Question: I’m confused about the two Repairman Certificates available to Light Sport Aircraft owners. It seems that I can perform the required annual condition inspection on my Experimental Light Sport Aircraft by taking and passing a two-day course and obtaining a “Repairman Certificate” with an inspection rating. But if I want to tow an ultralight glider for compensation (allowed by my operating limitations), I have to have a “100-hour” inspection, and this inspection must be done by a person holding a Repairman Certificate with a maintenance rating or an A&P certificate. This sounds backward to me.
You are correct—the certificates do seem to be backward from what goes on in the certified aircraft world. In the certified world, an A&P mechanic may perform a 100-hour inspection but cannot sign off on an “annual.” To sign off on an annual inspection, the A&P must also hold an Inspection Authorization, or IA.
FAR Part 65.107 defines the eligibility, privileges and limits for the Repairman Certificate (Light Sport Aircraft).
Training hours required for the maintenance rating.
A repairman with an inspection rating may perform the condition inspection on an Experimental Light Sport Aircraft (ELSA) certificated under 21.191(i)that is owned by the certificate holder. This is a 16-hour course and must reflect the particular class of ELSA owned by the individual. Once you have sold this particular aircraft, you may no longer perform this inspection. If you later purchase another Light Sport Aircraft of the same class, you’re allowed to add it to your certificate without repeating the course.
A repairman with a maintenance rating may perform the condition inspection on an ELSA certificated under 21.191(i) or a Special Light Sport Aircraft (SLSA) certificated under 21.190. This covers both the annual condition inspection and the 100-hour inspection required for “commercial” operations. The maintenance rating is a little more intense in that the course requires more training hours.
In addition, a repairman with a maintenance rating may perform required maintenance and/or repairs on an SLSA (21.190). However, he may only perform that maintenance authorized by the aircraft manufacturer, and then only if he has previously performed the same maintenance satisfactorily or does it under the supervision of a certificated mechanic or repairman who has.
It seems appropriate to mention here that an A&P with an IA is never required in the Light Sport world. The primary purpose of an IA is to confirm that everything conforms to a type certificate, and there are no type certificates involved in ELSAs or SLSAs.
Please send your questions for DAR Asberry to editorial@kitplanes.com with “Ask the DAR” in the subject line.
Mel Asberry is an experienced Designated Airworthiness Representative specializing in Experimental/Amateur-Built aircraft. He and his wife, Ann, have built seven amateur-built airplanes including two ultralight types, a Moni Motorglider, a Dragonfly Mk2, two RV-6s and a Zenair CH 601HDS. They are currently building a scratch-built biplane.
