New Inspection Privileges for Amateur-Built Aircraft May Require New Operating Limitations
By EAA Staff
The rule changes implemented by MOSAIC, Sport Pilot 2.0, on October 22 included a long-sought condition inspection option for owners of experimental amateur-built (E-AB) aircraft. In addition to the privileges already held by E-AB builders with repairman certificates and certificated FAA mechanics, holders of light-sport aircraft repairman certificates with an inspection (LSRI) or maintenance (LSRM) rating may now perform condition inspections on E-ABs, as detailed below. Contrary to what the names of these certificates may suggest, these privileges apply to all E-ABs, whether or not they meet the updated parameters for light-sport category aircraft.
The LSRI certificate can be obtained through a 16-hour course, and applies to aircraft the holder owns (FAA sources have indicated to EAA that aircraft owned through LLCs are acceptable). The LSRM certificate is nominally a three-week course, and grants commercial maintenance and inspection privileges for any aircraft certificated in the light-sport category*, and now any E-AB.
These are welcome options for many E-AB owners who, unlike experimental light-sport aircraft (E-LSA) owners, cannot obtain inspection privileges for their own aircraft if they were not the original, primary builder. EAA has long advocated for these privileges and was pleased to see them included in the final MOSAIC rule.
One barrier remains for many E-AB owners: operating limitations. No matter what the regulation provides, experimental aircraft operating limitations take priority and have the force of regulation under 14 CFR 91.319(i). Most aircraft certificated after, at the latest, 1994 have an operating limitation stating that condition inspections may only be performed by amateur-built repairmen, “an FAA-certificated mechanic,” and in some cases repair stations. LSRI and LSRM do not fall into these categories. Carefully review your aircraft’s unique set of operating limitations, as there can be significant variation from aircraft to aircraft (particularly older aircraft certificated when standardized limitations were less common).
In cases where this operating limitation exists, E-AB owners will need to obtain new operating limitations to take advantage of the new LSRI and LSRM rules. This is a paperwork exercise with either the owner’s local FSDO or a designated airworthiness representative (DAR).
Complicating the matter, however, is that the document detailing these new operating limitations is yet to be published due to the ongoing shutdown of the federal government. Order 8130.2L will contain this new guidance to inspectors and designees, but it is not officially an active document. We anticipate this being resolved shortly after the shutdown ends.
Many owners of experimental aircraft are wary of updating their operating limitations. This is understandable, as standard operating limitations change from year to year. EAA recently compared operating limitations issued in FAA Order 8130.2C (1994-1999) to 8130.2K (2024-present) and found that for most aircraft in most use cases there was little fundamental difference. Some special cases, such as turbine aircraft, may have more restrictions in newer versions, while some operating limitations have actually become more flexible in newer versions.
EAA is exploring other methods for enabling LSRI and LSRM to perform inspections on E-ABs. For the foreseeable future, however, an operating limitation update is necessary if the restriction exists. For owners concerned about updating to the latest version of operating limitations, EAA highly recommends carefully comparing the aircraft’s operating limitations to those found in the current revision of Order 8130.2, and the new version when released, before deciding.
The LSRI certificate can be obtained through a 16-hour course, and applies to aircraft the holder owns (FAA sources have indicated to EAA that aircraft owned through LLCs are acceptable). The LSRM certificate is nominally a three-week course, and grants commercial maintenance and inspection privileges for any aircraft certificated in the light-sport category*, and now any E-AB.
These are welcome options for many E-AB owners who, unlike experimental light-sport aircraft (E-LSA) owners, cannot obtain inspection privileges for their own aircraft if they were not the original, primary builder. EAA has long advocated for these privileges and was pleased to see them included in the final MOSAIC rule.
One barrier remains for many E-AB owners: operating limitations. No matter what the regulation provides, experimental aircraft operating limitations take priority and have the force of regulation under 14 CFR 91.319(i). Most aircraft certificated after, at the latest, 1994 have an operating limitation stating that condition inspections may only be performed by amateur-built repairmen, “an FAA-certificated mechanic,” and in some cases repair stations. LSRI and LSRM do not fall into these categories. Carefully review your aircraft’s unique set of operating limitations, as there can be significant variation from aircraft to aircraft (particularly older aircraft certificated when standardized limitations were less common).
In cases where this operating limitation exists, E-AB owners will need to obtain new operating limitations to take advantage of the new LSRI and LSRM rules. This is a paperwork exercise with either the owner’s local FSDO or a designated airworthiness representative (DAR).
Complicating the matter, however, is that the document detailing these new operating limitations is yet to be published due to the ongoing shutdown of the federal government. Order 8130.2L will contain this new guidance to inspectors and designees, but it is not officially an active document. We anticipate this being resolved shortly after the shutdown ends.
Many owners of experimental aircraft are wary of updating their operating limitations. This is understandable, as standard operating limitations change from year to year. EAA recently compared operating limitations issued in FAA Order 8130.2C (1994-1999) to 8130.2K (2024-present) and found that for most aircraft in most use cases there was little fundamental difference. Some special cases, such as turbine aircraft, may have more restrictions in newer versions, while some operating limitations have actually become more flexible in newer versions.
EAA is exploring other methods for enabling LSRI and LSRM to perform inspections on E-ABs. For the foreseeable future, however, an operating limitation update is necessary if the restriction exists. For owners concerned about updating to the latest version of operating limitations, EAA highly recommends carefully comparing the aircraft’s operating limitations to those found in the current revision of Order 8130.2, and the new version when released, before deciding.
