Will there ever be an EAB version of FAA LSRI?

[FORANE]

Ref: 14 CFR §65.107

The FAA established the ELSI "repairman (light sport) with an Inspection rating” (LSRI) for light sport pilots. This is a 16 hour inspection course for any light sport you own or purchase in the future. Completion of this course allows non-builder owners to complete the condition inspection for their LSA.

Will there ever be a version of this for EAB aircraft?

 

[RV6_flyer]

Ref: 14 CFR §65.107

The FAA established the ELSI "repairman (light sport) with an Inspection rating” (LSRI) for light sport pilots. This is a 16 hour inspection course for any light sport you own or purchase in the future. Completion of this course allows non-builder owners to complete the condition inspection for their LSA.

Will there ever be a version of this for EAB aircraft?

NO.

To be licenced as a Light Sport, the aircraft must be assembled by approved instructions with approved materials. Amateur Built does not have required assembly instructions and required materials.

 

[airguy]

NO.

To be licenced as a Light Sport, the aircraft must be assembled by approved instructions with approved materials. Amateur Built does not have required assembly instructions and required materials.

Correct.

To expand a bit - for the Light Sport category, there are a limited number of things that are expected to be seen during the inspection because of the limited number of things used during the build. In the EAB world, there is no limit to the ways the build could have occurred, so there is literally no limit to the things you would have to look for in an inspection. Hence the current requirement to either be the builder and get the repairmans certificate, or be a full A&P.

 

[Mark33]

My 2 cents

I’ve always found this rule/regulation to be too restrictive. I understand the line of thinking that all of these experimental’s are all built a little bit different from each other; even of the same type airframe, but I still see room to modify the rules.

It really doesn’t make sense to me that you’re able to work on your airplane all year long, make as many modifications/changes as you want to, know your airplane inside and out, but once a year have to have a total stranger (ie an A&P) that knows absolutely nothing about your airplane or possibly even your particular type of airframe, come look it over and give it their blessing and sign the logbook. This is literally just a snapshot in time and all they’re saying is that it’s airworthy on that one day out of the year. That makes no that makes no sense to me!

In my humble opinion it would make much more sense if the owner of an experimental aircraft that he/she didn’t build could go take a course….maybe an intensive 40-80 hour long course, that would not only teach them how to do proper ongoing maintenance of their aircraft but to also give them the privilege to be able to do the annual condition inspection on their own aircraft. Once again, this is just my opinion and I know they’ll be people that’ll argue the point I’m trying to make….but I digress.

 

[Untainted123]

I agree that in the ideal case, what you said would be reasonable. But, regulations work from a lowest common denominator mindset; so instead of

you’re able to work on your airplane all year long, make as many modifications/changes as you want to, know your airplane inside and out, but once a year have to have a total stranger (ie an A&P) that knows absolutely nothing about your airplane or possibly even your particular type of airframe, come look it over and give it their blessing and sign the logbook.

imagine instead it's

you’re able to work on your airplane all year long, doing god knows what, have no clue how airplanes or airframes should be maintained, didn't learn your airplane inside and out, but once a year have to have a total stranger (ie an A&P) that knows at least something about proper airframe construction and maintenance, come look it over and give it their blessing and sign the logbook.

That's where the regulations are coming from. As stated earlier, in RV world this seems restrictive because most of the RV'ers I have met are high-quality minded people, but there are lots and lots of one-offs and sketchy EAB designs and aircraft not built even close to the design. The regulations are hoping by having at least a touchpoint once a year, and a 2nd set of eyes, even if there was "interesting" decisions during the year, they are caught and rectified.

To keep this RV related somewhat, and also out of curiosity: has anyone here used their build and mx log to acquire an A&P cert? I had vaguely entertained this idea, as another way to justify the time and expense of building, but all roads kept leading to "attend this school for 2 years and work for an IA after that". From what I gather, it's theoretically possible, but unlikely and more hassle than it's worth?

 

[Mark33]

……But, regulations work from a lowest common denominator mindset;……

I understand the “lowest common denominator” line of thinking…..but I still argue that there should at least be an alternative avenue to go down for those of us that’s willing to put in the extra effort.

 

[BobTurner]

I understand the “lowest common denominator” line of thinking…..but I still argue that there should at least be an alternative avenue to go down for those of us that’s willing to put in the extra effort.

There is an alternative: go to A&P school. I think you meant ‘an easy alternative’. That’s unlikely to happen, unless you can get the FAA to relax the inspection standards for all non-builder owned aircraft, e.g., 172’s as well as eab.

 

[Mcmark]

Being Experimental AB, you as the owner can do maintenance on your airplane. Keep a copy of 43.13 in your library and use it. You will need your A&P to be on board with the maintenance you've done. Asking around for an A&P who is willing to work on EAB may take some effort but would be advantageous to both parties.
As an A&P, I'd rather have an owner that is willing and does look after their airplane. I don't want to do an end of year squawk list to anybody's airplane including my own. Having the owner assist with the inspection lets me know their interest and willingness to keep their airplane in airworthy condition.

 

[Tankerpilot75]

Not all A&Ps are equal

I’m one of those people who purchased their RV from the original builder. He had done all his own maintenance and condition inspections on the aircraft before selling it to me. As I mentioned several times in other forum posts, the aircraft had numerous build quality issues that required extensive efforts over a two year span to identify and resolve.

Over the years several A&Ps, some with IAs, have done my condition inspection with me working beside them just about every step of the way. It’s been a real learning curve and eye opener. Every year I also work on the aircraft without an A&P looking over my shoulder - BUT during the condition inspection I identify what’s been done and ask them to review my work. Early on their reviews identified issues they wanted corrected, but lately they’ve only complimented me on the quality of my efforts.

What I’ve also observed is that every A&P and A&P/IA that’s ever worked on my RV has his own criteria for what’s important and what’s considered “best practice.” It seems the less familiar they are with RV aircraft the more they concentrate their attention and focus to FWF concerns. Very few are interested in what’s been done behind the instrument panel or under the seat panels. Those with EAB experience (and particularly RV aircraft) the greater the likelihood of a thorough inspection - as Vic says “are your nuts tight!

Personally, I’d like to see greater requirements for those people getting their Repairman Certificate than just having built the aircraft they’re authorized to inspect. If you’ve built it wrong you’re not likely to identify or admit your own mistakes! And it seems like there are DARs that aren’t looking closely at EAB aircraft when they issue the airworthiness certificate.

I’d like to see a path for EAB owners to get EAB inspection authority (maybe a Special EAB Inspection Certificate for the aircraft they own) without having to become an A&P. Maybe a two to three week course sponsored by an FAA approved training program plus accomplishing a condition inspection of their own aircraft under the supervision of a licensed A&P/IA as a requirement for the certification.

My two cents.

 

[jnorris]

The repairman certificate for AB aircraft has been discussed many times since the LSA rules became effective. When I worked at EAA I sat in several meetings with FAA personnel when the subject came up. While there can be many pro and con discussions on the practical application of the repairman certificate, the bottom line is that it would take a regulatory change in order to align AB repairmen rules with LSA.

You all know how long it takes to change a regulation. What you may not know is the internal process at FAA and DOT to make a regulatory change happen. So any time something comes up that would require a regulatory change, the FAA has to look at the impact the change would have (positive and negative) as compared to the cost (time and money) to make the change happen. There has to be some compelling reason (usually a measurable increase in safety) to make the change.

So far, the impact of changing the AB repairman rules hasn't risen to the level where it makes the effort/cost worthwhile for the FAA/DOT to expend the resources to change the regulations.

 

[gasman]

Being Experimental AB, you as the owner can do maintenance on your airplane. Keep a copy of 43.13 in your library and use it. You will need your A&P to be on board with the maintenance you've done. Asking around for an A&P who is willing to work on EAB may take some effort but would be advantageous to both parties.
As an A&P, I'd rather have an owner that is willing and does look after their airplane. I don't want to do an end of year squawk list to anybody's airplane including my own. Having the owner assist with the inspection lets me know their interest and willingness to keep their airplane in airworthy condition.

I just want to point out that the above statement is not true.

If you have no experience working on the aircraft that you own, find someone that has.... local EAA chapter??

I have been around a few A&P's that I would not let inflate my tires..... An A&P title does not guarantee quality work.

 

[bruceh]

I built my RV-9A and have the Repairman certificate to do the conditional inspections. I'm also now going through A&P school and have one more semester left. I learn something new every night in every class. It is really a case of "you don't know what you don't know". Van's assembly kit instructions are great for getting the airplane built, but maintenance information is sparse. The VAF forums are a great resource, but how do you know who/what to trust?

The A&P curriculum is pretty much everything from gliders to helicopters to supersonic jets. It is a bit over ambitious to make a mechanic know all of this information just to get in the door as an FAA certified mechanic. For example, I have to take a class on Turbine engines, yet I will probably never touch one in my GA life. It would be nice to have varying levels of mechanic licensing for things like sheet metal, composites, fabric, pressurization, etc.

I agree with Mike Busch's thoughts on this that are well summarized in this video/webinar.

I have to agree with him that getting the A&P is a huge commitment.

 

[Ironflight]

I built my RV-9A and have the Repairman certificate to do the conditional inspections. I'm also now going through A&P school and have one more semester left. I learn something new every night in every class. It is really a case of "you don't know what you don't know". Van's assembly kit instructions are great for getting the airplane built, but maintenance information is sparse. The VAF forums are a great resource, but how do you know who/what to trust?

The A&P curriculum is pretty much everything from gliders to helicopters to supersonic jets. It is a bit over ambitious to make a mechanic know all of this information just to get in the door as an FAA certified mechanic. For example, I have to take a class on Turbine engines, yet I will probably never touch one in my GA life. It would be nice to have varying levels of mechanic licensing for things like sheet metal, composites, fabric, pressurization, etc.

I agree with Mike Busch's thoughts on this that are well summarized in this video/webinar.

I have to agree with him that getting the A&P is a huge commitment.

Congratulations on the commitment of getting your A&P - it is definitely not trivial, and takes a huge commitment over a couple of years, or decades of commitment building experience. Either way - you end up with a head full of knowledge about stuff you’ll never use, and some that you will.

I always tell folks that A&P’s are taught a lot about maintenance and repair, but little about “building” - which is why I cringe a little when RV’s are advertised as “A&P Built”. That might mean something good, or it might not. Many of the folks in my A&P exam-prep class were young men and women coming out of the Marines that had never seen a light plane, or internal combustion engine.

Don’t get too worried about being asked to disassemble a turbine or balancing a helicopter rotor on the exam — they don’t seem to come up in folk’s practicals. But you sure as better study those fire suppression systems for the written exams(s)! The FAA really seems to care about them….

Oh - wind when you finish your certificate, and are inspecting other people’s experimentals, make sure to do a “condition” inspection, not a “conditional”…..

 

[Mel]

Oh - wind when you finish your certificate, and are inspecting other people’s experimentals, make sure to do a “condition” inspection, not a “conditional”…..

And to address another problem I see often; Be sure you sign off their condition inspection as "In a condition for safe operation", not as "airworthy".

 

[Mark33]

There is an alternative: go to A&P school. I think you meant ‘an easy alternative’. That’s unlikely to happen, unless you can get the FAA to relax the inspection standards for all non-builder owned aircraft, e.g., 172’s as well as eab.

Well, I have absolutely no desire to go to A&P school and no, I didn’t mean “an easy alternative”. I also said nothing about “relaxing” any standard nor anything about certified aircraft. What said was that there needs to be a common sense pathway for a person who’s not the original builder and who doesn’t hold the repairman certificate to be able to do the annual condition inspection on their aircraft.

Here’s an example to illustrate my point:

Let’s take a look at two people. Person number one is a multiple offender RV builder, has the entire build manual memorized, eats nuts and bolts for breakfast and washes it down with AvGas.

Person number two is a first time builder and barely made it through the initial inspection with the DAR after having to address twenty five squawks the DAR didn’t like. He’s now the proud owner of an airplane that he built and the holder of the repairman’s certificate and can exercise all of its privileges…..however, he has tho read the directions every time he changes the oil. He eventually decides this airplane stuff just isn’t for him and sells his airplane to person number one.

Now, because person number one isn’t the original builder and doesn’t hold the repairman's certificate on that particular aircraft, he either has to hire an A&P once a year to sign the logbook, or get the original builder/repairman certificate holder to sign off on the annual.

I know my example above is extreme but I’m just trying to drive my point home. No one can convince me that this scenario makes any sense at all and serves no safety benefit. The bottom line, the only reason there’s not a common sense pathway available for a non builder to be able to sign off on the annual condition inspection is purely regulatory and bureaucratic in nature….period!

Will any of this ever happen?….Probably not.

 

[Mark33]

I’m one of those people who purchased their RV from the original builder. He had done all his own maintenance and condition inspections on the aircraft before selling it to me. As I mentioned several times in other forum posts, the aircraft had numerous build quality issues that required extensive efforts over a two year span to identify and resolve.

Over the years several A&Ps, some with IAs, have done my condition inspection with me working beside them just about every step of the way. It’s been a real learning curve and eye opener. Every year I also work on the aircraft without an A&P looking over my shoulder - BUT during the condition inspection I identify what’s been done and ask them to review my work. Early on their reviews identified issues they wanted corrected, but lately they’ve only complimented me on the quality of my efforts.

What I’ve also observed is that every A&P and A&P/IA that’s ever worked on my RV has his own criteria for what’s important and what’s considered “best practice.” It seems the less familiar they are with RV aircraft the more they concentrate their attention and focus to FWF concerns. Very few are interested in what’s been done behind the instrument panel or under the seat panels. Those with EAB experience (and particularly RV aircraft) the greater the likelihood of a thorough inspection - as Vic says “are your nuts tight!

Personally, I’d like to see greater requirements for those people getting their Repairman Certificate than just having built the aircraft they’re authorized to inspect. If you’ve built it wrong you’re not likely to identify or admit your own mistakes! And it seems like there are DARs that aren’t looking closely at EAB aircraft when they issue the airworthiness certificate.

I’d like to see a path for EAB owners to get EAB inspection authority (maybe a Special EAB Inspection Certificate for the aircraft they own) without having to become an A&P. Maybe a two to three week course sponsored by an FAA approved training program plus accomplishing a condition inspection of their own aircraft under the supervision of a licensed A&P/IA as a requirement for the certification.

My two cents.

You’re exactly right!

 

[jnorris]

The bottom line, the only reason there’s not a common sense pathway available for a non builder to be able to sign off on the annual condition inspection is purely regulatory and bureaucratic in nature….period!

True statement. Scroll back up and reread my post about the regulatory process and the cost/benefit analysis from the FAA's viewpoint. Until a case can be made for the measurable increase in safety that would be brought about by changing the regulations regarding these repairman certificates, nothing will change. In the final analysis, it's a numbers game. If the numbers were there, the regulations would change. But not until then.

 

[lr172]

Well, I have absolutely no desire to go to A&P school and no, I didn’t mean “an easy alternative”. I also said nothing about “relaxing” any standard nor anything about certified aircraft. What said was that there needs to be a common sense pathway for a person who’s not the original builder and who doesn’t hold the repairman certificate to be able to do the annual condition inspection on their aircraft.

Here’s an example to illustrate my point:

Let’s take a look at two people. Person number one is a multiple offender RV builder, has the entire build manual memorized, eats nuts and bolts for breakfast and washes it down with AvGas.

Person number two is a first time builder and barely made it through the initial inspection with the DAR after having to address twenty five squawks the DAR didn’t like. He’s now the proud owner of an airplane that he built and the holder of the repairman’s certificate and can exercise all of its privileges…..however, he has tho read the directions every time he changes the oil. He eventually decides this airplane stuff just isn’t for him and sells his airplane to person number one.

Now, because person number one isn’t the original builder and doesn’t hold the repairman's certificate on that particular aircraft, he either has to hire an A&P once a year to sign the logbook, or get the original builder/repairman certificate holder to sign off on the annual.

I know my example above is extreme but I’m just trying to drive my point home. No one can convince me that this scenario makes any sense at all and serves no safety benefit. The bottom line, the only reason there’s not a common sense pathway available for a non builder to be able to sign off on the annual condition inspection is purely regulatory and bureaucratic in nature….period!

Will any of this ever happen?….Probably not.

certainly can't disagree with any of this logic. However, I am still a believer that all of the EAB regs are based upon the simple premise that if you build it wrong, you experience the consequences and no unsuspecting folks do. Logically this follows into the maintenance phase. As soon as an airplane changes hands, this is gone. IMHO, this NEVER changes. If anything, I fear more about the FAA taking away our privileges as repairman. Person #2 in your example is not that uncommon and sooner or later a #2 out there is going to kill himself because of it. If that happens enough, someone may start thinking harder about whether or not to let such a guy have those privileges. Fortunately there is enough of a record out there that this would be difficult.

Larry

 

[TShort]

I was actually thinking about this the other day.

When I finish the -8 and get the certificate for that airplane, it seems like there ought to be some sort of path to get a repairman's certificate for the -10 (that I bought flying). I spent hundreds of hours working with my friend (serial RV builder and A&P) on rewiring the entire plane and redoing the panel, and participate in the inspection every year.

I realize this is a unique case (though I suspect there are quite a few builders and buyers out there) and making a regulation to fit would be difficult. It doesn't seem like an unreasonable thing (in my unbiased opinion!! )

 

[gyoung]

... has anyone here used their build and mx log to acquire an A&P cert? I had vaguely entertained this idea, as another way to justify the time and expense of building, but all roads kept leading to "attend this school for 2 years and work for an IA after that". From what I gather, it's theoretically possible, but unlikely and more hassle than it's worth?

I got approval for the A&P tests a couple years ago based on 40+ years of owner maintenance. In my listing of experience I included my two RV builds. The inspector commented that he was not allowed to include the builds but I had plenty of experience otherwise. He said it's in their orders and it's because the build is not certificated. Once it has an AWC you can count the maintenance on it. Go figure. He has a rep as fair and knowledgeable and I've read it elsewhere. Check with your local inspector who may view it differently.

 

[Mark33]

certainly can't disagree with any of this logic. However, I am still a believer that all of the EAB regs are based upon the simple premise that if you build it wrong, you experience the consequences and no unsuspecting folks do. Logically this follows into the maintenance phase. As soon as an airplane changes hands, this is gone. IMHO, this NEVER changes. If anything, I fear more about the FAA taking away our privileges as repairman. Person #2 in your example is not that uncommon and sooner or later a #2 out there is going to kill himself because of it. If that happens enough, someone may start thinking harder about whether or not to let such a guy have those privileges. Fortunately there is enough of a record out there that this would be difficult.

Larry

I’m certainly grateful for the privileges we have, but like everything else, there’s always room for improvement.

 

[Mark33]

True statement. Scroll back up and reread my post about the regulatory process and the cost/benefit analysis from the FAA's viewpoint. Until a case can be made for the measurable increase in safety that would be brought about by changing the regulations regarding these repairman certificates, nothing will change. In the final analysis, it's a numbers game. If the numbers were there, the regulations would change. But not until then.

Yep, I read your post and totally agree with you.

 

[jnorris]

I got approval for the A&P tests a couple years ago based on 40+ years of owner maintenance. In my listing of experience I included my two RV builds. The inspector commented that he was not allowed to include the builds but I had plenty of experience otherwise. He said it's in their orders and it's because the build is not certificated. Once it has an AWC you can count the maintenance on it. Go figure. He has a rep as fair and knowledgeable and I've read it elsewhere. Check with your local inspector who may view it differently.

There was a change in the FAA order a number of years ago. It used to say "construction of amateur-built aircraft should be evaluated on its own merit" or something very similar. But the order now specifically states that construction of an amateur-built aircraft cannot be counted toward the experience requirement for an A&P certificate. There is no further explanation in the order.

 

[avrojockey]

I got approval for the A&P tests a couple years ago based on 40+ years of owner maintenance. In my listing of experience I included my two RV builds. The inspector commented that he was not allowed to include the builds but I had plenty of experience otherwise. He said it's in their orders and it's because the build is not certificated. Once it has an AWC you can count the maintenance on it. Go figure. He has a rep as fair and knowledgeable and I've read it elsewhere. Check with your local inspector who may view it differently.

This is the path I'm taking...hopefully it doesn't take 40 years, but if I can get the logged time in 10 years I'll be happy. I did get my LSRM certificate though...I had the time to do that.

There may be some revisions to the Light-Sport Repairman and Inspection certificates coming with next years NPRM of MOSAIC. However, it may be more focused on expanding the envelope of the category rather than maintenance.

 

[gyoung]

This is the path I'm taking...hopefully it doesn't take 40 years, but if I can get the logged time in 10 years I'll be happy.

Try to get the sign-off as soon as you can. I waited way too long. The worst they can say is no. If they do, then ask for written documentation of your deficiencies. The IA who recommended me did that for his initial A&P and the inspector just signed him off rather than write a letter. They're bureaucrats, play to it.