Is an A&P required to do Rotax engine work for hire?

[3kdscf]

I am really confused, what credentials are required for someone to do Rotax engine work for hire? I thought that an A&P was the minimum but when you use the Rotax "service finder", it shows you a bunch of people who have taken a two day class but have no A&P. Is that legal? Did I miss some change to the FARs? Is this part of the difference between "light sport" regulations and "experimental" regulations? My Kitfox is registered as experimental and I need to find someone who can do my gearbox inspection right.

[Eric Page]

Yes, you hit on the answer. Legally speaking, anyone can work on an Experimental aircraft and its engine. The only time an A&P is required is to sign off an "annual" condition inspection, and then only if the owner doesn't hold the repairman certificate for the aircraft. You could hire anyone you like to overhaul an engine for an Experimental, Rotax or otherwise.

Rotax has maintenance training programs at five different levels, at various course lengths. The first four are available to anyone, but the overhaul course is not. Quoting from the RFSC website, "The 9 Series Overhaul course is available by invite only. Applicants must meet both facility and training requirements to be eligible."

[rv9ralph]

You could hire anyone you like to overhaul an engine for an Experimental, Rotax or otherwise.

You are correct Eric concerning doing the work on an Experimental AB aircraft, with one addition. The owner has to sign off the work.

[Eric Page]

Yes, indeed. Thanks Ralph!

[3kdscf]

Yes, you hit on the answer. Legally speaking, anyone can work on an Experimental aircraft and its engine. The only time an A&P is required is to sign off an "annual" condition inspection, and then only if the owner doesn't hold the repairman certificate for the aircraft. You could hire anyone you like to overhaul an engine for an Experimental, Rotax or otherwise.

Rotax has maintenance training programs at five different levels, at various course lengths. The first four are available to anyone, but the overhaul course is not. Quoting from the RFSC website, "The 9 Series Overhaul course is available by invite only. Applicants must meet both facility and training requirements to be eligible."

No wonder I was confused! Thank you for the clarification!

[3kdscf]

You are correct Eric concerning doing the work on an Experimental AB aircraft, with one addition. The owner has to sign off the work.

Ah, that makes sense. Not that I need more motivation to find a competent mechanic but the fact that I assume legal responsibility for their work makes it even more important.

[Delta Whisky]

RV9ralph - I'll have to admit that your comment "The owner has to sign off the work" sent me off into the vastness of the internet and I learned a lot about a bunch of similar or related questions but not this one specifically. For example, one was "Can a repair shop sign off the required 411 or 413 transponder test?" (It took a long letter of interpretation from the FAA but the answer is yes! - thank goodness cus that's where I get mine done.) But I still haven't been able to nail down why anyone can't perform maintenance on an experimental AB aircraft. More to the point - sign off the work. Can you point us to the reg or other trusted answer source? (In other words: I give up on the research.) I know it may be a case of CDO (OCD alphabetized) but inquiring minds want to know. Why is it of interest to me one might ask? I know of several pilot owners that take their planes to other folks for work that they, the owner, feel uncomfortable performing and certainly are not capable (therefore) of approving the work by a signature. Thanks.

[13brv3]

This is about the best article you could hope for on the question of EAB logbook entries.

https://www.kitplanes.com/aircraft-r...-and-logbooks/

Aside from some specifically required entries, it sounds like there's a lot of this that's open to interpretation. I could swear I was told that EAB logbooks didn't require any entries other than the ones specifically called out in the regs, such as the annual conditional inspection, major mods or repairs, and some equipment stuff. Since anyone can do maintenance on an EAB, I'm not sure anyone really needs to "sign it off". I'd put anything significant in there just for a proper maintenance record, but I'm not convinced you're legally required to.

As for the original question, if you want the gearbox inspection done in a way that gives you full confidence, I'd stick with one of the big service centers. Rotax seems to make it difficult to find those, but Lockwood, LEAF, South MS Light Sport, Roger Lee's shop, etc. I'm sure there are many more.

Rusty

[rv9ralph]

From Delta Whiskey:

RV9ralph - I'll have to admit that your comment "The owner has to sign off the work" sent me off into the vastness of the internet and I learned a lot about a bunch of similar or related questions but not this one specifically.

Like you, I cannot refer to a specific section of the FARs. My statement was based on information I have gathered over the years talking to A&Ps, IAs, articles I have read, conversations I have had and presentations at EAA meetings by FAA FSDO reps.

The concern here is who can do work and sign off for work on an E-AB aircraft. By my experience through the above sources is that the owner can do any work on the E-AB certificated aircraft (except sign off the Condition Inspection unless being the holder of a Repairman Certificate for that specific aircraft). The FARs do specify that there must be a record kept of that work and the person signing off that work must enter their certificate number. In the case of the owner, that would be their pilot certificate. If work is done by a non certificated person, that work should be done under the supervision of the person returning the aircraft to service and the signature would be the owner. Operating Limitations issued for specific aircraft may outline this depending on when they were issued.

However, I will state that anything I have written may be challenged by anyone and different FSDOs will interpret things as they wish. Just try to stay as informed as possible.

[Maverick]

I believe that this applies to motors like the C-O200, L235, etc. I do not know whether the Rotax 912 falls into this category. My understanding is that if an EAB plane has a certified engine and you wish to keep the engine certified, all work on the engine must be signed off in the logbook by an A&P. Simply placing a certified motor on an EAB airplane does not change the requirements for engine maintenance unless you decertify the engine by removing the engine data plate (serial number). This applies to builders too, i.e., I am not an A&P but installed a C-O200 on one of my EABs thus, I had to have the annual inspection of the engine done by an A&P because I wanted the engine to remain as a certified engine. Once the engine is decertified, it cannot be recertified unless it is restored to zero time by a certified engine shop and the data plate restored. Of course all history of the engine must be documented in a separate logbook for it.

I had the gear box on a 912 ULS inspected by California Power Systems.