trying to connect too many dots.

The definition in 21.191 is what it is, and what an EAB always has been. An aircraft built for education and recreation. What you pasted is creating limitations that flow to other regs, it's defining an operating amateur-built aircraft.

You can swim upstream all you want but the new inspection authorizations for Repairman with Inspection or Maintenance ratings is well understood. Inspection authorizes an owned airplane, Maintenance authorization includes non-owned EAB.
 
talon167 said:
My point is the original post is incorrect. MOSAIC does not permit a person who owns an EAB, but did not build the EAB, to get a repairman certificate that will permit the non-builder owner to perform the annual inspection. MOSAIC only extends that privilege to original builders who own the aircraft they built that receive the requisite training.
Click to expand...
Pretty sure that is not true with the new changes. If you bought an eab, and it confirms to the LSA 2.0 rule changes, you *can* take the short LSA maint course and request from the FSDO that the eab you bought be listed under that LSA repair cert and you can then do the conditionals on it. That was the new thing and it's been discussed both by the eaa, FAA, and others as a noteable change.
 
talon167 said:
The changes adopted in § 65.109(a) and (b) of this final rule do not impose
additional restrictions but rather expand the privileges of a light-sport repairman.
Specifically, § 65.107(c) will allow a light-sport repairman with an inspection rating to
perform the annual condition inspection on an EAB aircraft that is owned by the
repairman and that is in the same category of aircraft for which the certificate holder was
trained.271 In addition, § 65.109(b) will permit a light-sport repairman with a maintenance
rating to perform the annual condition inspection on an EAB aircraft that is in the same
category of aircraft for which the certificate holder was trained.
Click to expand...
LSRI does not require one to be a builder. It only requires a 16hr FAA approved course and to be an owner of the airframe to be signed off for a CI
 
aadamson said:
Pretty sure that is not true with the new changes. If you bought an eab, and it confirms to the LSA 2.0 rule changes, you *can* take the short LSA maint course and request from the FSDO that the eab you bought be listed under that LSA repair cert and you can then do the conditional s on it. That was the new thing and it's been discussed both by the eaa, FAA, and others as a noteable change.
Click to expand...

Sorry, a technical correction is needed here. It's important that people understand there are two authorization under the Repairman rating, Inspection and Maintenance, in order to avoid poor communication. You have said "LSA maint course" but the second half refers to a requirement of the LSA Inspection course.

Inspection - Short course -> The EAB needs to be owned by the Repairman and listed via FSDO
Maintenance -> Long Course -> The EAB need not be owned by the Repairman and there is no need to list individual aircraft.
 
My understanding is that the EAB does not have to comply with the LSA rules. It just says EAB under blah, blah, blah. What we consider normal EAB aircraft. Not warbirds or turbines or anything unusual. Therefore, any EAB owner who completes the 16 hour course will be able to conduct their condition (not conditional) inspection on any EAB aircraft they own.
 
The problem is that the FAA did not amend § 21.191(g) to include anyone other than EAB aircraft's builder. As they explain in the footnote I quoted, the FAA did the expansion to including the builder because, having built the aircraft, they have a special knowledge base that supports expanding inspections to them when combined with the new formal training requirement. Nowhere does the FAA talk about in the comments any intent, desire, or justification to expand annual EAB inspection privileges to people who own an EAB, but did not build the EAB to the extent specified in § 21.191(g).
 
talon167 said:
The problem is that the FAA did not amend § 21.191(g) to include anyone other than EAB aircraft's builder. As they explain in the footnote I quoted, the FAA did the expansion to including the builder because, having built the aircraft, they have a special knowledge base that supports expanding inspections to them when combined with the new formal training requirement. Nowhere does the FAA talk about in the comments any intent, desire, or justification to expand annual EAB inspection privileges to people who own an EAB, but did not build the EAB to the extent specified in § 21.191(g).
Click to expand...
There is no reason for them to change anything in 21.191. That is where the types of experimental certificates is described. There is no change to the types of certificates. You are making a connection to the authorization to inspect in a place where it would not exist.

If I have to go find things for you, then you owe me a burrito.
 
Direct from the Federal Register:
This results in the new owner lacking eligibility for a repairman certificate (experimental aircraft builder) and having to obtain the services of a certificated mechanic or repair station to perform the required condition inspection on their EAB aircraft.

FAA agrees with commenters' suggestions and finds there is a safety benefit in permitting additional properly trained and certificated repairmen to perform condition inspections on EAB aircraft because it will be easier for owners to find qualified personnel to conduct required inspections. Therefore, this final rule expands the privileges of a light-sport repairman certificate under § 65.109 to allow a certificate holder, with either rating (inspection or maintenance), to perform the annual condition inspection on an EAB aircraft issued an experimental airworthiness certificate under § 21.191(g).2
Click to expand...

Also, you will be able to get your certificate as soon as you finish the class!
FAA will no longer require an applicant for a light-sport repairman certificate to show evidence of aircraft ownership and will not deny a certificate or rating based on whether an applicant owns an aircraft certificated in accordance with § 21.191(g), (i), (k), or (l). Though not discussed in the NPRM, this is a change to internal policy and does not impose new burdens or obligations to the regulated community, nor does this change affect existing or future certificate privileges. Ownership is not a certificate or rating eligibility requirement specified in § 65.107(b); rather, ownership is a requirement to exercise the privileges of an inspection rating, as specified in adopted § 65.109(a). Furthermore, applicants will not be asked to provide, and repairman certificates (light-sport) will not be issued with, aircraft registration number (N-number) and serial number (S/N) information of aircraft owned by the applicant.
Click to expand...
(no burrito required)
 
talon167 said:
Nowhere does the FAA talk about in the comments any intent, desire, or justification to expand annual EAB inspection privileges to people who own an EAB, but did not build the EAB to the extent specified in § 21.191(g).
Click to expand...
21.191(g) has nothing to do with it. This expansion is discussed repeatedly throughout the MOSAIC final rule starting on page 8.
 
talon167 said:
The problem is that the FAA did not amend § 21.191(g) to include anyone other than EAB aircraft's builder. As they explain in the footnote I quoted, the FAA did the expansion to including the builder because, having built the aircraft, they have a special knowledge base that supports expanding inspections to them when combined with the new formal training requirement. Nowhere does the FAA talk about in the comments any intent, desire, or justification to expand annual EAB inspection privileges to people who own an EAB, but did not build the EAB to the extent specified in § 21.191(g).
Click to expand...
Pg 423. Included below.

Start with the highlighted language in the first paragraph. This is a clear statement of intent if you can read English. The FAA says it will be 'easier for owners to find qualified personnel to conduct required inspections'. This is different than saying 'easier for owners to be qualified to do their own inspections.

In the second paragraph, the inspection rating is mentioned with a limitation on ownership. The maintenance rating is mentioned without that restriction. Inspection and Maintenance ratings are different things and are thus described differently. The different authorization levels are created by *restricting* the Inspection rating.

Someday when we find ourselves in the same place at the same time I prefer pastor, spicy, with everything.

Screenshot 2025-07-24 at 11.30.47 AM.png
 
With the expansion of aircraft eligible for Light Sport privileges under MOSAIC, it would seem that any newly accepted E-AB aircraft that meets the Light Sport criteria should be eligible for the same operating and maintenance privileges—including condition inspections by the holder of a repairman certificate, if applicable.

If different rules were intended for these newly included aircraft, one would expect an explicit exception or clarification in the regulation text.


Has anyone seen anything that says otherwise?
 
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talon167 said:
The problem is that the FAA did not amend § 21.191(g) to include anyone other than EAB aircraft's builder. As they explain in the footnote I quoted, the FAA did the expansion to including the builder because, having built the aircraft, they have a special knowledge base that supports expanding inspections to them when combined with the new formal training requirement. Nowhere does the FAA talk about in the comments any intent, desire, or justification to expand annual EAB inspection privileges to people who own an EAB, but did not build the EAB to the extent specified in § 21.191(g).
Click to expand...

I think you are reading different source material than what I read.
 
pr1malr8ge said:
It is my understanding that the 16hr course + FSDO issued repairman cert will allow you to sign yearly CIs on an EAB/LSA that you own. From what I have read [this is for everyone's reference] That even if you don't own an EAB at this moment, you can take the 16hr course and gain a completion certificate that never expires. At anytime after the course you become a verifiable owner of an EAB/LSA [*ownership must be in your name and NOT in an LLC] you can then go to your local fsdo and apply for the repairman certificate for that aircraft and at anytime after any other EAB/LSA that you purchase [*ownership must be in your name and NOT an LLC] can be added to your repairman certificate. The 120hr course is so that you can work on and sign CIs for any EAB/LSA regardless of ownership.

I do hope what I type is correct. If not please correct me so as I can alter/change/delete if needed. *e1 added LLC as not qualified
Click to expand...
EDIT: Still digging, but I just hit something in the preamble that’s about as clear as it gets. Federal Register, July 17, 2024, page 50832:


“The 16-hour course will not qualify a person to perform a condition inspection on an experimental amateur-built aircraft they did not build.”


It’s not in the reg text itself—it’s here in the commentary.


EDIT 2:
This is the reg created by MOSAIC for the 16-hour certificate. The key part is in paragraph (b):

“A person who holds a repairman certificate (light-sport aircraft: inspection) may perform the annual condition inspection on an experimental light-sport aircraft that is owned by the holder of the certificate and identified by aircraft serial number on the certificate.”

This line sets two hard conditions:
  1. The aircraft must be an E-LSA, not an EAB.
  2. The certificate is aircraft-specific, by serial number.


I’m still digging if I was if I was a baseball player, I’d be batting about .400 now so I’d be great, on here not so much
 
mr_matt said:
EDIT: Still digging, but I just hit something in the preamble that’s about as clear as it gets. Federal Register, July 17, 2024, page 50832:

“The 16-hour course will not qualify a person to perform a condition inspection on an experimental amateur-built aircraft they did not build.”
Click to expand...
July 17, 2024 is a year before the MOSAIC final draft was released. I don't know what you're reading, but it's not the new MOSAIC.

In July 2024 that statement was true. Please, read 65.109(a)(1) in the regulation that came out THIS week, not something from last year.
 
mr_matt said:
EDIT 2:
This is the reg created by MOSAIC for the 16-hour certificate. The key part is in paragraph (b):

“A person who holds a repairman certificate (light-sport aircraft: inspection) may perform the annual condition inspection on an experimental light-sport aircraft that is owned by the holder of the certificate and identified by aircraft serial number on the certificate.”

This line sets two hard conditions:
  1. The aircraft must be an E-LSA, not an EAB.
  2. The certificate is aircraft-specific, by serial number.
Click to expand...
What are you quoting from? I can't find the phrase "and identified by aircraft serial number on the certificate" in ANY regulation. Please see this paragraph from the actual final MOSAIC.
 
Here’s my take…. I did not build plane, so I cannot get a repairman certificate. But my buddy did build his, and has a repairman certificate already. But now he can get a maintenance add-on, which will allow him to do CI on my plane,since it’s the same type. So I don’t have to find an A&P to do it. Is this correct?
 
edhunter said:
Here’s my take…. I did not build plane, so I cannot get a repairman certificate. But my buddy did build his, and has a repairman certificate already. But now he can get a maintenance add-on, which will allow him to do CI on my plane,since it’s the same type. So I don’t have to find an A&P to do it. Is this correct?
Click to expand...
Not quite. You can take the course and do your own ci. He can't because he doesn't own it ... Unless he takes the more indepth course, then he could do LSA, eab, etc of anyones .. neither of which have anything to do with model number.
 
edhunter said:
Here’s my take…. I did not build plane, so I cannot get a repairman certificate. But my buddy did build his, and has a repairman certificate already. But now he can get a maintenance add-on, which will allow him to do CI on my plane,since it’s the same type. So I don’t have to find an A&P to do it. Is this correct?
Click to expand...
His repairman certificate is not relevant, except for inspecting his airplane. MOSAIC does not extend his inspection auth in any way.

You can take the short course, currently 2 days, and have the equivalent inspection auth that he does. CI on your own plane.

Either of you could take the longer course, currently 15 days of instruction, and inspect any EAB.
 
My shorthand is on obvious way too short...lol. (I just have drawn tired of those who won't read the other posts or the actual documents ..). Sorry, just being honest
 
This is killing me. Only a government agency can put out hundreds of pages of guidance with enough extra words such that 10 people reading the same thing walk away with 10 different interpretations.

The question most of us have:
- A pilot has an RV that he/she did not build. Can that owner now sign off Condition Inspections and if so what actions does he/she need to take to do so?

Perhaps there is an FAA engineer that can translate the pages of stuff into a very few bullet points to answer this question.

Carl
- A simplistic, bullet point guy
- I have three, soon to be four Repairman Certifications so have no horse in this race other than for the people now flying my earlier builds
 
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Carl Froehlich said:
This is killing me. Only a government agency can put out hundreds of pages of guidance with enough extra words such that 10 people reading the same thing walk away with 10 different interpretations.

The question most of us have:
- A pilot has an RV that he/she did not build. Can that owner now sign off Conditional Inspections and if so what actions does he/she need to take to do so?

Perhaps there is an FAA engineer that can translate the pages of stuff into a very few bullet points to answer this question.

Carl
- A simplistic, bullet point guy
- I have three, soon to be four Repairman Certifications so have no horse in this race other than for the people now flying my earlier builds
Click to expand...
The document can be a challenge but the answer to the question that you have is not that complicated and has been posted at least a dozen times on this forum by now. One example is right here, 2 posts above yours.

The problem is not that 10 people are reading and walking away with different interpretations. It's that for every 1 person reading it, 9 others are pretending that they did and posting guesses or their own imaginary version of how they think it should work. Muddying the water and creating doubt and confusion where it is not necessary.
 
Wait a tick... there is now a thing called a "conditional inspection"? What regulation is THAT in?
 
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