The current Light Sport Repairman Maintenance Training should remain in place for the following reasons:
1. There is no rationale for the changes
2. There is a positive safety record therefore there is no safety rationale (acknowledged in the NPRM)
3. Similar to the sport pilot options for endorsement for more complex aircraft,
LSRMs should add complexity by added training offered in modules
Example: retractable gear would be offered as an elective.
4. Both A&Ps and LSRMs are already required to have the training to accomplish any task
5. There is no change to the sport pilot certification- even with the more complex aircraft
they are offered additional training and endorsements
6. There is no proposed change to the LSRI training
7. There is limited impact as this only applies to SLSA and ELSA , would not impact Type Certificated aircraft
8. The demographic of pilots who take the current training are not the same as those who would enroll in a longer more complex training. Most are 55 and older, buying factory built aircraft they can maintain
9. There is a majority who will still just want to fly and maintain simple, easy to fly and maintain aircraft.
10. There is a shortage of A&Ps , eliminating the 15 day LSRM option would increase the shortage of trained technicians
11. The majority of A&P mechanics do not have Rotax training or training for light sport speciality issues.
12. The new definition of light sport is much too broad and complex to train for all possibilities. The only reasonable answer is to offer the training in Modules. For example: areas like electric power plants, avionics or retractable landing gear systems, turbine power plants to name a few.
And finally, it is significant that LSRMs perform ALL tasks with manufacturer’s instructions: complete with list is tools and materials required, detailed instructions, diagrams, and even a method to test that the task was done correctly.