Van's Air Force
The definitive Van's Aircraft support community! Buying, building or flying an RV? Join our exclusive family of mentors and enthusiasts!
MOSAIC Repairman Certificate classes
- Thread starter IBRNGAS
- Start date
You're right, the only thing complicating things is your interpretation. Operating Limitations override regulations.
If the word "must" were used, that would insinuate that an A&P could not refuse to do it. FAAs interpretation is pretty clear, and their's is the only one that counts.
Sorry if you don't agree, but that's the way it is.
This reminds me of a couple of years ago when the FAA lawers decided that CFI's could not charge for instruction and checkouts in an owners EAB. The quick fix was to create a website that spit out an LOA (Letter Of Authotization) that gave the CFI authotity to charge for such services on an individual basis. The CFI filled out a form and within a couple of minutes an LOA was e-mailed back in his (her) name. The FAA then made a new rule that solved the lawerrs' problem.
I wonder if the FAA can make a website where the owner identifies the aircraft and the FAA spits out a revised Ops Spec exactly like the existing one but with new wording added to comply with MOSAIC? This would avoid all the work the FISDO would have to do to amend each Ops Spec.
Anything is possible, but I think the decision has already been made and the new Order is written. The shut-down just delayed everything and publishing the new Order is not a high priority for the FAA. They have much bigger things on their plate.
Everyone will not need the new Op Lims. Those who built their own aircraft and got their repairman certificate and those who prefer to have their aircraft inspected by professionals.
Last edited:
I don't see how the operating limitations you quote are contrary to the new regulations. What, exactly, is being "overriden"?
If the operating limitations said "the CI for this aircraft must be performed by an A&P or an old-school repairmen," as some older op lims apparently do, that would indeed conflict with the new regs. If they said "the CI for this aircraft can only be performed by an A&P or an old-school repairman," it would present the same problem. But they just don't say that. Instead, they identify some people who may perform the CI, and now the reg adds two more.
Nothing needs to be "overriden."
That would be an objectively ridiculous interpretation.
I haven't seen their interpretation explained anywhere, yet.
But I certainly agree that only their interpretation counts! They've done strange things before, and we've just had to live with it.
It may well be that somewhere the FAA has decided that a new reg can't expand on what's permitted by operating limitations, even when the reg doesn't conflict with the operating limitations--which is the situation we have here. I haven't seen that rule or policy set down anywhere, but I'm certainly not an expert. Such a rule would be the only justification for requiring revision of the operating limitations you quote.
Last edited:
They don't identify "some people" who may perform the CI. They identify who may perform the CI. And LSRI are not included.
Obviously I'm not going to change your mind. I'm done trying. You do what you want. Good luck.
Agree completely. But they're also not excluded, which means the new reg does not conflict in any way with the limitations you quote.
If the FAA thinks that regs and operating limitations that don't actually conflict with each other can't just be allowed to live together in peace and harmony, so be it. What they say goes.
Mconner7
Well Known Member
Agree completely. But they're also not excluded, which means the new reg does not conflict in any way with the limitations you quote.
If the FAA thinks that regs and operating limitations that don't actually conflict with each other can't just be allowed to live together in peace and harmony, so be it. What they say goes.
The crux seems to be what they interpret as an “appropriately rated FAA certified mechanic.” I see nothing about A&P or IA and all they would need to do is say that LSRI is appropriately FAA rated for EAB CI’s.
This is the Federal Government and my suggested solution would be WAY too simple for it to be implemented.
Key word here is "mechanic". A repairman is not a mechanic.
An appropriately rated mechanic is an FAA Certificated Mechanic with Airframe and Powerplant rating.
An IA is not required because they are only concerned with compliance with a type certificate and experimental aircraft do not have a type rating.
Last edited:
I'd like to repeat this question because I worked for many years enforcing federal regulations pertaining to hazardous materials transportation. Interpretations were key in my line of work, but the Federal Interpretations that were binding on the relevant parties were always issued in writing. They were published as a result of FAQs asked by trucking companies as well as enforcement personnel. The "Interpretations" documentation was always the last stop after reading the regulations and before issuing a penalty. The interpretations sole purpose was to clarify questions about regulations that could be construed as vague.
Not for everyone. The people who built their own aircraft don't need it and the people who prefer to have their aircraft inspected by professionals won't need new op lims. There are many people who want different eyes on their aircraft every year.
The discussion is about inspection authority, not maintenance or other work on an airplane.
Aside from muddying the waters, you're also wrong about the regs as they pertain to *maintenance*. It's not necessary to the owner of an EAB, my 6 year old neighbor kid could legally rebuild your engine in his dad's garage.
Well this puts this thread to rest. Sorry Doug. https://www.faa.gov/newsroom/fact_sheets/MOSAIC_Fact_Sheet.pdf
Page 3
"NOTE: EAB aircraft with operating limitations issued prior to Oct. 22, 2025 must obtain revised operating limitations that permit a light-sport repairman to perform the annual condition inspection"
Page 3
"NOTE: EAB aircraft with operating limitations issued prior to Oct. 22, 2025 must obtain revised operating limitations that permit a light-sport repairman to perform the annual condition inspection"
Only if you want this option.
Hey, they are getting somewhere! The Wheels of change are in first gear
Yep. Big question now is how much of a headache is it going to be to get them changed.
Just because you can, doesn't mean you should....
Soooo, before we all rush off to change our op limitations, I wonder if we should consider this question. Might a buyer of an EAB find more comfort in knowing that only the builder or an A&P could possibly have done the inspections of the homebuilt they are considering buying as opposed to a 16 hour participation trophy holder? I for one, having taken that 16 hour course, was less than impressed with the instruction provided. And even if it was awesome, which it wasn't. it's still only 16 hours. One of the guys in my class tragically killed himself because of the botched controls on his 12 that resulted in an SB (SB-00102). His error would have been obvious to a trained mechanic. What if changing the op limitations to allow less qualified folks to sign off on your condition inspection might have the opposite effect and becomes a black mark and lowers future value?
Just something I was wondering about.
Personally speaking, I do my condition inspections on my RV-12, but I built it. and I do probably 90% of grunt work of the condition inspection on my RV-10 that I bought 5 years ago, but I have an A&P that has the final sign off. and will likely continue that. A future buyer can always change the limits themselves.
Soooo, before we all rush off to change our op limitations, I wonder if we should consider this question. Might a buyer of an EAB find more comfort in knowing that only the builder or an A&P could possibly have done the inspections of the homebuilt they are considering buying as opposed to a 16 hour participation trophy holder? I for one, having taken that 16 hour course, was less than impressed with the instruction provided. And even if it was awesome, which it wasn't. it's still only 16 hours. One of the guys in my class tragically killed himself because of the botched controls on his 12 that resulted in an SB (SB-00102). His error would have been obvious to a trained mechanic. What if changing the op limitations to allow less qualified folks to sign off on your condition inspection might have the opposite effect and becomes a black mark and lowers future value?
Just something I was wondering about.
Personally speaking, I do my condition inspections on my RV-12, but I built it. and I do probably 90% of grunt work of the condition inspection on my RV-10 that I bought 5 years ago, but I have an A&P that has the final sign off. and will likely continue that. A future buyer can always change the limits themselves.
Good points, but your classmate’s error could have easily occurred outside a condition inspection, given who is allowed to work on EAB's.
The rest of your concerns sound like something that would easily be covered under a competent pre-buy.
I’ve dealt with enough borderline A&P’s that just because some signature has “A&P” next to it says very little extra to me.
This is a large reason why I’ve been assisting with all my CI’s for the last decade and plan on changing my limitations as soon as able.
Last edited:
My thoughts also
Jerry Fischer
Well Known Member
DUG, you're giving yourself a headache when you don't have to, and by the way, did you obtsin WRITTEN Permission to use the Navy's Black Cat Squadron logo as your avitar? See, the government has eyes and ears everywhere...
Story of my life. And actually I think the Navy and I are in the same boat, we both might want to get permission from whomever owns Felix the Cat. But it’s a parody of a parody so I’m going with a “fair use” defense to copyright infringement.DUG, you're giving yourself a headache when you don't have to, and by the way, did you obtsin WRITTEN Permission to use the Navy's Black Cat Squadron logo as your avitar? See, the government has eyes and ears everywhere...
IMO, inspections are for finding things. A buyer can simply start all over with a new inspection from a competent source, so no baggage from past inspection deficiencies. I definately would not fly home in a plane I bought from someone doing CIs with their 16 hrs of knowledge. Maintenance and building on the other hand is a whole nother animal! The best inspector in the world can't find mistakes someone made inside the engine they overhauled. Just did an IRAN on a 360. Engine came apart and we found a counter weighted crank with the ears machined off leaving too little meat on the crank: red tag from ASI (they said Unsafe and wouldn't touch it with a 10' pole). Owner maintainance is allowed for all experimental aircraft and I would be FAR more concerned with shoddy work and sub standard parts that were installed in areas that can't be seen, or easilly seen, by inspectors. I still cannot believe some of the things I have seen looking over RVs; And that is just what is visible via inspection.
So, IMO, someone doing their own inspections shouldn't have a hit on value and each exp plane needs to be approached with the risk that who knows what could have been done to it over it's life.
This is really something to think about…. And not just in the sense of resale value, but in terms of your own 9and your passengers) safety.
Let’s look at a different example that I use all the time when talking about flight testing. As far as the regulations are concerned, you can legally get out of your C-150 after your (passed) private pilot check ride, and get right in a fixed-gear fast-glass airplane with a 199 HP motor and do its first flight, with 40.1 hours in your logbook. Does that sound like a good idea to you? I think most folks would be “uhhh….let’s think that through again…”
If you BUILT an airplane, you have probably spent several thousand quality hours with it and know every nut, bolt and washer. If you are an A&P, you have the equivalent of 3,000 hours of training and practice. If you are inspecting a certified airplane, you have the A&P time plus three (or is it five…I forget) years of demonstrated experience as an A&P plus additional training and testing. Let’s stack that up against a 16 hour, two-day course…..Hmmmmm….
If you have built previous airplanes and decided to buy one from your buddy, you have all that building experience and have done inspections before, so I think there is a pretty reasonable use of the new authority to inspect an airplane that you bought.
I am ALL for more freedom to do what we want in the experimental world, but I do pause when we realize that in the case of anything bigger than a single-seater, we are putting potentially unsuspecting passengers at risk…. So let’s use the new authority (and responsibility) wisely!
The problem here is thinking that trained mechanics don't miss things. I have an airplane in for inspection that had 3 prior ACI done by an A&P, with some important things that were missed. Very obvious rigging issues. Things that the new owner, a student pilot, noticed immediately and brought to my attention. No way to know if the 'trained mechanic' looked at things and didn't see them, or just didn't bother looking. I suspect they never looked, as evident by certain fairings still sealed up by the builder's original vinyl wrap job. I see complacency, training and experience spoiled by a hazardous attitude.
The botched controls in the accident that you mention were built wrong. Presumably, that aircraft went through an inspection by the FAA and/or a DAR. That's one of the highest levels of inspection authority we can encounter, and it was missed. The error was not obvious to the DAR. Or, they never looked. Complacency again. Inspection with a hazardous attitude.
Training is important. Experience is important. Certification level plays a role, but it's usually a red herring in the context of GA safety.
not really. Got two A/W certs via FSDO personnel. Total time inspecting the plane was approximately 5 minutes both times. Both guys said that confirming the plane was safe and airworthy was entirely on the builder and why I was required to sign a doc that the plane was safe and airworthy. One guy even had me run the elev trim and told me it was setup wrong, but iut wasn't. He said oh yea, your right it moves opposite from the elev.
Thank you for providing additional examples of hazardous attitudes by those with higher levels of certification.
Some reference material if you are interested in learning more...
I don't think it is a hazardous attitude. The FAA is pretty clear that it is the builders job to determine airworthiness at certification time not theirs; At least that is my read on the regs. IIRC, I even had to have that certification notarized so there would be no confusion on who was attesting to that fact. One guy went so far as to be sure that I understood that he was no doing anything A/W related and it was all on me. Many folks want a complete inspection by someone else and the FAA has the DAR program to help folks looking for that. Many of those guys are very experienced.
Last edited:
I see a bigger problem with liability. If someone buys an RV from the original builder and changes the operating limits to include CI's from a new owner with only 16-hours of mostly classroom time, and since the actual manufacture on the nameplate is the original builder, then if something goes wrong after the aircraft is sold and condition inspected by the new LSRI owner, then who takes the "liability hit", especially if the new owner botches the CI due to lack of experience and/or guidance. After many years of performing owner assisted annuals and general maintenance on many other type certified airplanes, and then building an RV-9A and performing 21-years of CI's on it, I see the responsibility as nothing short of "huge" each time I sign-off on another condition inspection. And, if I don't know something, I find someone who does, or I consult my thick AC 43-13 (-1B, -2B) manual.
Last edited:
Yet one more issue on the pile of reasons I am afraid to sell the planes that I built.
These last few posts show why you should pick your inspector carefully. Technically all we are required to confirm is that the aircraft meets the requirements of §21.191. Most DARs, at least the ones that I know, will give a very thorough inspection, but it is not required.
As to the comments about an inspector missing things, of course, no one is perfect. BUT, an experienced inspector has a much better chance of finding discrepancies than a wet-behind-the-ears repairman.
As Paul pointed out an A&P has roughly the equivalence of 3,000 hrs. experience. And that's plus the experience he/she has gotten in the field after
issuance of the certificate. Is that equivalent to a 16 hr. course?
Your call!
As to the comments about an inspector missing things, of course, no one is perfect. BUT, an experienced inspector has a much better chance of finding discrepancies than a wet-behind-the-ears repairman.
As Paul pointed out an A&P has roughly the equivalence of 3,000 hrs. experience. And that's plus the experience he/she has gotten in the field after
issuance of the certificate. Is that equivalent to a 16 hr. course?
Your call!
I guess I'll just say thanks again.
(BTW, I mentioned that significant rigging and binding problems made it past the last 3 ACIs performed by a Mechanic/IA. I forgot to include that the individual is also the DAR that signed off the AW cert.)
It's also important to realize that after an EAB receives it's airworthiness certificate and starts receiving annual CI's and general maintenance there after, complex repairs come-up (i.e. removing things to get to the actual thing you are working on). If not inspected properly, such work can also lead to an EAB becoming unsafe. Therefore, follow-on annual CI's and post maintenance inspections become just as critical as the original airworthiness inspection!
That's really the relevant part for this thread and I apologize for taking things off track to AW inspection.
My point was for owners to avoid the pitfall of assuming that cert levels guarantee some quality of inspection. Most of us have seen enough examples to know better, yet the argument is made when it's expedient against the 16 hour edge case. An A&P/IA asleep at the wheel can be just as bad as a 16 hour trainee that is in over their head. Neither should be performing inspections.
Thanks Paul for expanding on this. Hmmmmm is right! These are things to think about. And yes, I completely agree that the risk is not just resale. I just picked that one peel of the onion. Passenger safety, of course....Liability as others have mentioned, that's another hairball. Am I supportive of more freedom in the experimental world? You bet! As long as we don't pee in our own pool. But I also pause and think about unintended consequences of changes in regulations.
Continuing: Do I think one can sleep easy just because a certificated mechanic inspects a plane, No...but it helps a bit. I will say that I benefit and learn a ton working with a very competent A&P IA (tens of thousands of hours if i had to guess) on my EAB Annual condition inspections and almost year every we always find something that hopefully blocks off one hole in some swiss cheese. I like to think that it also improves the quality of my maintence work the other 51 weeks of the year. Would I have hired him do an owner assisted ACI without the (former) regulatory requirement? Maybe, maybe not. but the requirement definitely precipitated our actions. and I think we'd be naive to not assume that lesser requirements in the fleet will also precipitate lesser actions with some unfortunate consequences. So long after this thread is gone we will still have the new regulations and the good and bad that comes with it. Despite our human tendency to belive the contrary. We all aren't above average.
Paul benefitted from NASA. Full disclosure, I benefitted from Rickovers Nuclear Navy where I had the opportunity to grow up as an engineer and learned the importance and resulting humility of a (staggering) level of checks and balances. And definitely No sloughing off responsiblity. One of my favorite Rickover quotes that I had hung above my desk for many years.
“Responsibility is a unique concept... You may share it with others, but your portion is not diminished. You may delegate it, but it is still with you... If responsibility is rightfully yours, no evasion, or ignorance or passing the blame can shift the burden to someone else. Unless you can point your finger at the man who is responsible when something goes wrong, then you have never had anyone really responsible.”
First, thanks for your service!
I have watched a couple of documentraries about rickover and his approach to safety, accountability, and compliance. An impressive man to say the least. I can't think of a better breeding ground for developing discipline in considering the consequences of inexperience. I am sure you will make good choices and fully respect your limitations.
Yes -- there are a few "pencil whippers" out there, but I have found that A&P's who encourage "owner assisted" inspections and maintenance are generally the best people to have while you are learning! And, better yet are the folks who teach A&P.
Had my appointment this morning at the Atlanta FSDO. So have a freshly minted "Temporary Airman Certificate" for "Repairman (Light-Sport Aircraft)"
<Engage Cheering> Probably the 1st one in Atlanta since MOSAIC became active. The examiner had to look up a lot before he could help me.
However, there is still no guidance yet for the operating limitations change and the Certificate Number says "Pending". So I can't sign anything until the the real certificate shows up and there is a way to update the operating limitations.
FWIW,
Mark Napier
<Engage Cheering> Probably the 1st one in Atlanta since MOSAIC became active. The examiner had to look up a lot before he could help me.
However, there is still no guidance yet for the operating limitations change and the Certificate Number says "Pending". So I can't sign anything until the the real certificate shows up and there is a way to update the operating limitations.
FWIW,
Mark Napier
I've been told by someone attending the class that pending is enough to sign, no need to wait for other than operating limitations.
So under MOSAIC, let's say a guy owns a Cessna 172, and the owner holds an LSRI. Since it's considered a "type certified" aircraft, can the LSRI owner or any LSRM perform and sign-off maintenance and annual inspections? Or, does the aircraft first need to be reclassified under the Light Sport category even though any pilot can fly that same aircraft under MOSAIC Light Sport rules using a drivers license as their medical?
So how did they do this when the big FAA official guidance is to wait on the regulations to be released before issuing anything? Greensboro FSDO has us all in the holding pattern.
This is what the Lancair forum admin posted, he is currently at the class.
"We expect to obtain the certificates in January but we will have 120-day temporary certificate upon completion of the course and those can also be extended for 120 days until the permanent is supplied. During that temporary certificate period, we will be able to exercise the privileges of the LSRM certificate by signing with certificate "Pending" and the date of temporary issuance. Good to go out of the gate."
FORANE
Well Known Member
Unless said C172 has been converted to a ELSA, a LSRI or LSRM may not sign-off maintenance and annual inspections on the C172. MOSAIC allows a C172 to be flown as a LSA but doesn't change its type certification.
NO! A certified aircraft will always be a certified aircraft and must be maintained per part 43. Mosaic does not change the certification of any aircraft.
MOSAIC simply says that the C-172 meets LSA parameters and Cessna "could" build one, certificate it as an S-LSA, then offer a "light sport kit".
P.S. THIS AIN'T GONNA HAPPEN!
Last edited:
Okay -- that's what I thought, and that seems correct and logical -- I'm an RV-9A EAB builder/repairman, who will probably never fly a C172 again anyway.
The confusing part to me is allowing a "type certified" aircraft to be operated under Light Sport rules? Is this truly what the FAA had in mind for MOSAIC, or does a MOSAIC S-LSA pilot (drivers license medical) need to fly some new Light Sport version of the Cessna such as C172-S-LSA to be legal?
I think it allows a C172 to be flown by a Sport Pilot. I don’t think “flown as a LSA” is a thing. But it’s MOSAIC, so I could be wrong.
