By Jon Thornburgh

       September 2005


     The Sport Pilot rule was promulgated on September 1, 2005. A year has passed and slowly but surely the Sport Pilot infrastructure is being developed. The EAA states that 13 aircraft models have received certification allowing their manufacturers to deliver them as Special Light-Sport Aircraft (LSA.) There are 93 Sport Pilot Examiners and 30 Sport Pilot airworthiness inspectors (DARs.) More than 450 persons have been issued Sport Pilot Student Certificates.


            Now the LSA maintenance issues are being addressed. On the weekend of August 13, 2005 Rainbow Aviation conducted its first Sport Pilot Repairman Course at their facility in Corning, California.  Sixteen pilots attended the course and everyone graduated with a completion certificate.


            As every ultralight pilot knows, all two-seat ultralights must be converted to "experimental light-sport aircraft" (E-LSA) by January 2008. Presently ultralight owners may perform their own maintenance and annual inspections on their flying machines. However, after the ultralights are converted to E-LSA, pilots may no longer perform their annual inspections unless they attend a Sport Pilot Repairman Course, often called the "16-hour" course.


            Only the Experimental Aircraft Association (EAA) and Rainbow Aviation have been certified to conduct the Repairman course. The time, effort, and cost of meeting the FAA course requirements prevent all but the most determined organizations from obtaining FAA certification. The curriculum includes numerous items to be addressed. A partial list includes: aircraft fabric and tubing, seats and safety belts, instruments, flight and engine controls, batteries, studs and nuts, lines, hoses, and clamps, exhaust stacks, accessories, hydraulic lines, electrical system, wheels, tires, brakes, radios, propeller, fuel system, landing gear, and the aircraft logbook.


The Repairman course is a two-day class. The training consists of lectures, slide shows, and Power Point presentations, as well as hands-on experience. On the first day the subjects discussed are aircraft systems, airworthiness issues, regulations, and inspection procedures.


            On the second day, the students review aircraft theory of flight and spend the afternoon in the hangar for hands-on training. At the end of the course there is a review and written test. The FAA requires a passing score of at least 80% on the multiple-choice exam.


The sixteen course attendees were Daniel Barnes, Dan Crooks, Doug Dugger, Dan Flores, Les Goldner, Bill Massey, Bill Massey (yes, there were two with the same name,) Phil McNally, Frank Miller, Keith Parrish, John Peters, Denis Porter, Bob Roth, Ron Rountree, Mat Ryant, and Art Stienbach.  FAA maintenance inspector Edsel Ford monitored the training.


            The Repairman course is a by-product of the new Sport Pilot rule. The FAA rule regulating the course is presented in FAR Part 65.107, entitled "Repairman Certificate (Light-Sport Aircraft): Eligibility, Privileges, and Limits." FAR 61.107 specifies that a 16-hour course is required for owners of E-LSA aircraft if they wish to perform conditional inspections.


Any competent person may perform maintenance on an experimental aircraft. However, only an A&P mechanic or someone with a "repairman" rating can perform a conditional inspection, which is required annually. At the completion of the Repairman course the graduates are awarded a "Certificate of Completion." 


Contrary to popular belief, a person is not required to own a light-sport aircraft in order to attend the Repairman class. Anyone may attend the Repairman course. However, a graduate can only perform a conditional inspection on an aircraft that he personally owns. And, he may only inspect his own aircraft. He may not perform a conditional inspection on someone else's LSA, even if the other person has an identical airplane.


After a person buys his airplane he takes the Certificate of Completion to the FAA in order to obtain his Repairman certificate. The certificate reads: "Repairman (light-sport aircraft)--Inspection rating."


There is another Repairman certificate, called the "Repairman (light-sport aircraft)--Maintenance rating."  The maintenance rating is only available by attending a much longer Repairman course. This longer course is presently not available, although Rainbow Aviation is in the process of formulating a course for FAA approval.


The purpose of the longer course is so to train a person to perform maintenance and conditional inspections on Special light-sport aircraft, as opposed to Experimental light-sport aircraft.  Special LSA aircraft are those which are delivered turn-key flyable from a manufacturer, and which meet certain ASTM "consensus standards."


Unlike E-LSA, a Repairman-Maintenance rating is required to perform all maintenance on S-LSA, not just the annual conditional inspection. However, unlike the Repairman-Inspection rating, a person with the Repairman-Maintenance rating can perform maintenance on anyone's

S-LSA or E-LSA.  He is not limited to just his own airplane. In fact, a Repairman with a Maintenance rating need not even be a pilot. The Maintenance Repairman may receive compensation for his work. For this reason, he is sometimes referred to as a "Sport Mechanic."


            Ultralights which are converted into E-LSA may be used commercially for flight training until January 2010. When used commercially, the aircraft must undergo a "100-hour" inspection, in addition to the annual conditional inspection. Many ultralight pilots don't realize that only a repairman with a "Maintenance" rating can perform the 100-hour inspection (or an A&P mechanic.)  Someone with the "Inspection" rating may not do the 100-hour inspection.


            To make the situation worse for the commercial E-LSA pilot, the annual conditional inspection does not "reset the clock" back to zero, or act as a substitute for the 100-hour inspection. This quirk in the Sport Pilot regulations is exactly opposite to the maintenance rules pertaining to general aviation. See FAR 91.327 and 65.107(c) to read the exact wording of the rule.


Let's say that a Quicksilver used commercially for training has 90 hours on it when it undergoes a conditional inspection by the owner with a Repairman-Inspection rating. After 10 more hours of flight time it must have a 100-hour inspection by a repairman with a  "Maintenance" rating (or an A&P mechanic) before the owner can use it again commercially.


            Based on this information, one can see that it is vitally important that the Repairman-Maintenance course be available to the Sport Pilot community, because many A&P mechanics won't work on tube-and-fabric, Rotax 2-cycle aircraft.


            In fact, there is a possibility that even A&P mechanics will not be able to work on S-LSA. The FAA is leaving it up to the manufacturer who certifies the Special light-sport aircraft to specify in the Operating Limitations exactly who may work on the aircraft. A manufacturer may deem that an A&P who wants to maintain a S-LSA must attend a 120-hour class, or at least some of the class training modules discussed below. At the present time it is not known whether many manufacturers are likely to restrict an A&P mechanic or not.


The amount of training required to qualify for the Repairman-Maintenance rating depends on what category of light-sport aircraft he intends to work on. In order to maintain or inspect an airplane the mechanic candidate needs 120 hours of training.


To qualify for a Maintenance rating to work on weight-shift-control aircraft (trikes) and powered parachutes the mechanic must complete a 104-hour school. For lighter-than-air and gliders a person needs 80 hours.


For all five LSA categories, there are a total of eight "modules" that Repairman-Maintenance candidates must study.   Below is a list of the modules pertinent to the various categories of LSA.


Airplane: modules 1, 2, 3, and 4

Weight-shift-control (WSC): modules 1, 2, 3, and 5.

Powered parachute (PPC): modules 1, 2, 3, and 6.

Lighter-than-air (LTA): modules 1 and 7

Glider: modules 1, 2, and 7


The "core" modules are numbers 1, 2, and 3. The modules specific to the various categories are numbers 5, 6, 7, and 8. Once a person takes the core modules he receives credit for those modules if he continues training for another category.


For example, if a person attends a course to obtain a Repairman-Maintenance rating to work on airplanes, he would take a 120-hour course consisting of modules 1, 2, 3, and 4. If he later wanted authorization to work on trikes, he would only need to take module number 5.


Here is a list of the modules, the number of hours allocated to each module, and a brief description of the content of the module:


Module    Hours                       Content


  1        16        Overview, regulations, and record keeping


  2        24        Airframe, weight and balance, and ballistic para-



  3        45        Engines and propellers


  4        35        Airplane maintenance knowledge


  5        19        Weight-shift-control maintenance knowledge


  6        19        Powered parachute maintenance knowledge


  7        64        Lighter-than-air maintenance knowledge


  8        40        Glider maintenance knowledge


            If an extremely ambitious person wanted to be able to maintain all five categories of S-LSA, he could take all eight modules, once they all become available. In that case, he would undergo a total of  262 hours of training that would take approximately 5 weeks. Unfortunately, if someone takes a 16-hour course before taking a 120-hour course he does not get any credit for having taken the 16-hour course.


            Rainbow Aviation is proposing to the FAA that they offer each module on a continuing basis, rotating modules from week to week. That way a student could take a specific module for a few days and return later for another module. If someone wanted to take all the modules for airplane with one trip to Rainbow, he would be in class for three weeks with one day off per week. Rainbow has arranged for a discount at several hotels in the vicinity.


            For more information on Sport Pilot see the FAA website at http://afs600.faa.gov/AFS610.htm. The Federal Air Regulations are available on a link in the upper right corner at the FAA website www.faa.gov.


            The schedule for future maintenance classes at Rainbow Aviation is on their website at www.rainbowaviation.com.