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FAA Issues New Interpretation on Manufacturer Required Training and Your LSA

The Rotax training requirements for Special Light Sport Aircraft (S-LSA) have been one of the most misunderstood and debated issues since the implementation of the light sport rule. Since Rotax manufactures about 85% of all engines installed on S-LSAs, it is essential for mechanics, repairmen and owners alike to understand the training requirements necessary for compliance.

Rotax has an extensive training program available under the Rotax Flying and Safety Club (RFSC). This is the only approved independent Rotax Maintenance Technician (iRMT) training organization for the United States, Central and South Americas. The program consists of three specialty classes for the Rotax 9 Series engines (the 9 series covers the 912 and 914 engines) and one for the Rotax 2 Stroke. There are three 2-day classes for each of the following: 9 Series Service Course, 9 Series Maintenance Course and a 9 Series Heavy Maintenance Course. A 2-day Maintenance Course is also offered for Rotax 2 stroke engines.

Rotax has published in their manuals that all mechanics, repairmen and even owners are required to take the above classes to perform any service, maintenance or repairs to their engines or their customers’ engines as applicable. For example, Rotax requires that an owner take the service level course to perform any preventative maintenance. Further, Rotax requires the Service Level Course as a prerequisite to the Line Maintenance Course. Additionally, Rotax requires recurrent training every two years.

Until February 2012, the FAA Light Sport Branch agreed that Rotax, as an ASTM engine manufacturer, had the right to impose this training. Initially, their stance was based on both the interpretation of the regulations as well as the ASTM standards (formally, the American Standards for Testing and Materials, today ASTM International). The ASTM standard for

maintenance lays out a system governing how maintenance, repairs and alterations are handled, including required documentation. The standards clearly allow the manufacturers to list the level of certification and training required to perform all work.

The initial rationale, that the ASTM standards must be adhered to, was founded on the fact that all Special Light Sport Aircraft (S-LSA) are certificated based on a signed statement of compliance which warrants that the aircraft meets certain FAA Accepted ASTM standards rather than an FAA approved type-certificate like Standard Category aircraft. Therefore, in order for the S-LSA to remain compliant, it was concluded that the aircraft must be maintained in accordance with these standards. However, the issue was a continual subject of debate.

Finally, in October 2011, I wrote a letter to the FAA Office of the Chief Counsel. The Chief Counsel provides legal counsel and legal interpretations of the FAA regulations. In my letter I requested a determination as to whether a mechanic or repairman must complete “factory training” and “recurrent training” that has been “mandated” by Rotax in its maintenance manual for an engine installed in an aircraft issued a special airworthiness certificate in the light-sport category prior to performing work on that engine and approving the aircraft for return to service.

On February 2012, I received a formal interpretation from the Chief Counsel clearly stating that Rotax can not mandate the completion of any initial or recurrent training in order for a certificated mechanic or repairman to perform work on an aircraft engine.

They further stated that the FAA regulations do not mandate completion of initial or recurrent training prior to the performance of work by a certificated mechanic or repairman.

The Chief Counsel determined that, “Although manufacturers may reference regulatory requirements in their maintenance manuals, they may not impose additional requirements on mechanics or repairmen that are not contained in the regulations. The FAA recognizes that some manufacturers have placed what they deem “training requirements” in their maintenance manuals and that these provisions may be consistent with consensus standards accepted by the FAA. These maintenance manuals however, are not FAA approved and without a regulatory basis, these training provisions are non-enforceable.”

It is important to include here that “The FAA strongly encourages mechanics and repairmen to obtain both initial and recurrent training. Training provided by a manufacturer may provide a mechanic or repairman with a means of obtaining the necessary understanding of the methods, techniques and practices required to properly perform work on an aircraft and its components. A manufacturer may not use a maintenance manual to impose a training requirement on a certificated mechanic or repairman that is not set forth in a regulation.”

FAA Legal did reference Part 65.81 which basically states that a mechanic or a repairman may not perform any task unless he has satisfactorily performed the work concerned at an earlier date- the “you can’t do it unless you’ve done it before” rule. If this is the case, the regulations say “(the mechanic) may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic or a certificated repairman who has had previous experience in the specific operation concerned.” For example, if you have successfully changed the oil in a Continental engine then you have successfully performed that work before and you may legally change the oil in a Rotax engine.

There are critical differences between the Rotax engines compared to the Continental or Lycoming engines.

So I do want to encourage you to get Rotax specific training, but that training does not have to be Rotax factory training and once you have the initial training, as far as the FAA is concerned, there is no regulation requiring recurrent training.

What about aircraft owners and preventative maintenance? Many S-LSA owners have spent the time and money to take the Rotax Service and Line Maintenance Courses and mistakenly believe they can legally complete line maintenance and the yearly inspection on their Rotax engines.

However, the Rotax Certificate DOES NOT stand alone. As an S-LSA owner, you can take any of the Rotax courses; very valuable information, but you can legally perform preventive items without the course. However, the Line Maintenance Course and Heavy Maintenance Course, while useful information and excellent for any aircraft owner, will not allow an owner to perform maintenance on an S-LSA without the Repairman Maintenance Rating or an A & P certification. The bottom line: if you own an S-LSA, you must hold an A & P or a Light Sport Repairman Maintenance rating to benefit from the Line Maintenance And Heavy Maintenance Rotax Training Courses. A person must have the LSRM or an A & P and the Rotax certificate to maintain and perform the required inspections an S-LSA.

We do offer the Rotax Factory Training in our 3 week 120 hour Light Sport Repairman Maintenance (LSRM) course. I have found that our graduates find the course invaluable; however, most believe that the recurrent training is difficult to carry out and many are hoping for an online renewal option.

There are benefits to the Rotax Factory Training. It is the only Rotax approved training in the United States.

Mechanics and repairmen who are interested in setting up a Rotax Service Center need to remain current with the Rotax Factory Training Program.

And finally, if you are interested in providing Rotax warranty work, you should consider the Rotax Factory Program.

The Rotax Factory training is available in four locations in the United States: Lockwood Aviation in Sebring, FL, CPS in Corona, CA, LEAF in Lyons, WI, and at South Mississippi Light Aircraft in Lucedale, MS.

What you need to know about the Rotax training courses and your Experimental Aircraft:

It is just as common for the owner of an E-LSA to be confused and believe that he must take the Rotax courses to perform maintenance or service on his Rotax engine. However, when it comes to an Experimental Aircraft there are no requirements to hold a Rotax certificate to perform any maintenance or service. The Rotax courses, while useful information and highly recommended, are not required to maintain a Rotax on an experimental aircraft. The training is not even required to complete the inspection as a Light Sport Repairman with an Inspection Rating. However, even if your aircraft is Experimental, there are likely certain types of maintenance procedures you may want training for or may prefer to have handled by a certified Rotax Maintenance Technician.

Repairman Maintenance Rating (for S-LSA)

This rating allows you to perform maintenance and the yearly condition inspection on S-LSA’s and E-LSA’s for compensation or hire. It requires the completion of a course on the maintenance requirements of various lightsport aircraft.

Repairman Inspection Rating (E-LSA only – does not apply to S-LSA)

This rating allows you to conduct the yearly condition inspection on an E-LSA you own. It requires the successful completion of an FAA accepted, 16-hour course on the inspection of your particular class of LSA.

 
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August 2012 Light Aviation Edition

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