Repairman's cert rule change request

Greetings,

This may not be the best forum for this, but there are probably more RV folks who would benefit from a change than with any other aircraft type. I'm fully aware of how the current repairman's cert works, where you can only work on the specific plane you built. That's fine, but I think this should be logically extended.

In my mind, if you have a repairman's certificate for an RV-8 you built, you should be able to apply it to any RV-8 you own, even if you didn't build it. I think you could even go so far as to extend that to any RV, since they're all so similar in construction.

Am I the only one who thinks this makes sense? I sent a similar message to the EAA a couple weeks ago, asking them to consider it for future negotiations with the FAA, but I didn't get a reply.

Cheers,
Rusty

Working with the government daily for a job, I can tell you they don't go by what makes sense most of the time. Although I agree with you on airplanes you own.

Where would you draw the line?

Would building an RV-12 qualify you to inspect a Rocket?

Another thing to consider is that an amateur-builder may "name" the model of his aircraft anything he likes. Nothing to keep him from building a Glasair III and calling it an RV.

There's just too many negative possibilities. I wouldn't get my hopes up.

I've seen too many RVs built by people I would NOT want inspecting my RV-6....wouldn't want them working on it either even though that is now legal.

Ah, but

working on it is legal - for any Joe on the street.

Signing it off once a year isn't.

Repairman's certificate rule change request

Rusty- I agree with you, but don't hold your breath. Even worse as far as I am concerned, is the difficulty of obtaining the FAA light-sport repairman certificate with inspection rating. Rainbow Aviation is the only source I've found for the approved course, and they spend precious little time in the SouthEast, except for Apopka during Sun N Fun, and that one is always booked up.

I have to bring in an A&P annually for my ELSA RV12 condition inspection, even though I know WAY more about the a/c and Rotax than he does- and I have maintained it all year, but am not qualified to inspect it? An A&P doesn't even have to ever have SEEN an RV12 or a Rotax before. FAA is OK with me doing the inspection on my Rotax powered Kitfox, which I built, and would be with my Long EZ when complete- but not my RV12 built by someone else??? Ben

I've kind of pondered the same question, from both a narrow perspective and a broader one. Narrow one first:

At some point (hopefully a long time from now) my dad is going to have to get rid of his -6. If that airplane stays in the family it would grate a little to have to go get someone else to do the condition inspection, when I was right there building the airplane beside him and by that point would have built a -7. It sure would be nice to be able to transfer the repairman's certificate from him to me, given that I was involved in building that airplane, (will have) built another very similar airplane, and work as an in-service aircraft systems engineer.

From a broader perspective, the FAA's one-size-fits-all approach to A&P licensing--namely, that anyone working on an airplane should be qualified to do so for hire, and needs to qualify on everything from tube-and-fabric to glass to radials and jets and helicopters--is somewhat outdated and unrealistic at this point, at least as it applies to light privately-owned aircraft. If the only airplane I'm maintaining is a sheetmetal two-seater powered by a Lyclone, why do I need to learn how to overhaul a radial, inspect a turbofan, troubleshoot an air conditioning pack, repair a fabric wing, track a helicopter rotor, or troubleshoot a thrust reverser? That's all great training if you're going to work for hire on a variety of aircraft, but that (and the two years' experience requirement) seems a bit overkill for maintaining a simple, privately-owned, not-for-hire airplane.

LSA owners can attend training classes that enable them to do the work on their own personal LSAs. I would think we should have a similar thing in place for owners of other light airplanes. It might take getting the primary non-commercial category in place for certified airplanes (apparently the FAA thinks any certified airplane should be usable for commercial ops?) but it should be relatively simple for experimentals.

It's possible.

The system you gentlemen describe is similar to what we have in Australia. Basically, once you have completed the construction of an aircraft and the associated maintenance procedures course, you are then qualified to work on any aircraft of the same category of engine (e.g. air v's liquid cooled) and airframe (e.g. rage/tube v's aluminium v's composite). For example, if you construct an RV-7 with a Lycoming IO-360 you could perform the annual on a Zenith STOL CH-701 with a continental O-200. Alternatively you could not perform the annual on a Glasair II with a liquid cooled Subaru. As a consequence of this I haven't seen aircraft tumbling out of the sky here at any higher rate than elsewhere. You may like to speak with the Sport Aircraft Association in Australia to find out how they managed to negotiate this with our regulator.
http://www.saaa.com/Contact.aspx
Regards,
Tom.

benburb said:

Rusty- I agree with you, but don't hold your breath. Even worse as far as I am concerned, is the difficulty of obtaining the FAA light-sport repairman certificate with inspection rating. Rainbow Aviation is the only source I've found for the approved course, and they spend precious little time in the SouthEast, except for Apopka during Sun N Fun, and that one is always booked up.

I have to bring in an A&P annually for my ELSA RV12 condition inspection, even though I know WAY more about the a/c and Rotax than he does- and I have maintained it all year, but am not qualified to inspect it? An A&P doesn't even have to ever have SEEN an RV12 or a Rotax before. FAA is OK with me doing the inspection on my Rotax powered Kitfox, which I built, and would be with my Long EZ when complete- but not my RV12 built by someone else??? Ben

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I went down to TX (9 hour drive) to take the class. Getting the certificate wasn't difficult, but the classes are indeed sparse.

At least with an ELSA, you CAN get the repairman certificate for one that someone else built. Not so for an EAB, of course, even if were an identical airplane. I suspect the big difference is that there is a published, manufacturer developed inspection checklist and maintenance manual. Just my suspicion.

That would be great if we could get that here in the US.

tgmillso said:

The system you gentlemen describe is similar to what we have in Australia. Basically, once you have completed the construction of an aircraft and the associated maintenance procedures course, you are then qualified to work on any aircraft of the same category of engine (e.g. air v's liquid cooled) and airframe (e.g. rage/tube v's aluminium v's composite). For example, if you construct an RV-7 with a Lycoming IO-360 you could perform the annual on a Zenith STOL CH-701 with a continental O-200. Alternatively you could not perform the annual on a Glasair II with a liquid cooled Subaru. As a consequence of this I haven't seen aircraft tumbling out of the sky here at any higher rate than elsewhere. You may like to speak with the Sport Aircraft Association in Australia to find out how they managed to negotiate this with our regulator.
http://www.saaa.com/Contact.aspx
Regards,
Tom.

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Mel said:

Where would you draw the line?

Would building an RV-12 qualify you to inspect a Rocket?

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Why not? An A&P hasn't built either one. And the IA isn't needed either. There's a head scratcher.

Seriously, though. The LSR-I certificate training is not model or engine specific. It's training about what and how to inspect. You don't have to build squat.

I mean, let's face it... anyone can buy a Rocket (or an RV-12) and maintain and alter it at will. You're no less dead if you screw up the inspection of an LSA than if you screw up the inspection of a Rocket.

I don't have a dog in the fight, but the logic to support requiring an A&P to inspect seems a little thin.

Bill Boyd is correct about working on it vs inspecting it.

And there was a case written up in Sport Aviation some years back about a repairman certificate given to some one not the original builder. It can be done.

Ed

To clarify what Bill and Ed said...

If your purchased RV's condition inspection was signed yesterday, you can rebuild it with a different engine, panel, prop, etc. document the changes in the log books, and fly it until the next condition inspection is due. At that time the A&P inspects the aircraft to make sure it is in condition for safe flight and signs the log book.

Even then, I know many RV owners who do the complete inspection and then have their A&P give their work a review and sign the logbooks.

N941WR said:

Even then, I know many RV owners who do the complete inspection and then have their A&P give their work a review and sign the logbooks.

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The A&P had better conduct the entire inspection himself. Otherwise he has violated the FARs. An inspection may NOT be delegated!
Maintenance, yes, Inspection, NO.

Thanks for all the great discussion so far! In an ideal world I'd love to see more people approach the EAA with the idea, but it's always hard to be optimistic about working with the feds.

I also know there's always the fear of losing privileges by opening negotiations. For example they might say sure you can sign off the annuals if you take a course, but now you have to take the course to do any work on the plane. That would likely be a step in the wrong direction.

This is something that's always annoyed me about the repairman's cert, but now it's personal If all goes according to plan, I'll own an RV-3B that I didn't build very soon, and I'll definitely approach the FAA office about the possibility of getting a repairman's cert. It can't hurt (too much) to ask, and maybe they'll share some insight about the chances of getting this changed.

I'll also pass along a true but ridiculous situation. My previous -3B has a Mazda rotary engine. The person who owns it now previously built an RV-3 with a rotary engine. That aircraft is no longer with us (not the engine's fault), but now he owns mine. To be legal, he has to hire an A&P to sign off the conditional inspection, and we know what an expert the local A&P probably is with regard to rotary engines

Common sense is not as common as it used to be

Cheers,
Rusty

Good luck getting it changed. Nobody on here will live long enough to see a change by the faa on such a low priority issue.

An A&P has had training in aircraft systems, building and repair practices, inspection methods and has had plenty Of practical experience in all of the above. He has to prove that through written, oral and practical testing to get the certificate.
A builder with a repairman certificate has built at least the better part of one aircraft probably, but not necessarily, using good techniques that can apply to other aircraft. (Does a one time installation of two p mags make one capable of working on Slic or BEndix mags, light speed electronic or other ignitions? Same goes for fuel systems, hydraulic systems, etc.)
Even an A&P is not supposed to work on systems until he is properly instructed in how to do it.
I have seen amateur built planes that I wouldn't taxi in, much less fly in! According to the argument here, that builder should be able to inspect someone else's plane? I hope not!
The current rules at least set a standard for mechanics and inspectors to adhere to, and I think we need that.
Do I agree with everything the FAA comes up with, of course not. Are all mechanics good ones, no. But I'm pretty good with their rules in this area and I don't think they should Chang drastically for the safety us all.

sf3543 said:

An A&P has had training in aircraft systems, building and repair practices, inspection methods and has had plenty Of practical experience in all of the above. He has to prove that through written, oral and practical testing to get the certificate.
A builder with a repairman certificate has built at least the better part of one aircraft probably, but not necessarily, using good techniques that can apply to other aircraft. (Does a one time installation of two p mags make one capable of working on Slic or BEndix mags, light speed electronic or other ignitions? Same goes for fuel systems, hydraulic systems, etc.)
Even an A&P is not supposed to work on systems until he is properly instructed in how to do it.
I have seen amateur built planes that I wouldn't taxi in, much less fly in! According to the argument here, that builder should be able to inspect someone else's plane? I hope not!
The current rules at least set a standard for mechanics and inspectors to adhere to, and I think we need that.
Do I agree with everything the FAA comes up with, of course not. Are all mechanics good ones, no. But I'm pretty good with their rules in this area and I don't think they should Chang drastically for the safety us all.

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I agree with almost everything you say. But look at what the A&P actually does during a condition inspection... we're not talking about servicing mags, and I'd bet a lot of A&Ps haven't seen a Pmag or Lightspeed either. You're talking about servicing, I'm talking about inspecting.

Anyway. I would certainly not advocate that just anyone be able to inspect simply by virtue of the fact that they bought an E/AB. Certainly some required training would be in order. It just doesn't take an A&P level of training to be able to inspect. And we all know that even an annual inspection by an A&P/IA can be worthless... just ask someone who'se been airplane shopping lately. I don't want that to sound harsh, and I certainly don't mean to diminish the level of experience and expertise of many certified mechanics.

sf3543 said:

An A&P has had training in aircraft systems, building and repair practices, inspection methods and has had plenty Of practical experience in all of the above. He has to prove that through written, oral and practical testing to get the certificate.
A builder with a repairman certificate has built at least the better part of one aircraft probably, but not necessarily, using good techniques that can apply to other aircraft. (Does a one time installation of two p mags make one capable of working on Slic or BEndix mags, light speed electronic or other ignitions? Same goes for fuel systems, hydraulic systems, etc.)
Even an A&P is not supposed to work on systems until he is properly instructed in how to do it.

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And that A&P is probably working on other peoples' airplanes for pay, or maintaining aircraft used for commercial services. It's kind of like how you only need a Private certificate to fly for yourself, but a Commercial or ATP to carry passengers for hire.
I don't think that level of training is really necessary for a person wishing to maintain their own personally-owned light airplane. Do you really need training in maintaining thrust reversers or tracking rotor blades in order to inspect a purchased RV?

sf3543 said:

I have seen amateur built planes that I wouldn't taxi in, much less fly in! According to the argument here, that builder should be able to inspect someone else's plane? I hope not!

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No, we're only talking about being able to maintain and inspect an airplane that you own yourself, whether you built it or not. This has nothing to do with performing those inspections for other people.

The point in my original post remains: the FAA requires that I get the inspection certificate; the industry , so far, has provided only one source for the training. I'm perfectly willing to comply, but doing so is geographically challenging. I'm not saying the rule is unreasonable, but it sure makes it difficult.

rmartingt said:

No, we're only talking about being able to maintain and inspect an airplane that you own yourself, whether you built it or not. This has nothing to do with performing those inspections for other people.

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Actually, we're really only talking about inspections... since anyone can maintain an Experimental.

Up here in Canada, generally speaking, the owner of an amateur-built aircraft can legally make all logbook sign offs for that aircraft. It doesn't matter whether he built the aircraft or not. While you may argue that only the builder really knows all the details of that aircraft, having non-builders conduct and sign off maintenance in Canada has not resulted in any accidents of which I am aware.

Kevin Horton said:

Up here in Canada, generally speaking, the owner of an amateur-built aircraft can legally make all logbook sign offs for that aircraft. It doesn't matter whether he built the aircraft or not. While you may argue that only the builder really knows all the details of that aircraft, having non-builders conduct and sign off maintenance in Canada has not resulted in any accidents of which I am aware.

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Ssshhhh!! Heresy!

Kevin Horton said:

Up here in Canada, generally speaking, the owner of an amateur-built aircraft can legally make all logbook sign offs for that aircraft. It doesn't matter whether he built the aircraft or not. While you may argue that only the builder really knows all the details of that aircraft, having non-builders conduct and sign off maintenance in Canada has not resulted in any accidents of which I am aware.

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Unfortunately, application of logic and/or successful examples to the FAA typically just results in the FAA doubling-down on whatever the policy is, and maintaining "this is the policy, we don't know why it's that policy any more, we agree it maybe doesn't make sense, but thus it has always been, and thus it shall ever be".

Fascinating idea. This Repairman Certificate extension concept.

I admire anybody with enough passion to become an A&P in today's market.

Unfortunately 9 out of 10 A&P school graduates we have hired in the last two years don't seem to know much. I have my suspicions some of the A&P schools are milling them out the door as fast as possible for financial reasons. Imagine pressure they put on in-house DMEs. These mechanics seem to come from a parts replacement perspective rather than a fix it perspective. Their idea of troubleshooting is component replacement. Often a sign of inexperience and/or incompetence. They can't stab a mag. Can't flare a hard line. Don't know the difference between a dimple and a countersink. Many can't do simple math or fractions (How come an 11/16 wrench is smaller than a 3/4?). One fellow, an Army Aviator (which I highly regard) owns his own 172 and obtained his A&P through a military experience equivalence program. He couldn't safety wire his oil filter and thought his EGT probe was an CHT probe despite his not even having a CHT gauge. Last month we sent a new A&P into the shop to remove an actuator from a C210 nose gear. Instead of merely unscrewing the hydraulic hoses from the flare fittings he left the hoses connected and unscrewed the fittings from the actuator leaving the fittings dangling on the end of the hoses. That must have been a B. Who'd a thunk it. Hold this wrench while I turn the airplane. I know a supervisor at the Mesa Airlines overnight light maintenance facility across the field and he is having similar trouble finding competent A&Ps. They have a high turn over due to inexcusable errors and overall lack of skill sets. Sometimes with the same new hires we had tried.

There are of course exceptions and a good competent A&P is becoming a rare and wonderful thing to find. They need to be treated well and paid well.

I think the concept of a Repairman Certificate holder being allowed to sign off his personally-owned EAB that somebody else built is a fine idea. Not his neighbor's EAB. Only his. And honestly it could be a way to keep things on the up and up. It could reduce the shady activity of the $200 tailgate sign-off A&P guy usually around somewhere for those who do their own work and only want to buy an inspection signature.

Jim

sf3543 said:

An A&P has had training in aircraft systems, building and repair practices, inspection methods and has had plenty Of practical experience in all of the above. He has to prove that through written, oral and practical testing to get the certificate.
A builder with a repairman certificate has built at least the better part of one aircraft probably, but not necessarily, using good techniques that can apply to other aircraft. (Does a one time installation of two p mags make one capable of working on Slic or BEndix mags, light speed electronic or other ignitions? Same goes for fuel systems, hydraulic systems, etc.)
Even an A&P is not supposed to work on systems until he is properly instructed in how to do it.
I have seen amateur built planes that I wouldn't taxi in, much less fly in! According to the argument here, that builder should be able to inspect someone else's plane? I hope not!
The current rules at least set a standard for mechanics and inspectors to adhere to, and I think we need that.
Do I agree with everything the FAA comes up with, of course not. Are all mechanics good ones, no. But I'm pretty good with their rules in this area and I don't think they should Chang drastically for the safety us all.

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It doesn't much matter

I'm in this exact situation right now. I'm glad I have the repairman's for the RV-4 I built, but the only thing different on the RV-6 I also own and did a major repair and brought back to airworthy is the very modest fee my A&P charged to do the compression check, visually inspect all work and sign.

My point... repairman or not, on homebuilts, the actual difference means nothing if you're comfortable turning wrenches

Also... having the "card" doesn't mean you actually know how to fix or inspect anything. They are two different things, the actual A&P rating comes with real-world apprenticeship. That is invaluable. The repairman's just means you follow a manual from a factory and know how to assemble new parts. That's easy. I'm still constantly learning.

im dead set against it. I think the FAA should be a little bit tighter on the repairman certificates even. I know too many people that built it with a check book getting the repairmans certificate. the best solution is get to know a good A&P. my charges for a condition inspection are cheap, mostly in 12oz bottles.


bob burns
RV-4 N82RB

n82rb said:

I know too many people that built it with a check book getting the repairmans certificate.

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I don't doubt that, but I think it's a completely separate issue.

Rusty