 Good morning, everyone. Welcome to Sun and Fun, 2008. We had a beautiful morning this morning with more than 20 balloons going across the sky on a beautiful, still morning. Tom Markott, our speaker this morning, is with the Light Sport Branch for Aircraft Certification. Tom's been an Airworthiness Inspector for more than 21 years and he's certified in both Rotor Ring and Fixed Wing. He's only been with this new job for six months and he's excited because he's learning new things, something that keeps him young, keeps us all young. Tom is excited about the way the new aircraft are configured, the high wing, the low wing, the open cockpit. And this job is a learning situation for him and an exciting one. As his job continues, he will be looking at the Light Training Centers, Light Sport Training Centers to be sure that the training that Light Sport people are getting is appropriate and adequate to the work you're doing. It's an exciting field. It's one that is evolving and we need all of us together to make this work. Tom has a lot of information for you this morning. So, if during his presentation a burning question comes, we really want you to raise your hand and we'll come to you with the microphone, ask your question. So, Tom has an opportunity to really give you an answer on the spot. Please welcome our speaker this morning, Tom Marcotte. Thank you. Appreciate it. Good morning and welcome to everyone here. This is a new experience for me to make a presentation like this and as Christine says, we want to talk this morning about the Light Sport aircraft certification and also we want to talk about the Repairman certification for Light Sport aircraft. My background as she stated, I've got 21 years with the FAA but only six months in this branch and I've worked on both rotary wing and fixed wing aircraft in the Army Reserve for 16 years so I have been around smaller aircraft but nothing this small in the past. You know, the FAA has a regulation for everything and the regulation covers the Light Sport aircraft certification as 21190 and 21191. Also, there are instructions on how to do all of these things and that's in the FAA Order 8130.2F. Excuse me. But first thing we want to do is find out what a Light Sport aircraft is and there's some things in here that they're kind of hidden when you when you first read these definitions and this is in part one of the Federal Liberation Regulations and I'm going to read this to you. It says, Light Sport aircraft means an aircraft other than a helicopter or a powered lift that since its original certification has continued to meet the following. Now before we give you this criteria I want to emphasize here that where it says that since its original certification and you may think that well, you know, Light Sport aircraft is brand new. There weren't any certificated aircraft before Light Sport come about that would work as a Light Sport aircraft but we will look at that again later also because there are some aircraft that can be flown by sport pilots that are already certificated today but the definition of a Light Sport aircraft is has a maximum takeoff weight of 1320 pounds or 1430 pounds for operation over water. It has a maximum airspeed and level flight with continuous power of 120 knots. It doesn't give you a V&E speed for the Light Sport aircraft but there is a V&E speed for gliders which is 120 knots. The aircraft has to have a stall speed of 40 maximum of 45 knots without lift enhancing devices. The aircraft can only have a capacity of two persons including the pilot. It has to it has to have a single reciprocating engine if powered. Now in the preamble to the regulation there's some comments in there about reciprocating engines and it includes the Wankel engine and diesel engines so therefore Wankel engines are included and diesel engines are included if you can ever find one light enough to put in an aircraft. Another thing that has come about in the last few months of these type of aircraft are electric aircraft. We looked at one a few days ago that this thing had an 18 horsepower electric motor with a bunch of batteries below the seat. This does not fit into the Light Sport category because the regulation says it has to have a reciprocating engine. It may not fit into the ultra light category because it's over the 254 pounds because of the multitude of batteries that it has on it. So the electric aircraft this is a trike that had this electric power may have to go into the experimental amateur built category. The propeller on these aircraft has to be fixed pitch or ground adjustable if a powered aircraft other than a glider and it has to be fixed pitched or auto feathering if it's on a glider. That means anytime the engine is shut down whether intentionally or if they have an engine failure the prop has to feather on this thing. The gyroplane has to have a semi have a fixed pitch semi rigid teetering two blade rotor system. If you have a cabin on this aircraft it cannot be pressurized. The aircraft has to have a fixed landing gear except for an aircraft intended for operation on water or a glider. These exceptions are if it has a hull on it I mean if it's a water operation it can have a hull or it can have retractable landing gear. The picture that you see up there is one that has a hull on it. There has been some discussion about if you have a trolling motor on this hull to get you around while you're on the lake going out to where you want to take off whether that's a 20-engine vehicle or not and I don't know what the outcome of that is. There's been some discussion about it and you're actually not powering the aircraft with the trolling motor you're just moving the aircraft around the water. It can have a retractable landing gear if it's a glider or it can be fixed. Another thing that we want to look at here is going back to these aircraft that were certificated before light sport that qualify for light sport is there's no mention here of the of the type of airworthiness certificate in this definition of light sport. Excuse me. When you look at the different types of light sport aircraft we have the single single engine land. The one up on the left is a primary aircraft it's a J3 Cub. The one on the right there is the the ultra light like two place that was used as a trainer before light sport came about. Of course then on the lower left is the SLSA or the the consensus standard aircraft. You can have a lighter-than-air aircraft glider both powered and non-powered and the gyroplane. The gyroplane cannot be an SLSA because there are no accepted consensus standards for gyroplane aircraft at this time so that that can only be the experimental aircraft. The two newest categories in light sport are the weight shift control and the powered parachute. Matter of fact I just took my first ride in a weight shift control just a day or two ago and it's really exciting to me. I flew in powered parachutes back in the early 90s but the these two type of aircraft are the newest types in the light sport category and they're a lot of fun. What is not a light sport aircraft when you look at the things that cannot be light sport aircraft that somebody might want to make a light sport aircraft if it qualifies for a 103 ultra light it cannot be a light sport aircraft. Something has to be changed on it to make a light sport. Whether powered or unpowered the hang gliders, paragliders and training exemption holders cannot be light sport. Also multi-engine aircraft, powered lift helicopters or complex aircraft with retractable gear except those working over water or glider. Also if you have a propeller that's controllable pitch inside the cockpit you can't make that a light sport aircraft. The training exemption that was in effect for a number of years for the ultra light like aircraft or what they call the fat ultra light no longer exists that went out January the 31st 2008 so people who did not get their aircraft converted or registered in registered by January 31 2008 no longer have the opportunity to make these a light sport aircraft. There are three possibilities for an aircraft to be a light sport aircraft and this is where we're going to talk about the certification of the aircraft. There's the SLSA which is a special light sport aircraft. This is a new aircraft manufactured to the industry developed consensus standards and these standards are accepted by the FAA they're not approved. It's kind of like the automotive injury where they have standards that they build their automobiles to and they are self-regulated in keeping these things up to the standards. These aircraft are ground tested and flight tested and delivered to the customer in a ready to fly condition and they may be used for compensation or hire in training and towing or for rent. There's five classes of the light sport cut the LS SLSA as the airplane the glider the weight shift control powered parachute and lighter than air. I thought there was a question here but there's not. Another the second of the three possible categories are the ones that we call the eye aircraft. In the regulation 21191 there's an i1 and an i2 and an i3 aircraft. The i1 aircraft are the aircraft not previously certificated that do not meet the definition of 103. Again these are the are normally the ones that were flying under the exemption for training under the light sport category the two-place aircraft and also again they had to be registered by January 31, 2008 and at that time this exemption no longer exists. The second possibility for certification of light sport aircraft is the new aircraft assembled from a kit that meet a consensus standard. Now a new consensus standard kit has to be a part-for-part bolt-for-bolt duplicate of a special light sport aircraft. A company has to get certification of a light sport aircraft under 21191 then they can make all the parts and all the bolts and everything and sell it as a kit. One of the things that does not have to do it is not have to meet the amateur built standard where you over 51%. The customer and the manufacturer determine to what extent this kit is involved or how much has to be done to put this kit together. The third possibility for the experimental is the aircraft that were previously certificated in the special light sport category and they are converted to experimental light sport category and there are a number of reasons for that to happen. One of them is if the person no longer wants to maintain the aircraft as a special light sport he can have it certificated as an experimental light sport. The second possibility is where the manufacturer of the original special light sport aircraft has gone out of business, has not designated someone to take over the production of parts or to keep these things in the air and no one has voluntarily come forward to to help keep this aircraft in the special light sport category and they are automatically converted to the experimental light sport aircraft. In the experimental light sport aircraft area there's there's the same categories of aircraft that is in the special except for the experimental can have the gyroplane in it because it the consensus standard is not accepted there. The third possibility is the previously certificated aircraft and this is what we referred to in the very beginning when it talked about the the previously certificated aircraft the standard category aircraft there are some that meet the light sport definition the J3 Cub the champ and there's well there's a list of them on our website out there of the ones that meet this also the primary primary category aircraft such as the quick silver and the rands meet it experimental category amateur built exhibition also some of them also fall into the light sport definition these aircraft that meet the definition of light sport aircraft but are in the primary or the standard or experimental category can be operated by a light sport pilot because they meet the definition however they cannot be recertificated as light sport aircraft if you remember a few slides back we talked about aircraft that were non-certificated could become light sports in the i1 exemption or i1 regulation another thing that when we think about this the fact that these aircraft that are in the primary or standard or experimental category is just an added benefit to the definition of the rule the rule was originally designed just to cover the the exemption aircraft or the the aircraft that were the two-place trainers and the fact that these others fall into that category now as far as the weight category and the power and everything is just a secondary benefit the airworthiness certificate for the special light sport aircraft is a little bit different than the certificate for the the experimental if we look at the category of the special light sport aircraft it says the the category is light sport aircraft and the purpose is whether is weight shift in this case it can be pirate parachute airplane glider or whatever of course the airworthiness certificate has the the normal information on it the n number the serial number the builder the model the date of issuance and the expiration date if you notice this one the special light sport aircraft has an unlimited expiration date when you have a special air worthiness certificate you also have to have operating limitations on what the aircraft can and cannot do anytime you have a special air worthiness certificate or a pink air worthiness certificate it has to have operating limitations we're going to go into one of these operating limitations in a few minutes because it's it's the one that's going to expire in january two thousand thirty one two thousand ten and we're going to get into that on this airworthiness certificate if you look at this certificate it has the same information except for the category is called experimental the purpose is operating light sport and in the wsc is weight shift control or could have ppc for pirate parachute or airplane or glider also it has the same information as the n number the builder the serial number of the model on this case the expiration date is january 31 2010 so you know from looking at this airworthiness certificate that it has an operating limitation of training on it again operation limitations are required anytime there's a pink air worthiness certificate and this is this is the the limitation 13 this is kind of small so i'm going to read you exactly what this says if the aircraft has experimental light sport operating limitation number 13 which says no person may operate this aircraft for compensation or higher except this aircraft may be used for compensation or higher to conduct flight training in accordance with 91 319e until january 31 2010 at which time this airworthiness certificate on and operating limitation expires so if you're operating i mean if your airworthiness certificate expires you no longer can fly this aircraft but the operation limitation number 13 must be removed prior to january 31 2010 by requesting amended operating limitations through your local flight standing district office if this is not accomplished the airworthiness certificate expires and the aircraft cannot be recertificated as a light sport aircraft this is a fact that needs to be disseminated to all the people in the light sport arena that makes sure that everybody who has training on their operating limitations that they know that they have to get this done before january 31 2010 when we look at this picture right here we appear to have three identical aircraft and the aircraft in looks maybe maybe exactly the same but we have again the i category aircraft the i one is the existing fleet the aircraft which could have been an exemption trainer it can be used for flight training until january 31 2010 the next category is the kit the consensus standard aircraft built from an s l s a model it cannot be used for flight training for compensation or higher then you have the aircraft that was changed from special to to experimental again it cannot be used for training for compensation or higher yes have a question here in the front do we have someone with a microphone yeah who would be the manufacturer for the experimental would be the kit manufacturer would be like for the experimental amateur built you're talking about the the top one there no the the experimental well all of these are experimental aircraft okay but if i bought the kit from the manufacturer would i be the manufacturer of it or would the kit manufacture on the air worth on the consensus standard it would i believe that would be the the manufacturer of the kit i've got another question about i'm going to have to think about that one about how it's registered it may be that you're it's registered as your kit not the manufacturer you would be the right had another question back backtracking just a little bit to the airworthiness certificate if you have one of the certified aircraft like a air coupe right and it has its own airworthiness certificate does that stand in effect with the the original air worthiness certificate right will stay into effect you won't have any changes as far as your your maintenance requirements because it is a standard category aircraft right but it qualifies for a light sport to fly that aircraft because it meets the definition of the the maximum weight the maximum speed everything so nothing changes on the certification but it is eligible for light sport pilot okay thank you i may have an answer to your question in these slides and if not then after this is over then let's get together and discuss that i've got three guys in the back there that are they're working the same office and they can help me get answers to these now the the flight training for compensation or higher is available on the i-1 aircraft those are the exemption aircraft and also towing for compensation or higher if you get your operating limitations amended by january 31 2010 you cannot can no longer do flight training but your towing does not expire you can still do towing after that time frame each experimental aircraft has to have a program letter stating the purpose of the aircraft such as operating life sport and flight training aircraft in the i-1 category when they're going for certification they will have an operating limitation on there of the flight test and you have to designate a flight test area usually it's for five hours even though some aircraft may have existing time on it it's not absolutely necessary to have the flight test area on the i-1 aircraft but if you don't do the the flight test area and you want to make a modification on that aircraft then you have to go to your flight standards district office and get it your operating limitations amended to put the flight test area on it so the best thing to do is to get your flight test area on your original operating limitations then if you change your prop or something like that on the aircraft that's a major modification your test flight area is already designated you make your your modification you go out and do your five hours of test flight you sign it off and you're ready to go again so it's a lot more convenient to whoever does your original certification to have that operating limitation on there rather than six months later or a year later have to go back to the FISTO and get this added to your operating limitations identification on the life sport aircraft the SLSA airplane has to have 12 inch letters or as large as practical the other in numbers on the experimental life sport aircraft and on the SLSA's that are not airplanes have three inch letters also there's placarding that's required on the life sport aircraft on the SLSA by the door or close to it around the door somewhere it has to say life sport if it's an experimental aircraft it has to have the word experimental on it and this is referenced in AC 45 dash two there's also some requirements for the when you say the three inch letters or the 12 inch letters there's some dimensions in the 45 dash two which gives you that the letter has to be two-thirds as wise as it is tall and some information like that so before you put your in number on there you need to look at the dimensions of the aircraft or the in number and the spacing of the numbers I've seen some of them where they're jammed right close together and they're not readable from the from a specified distance so we want to look at all that before you put your document these two aircraft if they look to be the same type of aircraft the top one is it's an experimental aircraft and you see that on the bottom of the tail it's not real visible but that has the three inch in numbers on it the bottom one is a special life sport aircraft and it has the large in numbers on the airplane and that has to be 12 inches or as large as practical if you could put if you couldn't put more than a 10 inch letter on there then that would be acceptable but in most cases you can get the 12 inch letters on the aft part of the fuselage aircraft also has to have to have an identification plate this plate must be fireproof it must be attached to a structural member behind the passenger door that's one of the things that we've run across on a lot of aircraft they put these on the framework up by the cockpit or something like this but the the order says that they will be behind the passenger door they have to be etch stamped engraved or marked by another approved fireproof marking something that is not going to come off of there if the aircraft aircraft crashes you can still identify the aircraft with the data plate one of the things that we've seen on some of the aircraft is they will it has to be attached to a structure member but there may not be a place a good place to attach it so they'll use adel clamps and attach these to the to the frame with adel clamps if you have two adel clamps to holding the data plate that's sufficient also so long as they won't come off in a crash or in a fire the information that's required on the data plate is the manufacturer or kit builder not the designer or plans producer that then that's the answer to your question that I was thinking was there the manufacturer is who built the kit not the manufacturer of the kit or the designer of the kit it has to has the model designation and the serial number and again all of these have to be either embossed in or stamped in or something in the data plate so that it is not made unrecognizable in a crash or a fire there are requirements for emergency locator transmitter on some light sport aircraft but only on the airplane and only if this aircraft is designed to operate with more than one person it's not required until after the test flight but after the test flight to place airplane requires an emergency locator transmitter imported aircraft imported aircraft have the same requirements as the American aircraft as far as the consensus standard the manufacturer will issue a statement of compliance for your aircraft by or kit by the serial number so they have to have the statement of compliance from the manufacturer before it can be registered and certificated in this country there are additional requirements on imported aircraft that these are that the aircraft or aircraft assembled from a can't must be eligible for an airworthiness certificate in the country of manufacturer meaning that if the country does not allow this aircraft to be registered and certificated in their own country we're not going to accept it in our country also the country must have an agreement with the FAA that covers the imported export of aircraft next we're going to get into the certification of repairman what we have here is a picture of a an air creation just coming out of the kit being assembled here the regulations covering the certification of repairman is 14 CFR 65-107 and the order covering this is 8,084 all of these references that I'm giving you to regulations and to orders are out on the internet you can find them from our website the repairman ratings there's an a repairman inspection rating it's to be eligible for an inspection rating an individual individual must attend and successfully complete a 16 hour FAA accepted course there's a maintenance rating the person must attend and successfully complete an 80 to 120 hour course depending on the class of life support aircraft there's different requirements for weight shift or for an airplane the inspection rating in the the airworthiness world most of the time you think of like an ANP mechanic and then an IA which an IA can sign off things that the the ANP can do in life sport the inspection rating is limited to one experimental aircraft that you own and we'll cover that in just a minute the course consists of six elements there's a number of organizations that are giving these courses around the nation and you can find these on our website also the first element of this inspection rating is covers the regulations and guidance material applicable to light sport aircraft review of operating limitations condition inspections the way to record entry and review of ADs and manufacture safety directives one of the things that since this is not a T-seat aircraft the question comes up why do you have to worry about airworthiness directives because airworthiness directives are designed for T-seat aircraft or PC aircraft but if you have a a light sport aircraft with a T-C PC engine on it even though it is a light sport aircraft you and you don't have to comply with airworthiness directives how are you going to sign this aircraft off as being safe on a T-seat engine if you haven't completed the ADs applicable to that engine so normally you wouldn't consider ADs on these aircraft but but if you have a T-C PC engine then you have to look at those before you can sign it off as airworthy manufacturers safety directives come out from like road tax or whoever the engine manufacturer is hearth or some of these that you have to comply with also and it also has to comply with all the consensus standards you can't do any modifications that do not have these the second element is the inspection procedures advisory circular 43 13 1 B gives acceptable methods techniques and practices and aircraft inspection and repair and the use of manufacturers manuals technical data and personal safety in the work environment so there's the first two elements of the inspection rating the third one aircraft theory of flight and discussion of aircraft systems theory of flight most everybody has gone through that when they started work getting an aircraft if they don't learn theory of flight they don't fly for very long these include the proper operation of critical areas that are prone to failure and fatigue these system includes the airframe including the instrumentation the landing gear the brakes including the fuel and all systems the propeller with the gear reduction unit accessories including the ballistic parachute and flight console control operation and ringing so this is the the third element of the inspection rating it's probably one of the larger elements that gets you doing the the actual condition inspection for the aircraft oops it's back up one element number four is use of an inspection checklist it's always good to have a checklist to to go through the process of doing your inspection and usually the manufacturer will provide you with a checklist to do this if not you have FAAAC90-89A which is the amateur built aircraft and ultra flight ultralight flight testing handbook in appendix A it has a checklist in there the fifth element is the student course evaluation and you may think this is an odd element for a training course but it is critical if you don't complete this you don't complete the course every student has to do the critique of the course not only in the the content of the course the equipment that they have to look at and the reason they do this is these evaluations are sent into AFS-610 back in Oklahoma City and we look at these at the evaluations to determine if the training facility is doing the job that they're supposed to be doing and if they're doing it in a efficient and manner that gets these people the training that they need the final element of the inspection course is the final test it has 50 questions multiple choice four questions in each subject area the minimum passing grade is 80 percent so it's a pretty rough test it's you know once you get through with this and you pass it then then you will be well qualified to to do the annual condition inspection on your aircraft if you don't complete the course you can't go back and just take a certain portion of the course you have to take the whole course all over again uh light sport repairman with an inspection waiting will allow the repairman to perform the annual condition inspection on the experimental aircraft owned by him or her so this is this is aircraft specific it gives the the class the registration number and the serial number that you can do the inspection on if you sell this aircraft you can no longer do the inspection on this aircraft whoever buys the aircraft can go through the course and get qualified to do the inspection on this aircraft or you can have an A and P do it the maintenance rating the courses go from from 80 to 120 hours depending on what course you have they have all the five different ratings for airplane airplane weight shift powered parachute glider and lighter than air so there's five elective courses that you can take and you don't have to take all of them you can take the core courses plus one of the electives gets you for a repairman for a specific class of aircraft it's designed in modules of instructions and customized for the specific type of aircraft the three core modules are include the airframe the well regular regulation the airframe and and engine we'll get that to a minute there like said a fall ago there's five classes eligible for maintenance rating that's the airplane weight shift powered parachute lighter than air and glider there is no maintenance rating for a gyroplane gyroplane is is strictly an experimental aircraft and the maintenance rating course is designed for the special light sport aircraft there's a limit on the number of students in a course to to get the clat the level standard level three standard training have a maximum of 16 students per instructor on the lecture part of the class and eight students per the practical projects and of course if you have if this course is given in a a 147 school that number can be raised excuse me as I said the maintenance rating it's got six modules to it there's a regulation and maintenance overview which is a 16 hour core module everyone who goes for a maintenance rating has to go through this module number two is the airframe it's 24 hours and it says it must cover at least two representative aircraft for the practical sessions so the provider of the course has to have two airframes there to to work on to get your maintenance rating in this class of aircraft module three engine and propeller which is 45 hours it's also a core module this must this covers at least must have at at least three representative engines has one water cool two cycle one air cool two cycle and one four cycle engine but now this module even though it is a core module under most circumstances it's not required for non-powered gliders module four is the airplane class it's 35 hours again the must cover at least two representative airframes not produced by the same manufacturer the same thing for module five the weight shift but it's a 19 hour course elective if you're going for weight shift control aircraft module six powered parachute 19 hours elective again has to have two representative aircraft not produced by the same manufacturer lighter than air this is a 64 hour elective module must have at least one representative aircraft module eight is the glider class it's 40 hours and it's also elective must have at least one representative aircraft now here if the applicant wishes to be rated gliders with a retractable or fixed engine module three must also be completed so if you're going for non-powered glider you do one, two, and eight if you're going to for a powered glider you have to do one, two, three, and eight that's where you get the really long training courses the holder of a repairman certificate with a maintenance rating approve and return to service a special life sport aircraft or any part thereof after performing and inspecting maintenance to include the annual condition inspection and 100 hour inspections also line maintenance preventative maintenance or alter or alterations excluding major repair or major alteration on a product produced under the FAA approval of an SLSA aircraft also the the maintenance rating individual may perform annual condition inspection on an experimental life sport aircraft that has been issued an experimental certificate under 21191 I that's whether it's on I1, I2, or I3 there is only one repairman certificate all of your ratings will be put on that one certificate the front it will have your information about yourself you know and your certificate number and all that on the back of the rating the top of it here it says inspection rating and if you look at if he has an inspection it'll down in the limitations it'll give you what that inspection rating is for in this particular instance it's for a weight shift control N number 337 EF serial number 18-337 so he can only do inspections on that one aircraft and he can only do inspections on that one aircraft as long as he owns it once he sells that aircraft then he can no longer do the inspection on that aircraft the new person either has to get their own inspection certificate or have an ANP do the inspection the second rating here is a maintenance rating he has a maintenance rating in powered parachutes he can do any powered parachute it's not limited to something that he he owns so it's the maintenance rating is is a much broader rating this is my contact information to to get in touch with myself for anyone in our branch I'm not going to read all this to you there's the main number that we call there's at the top is 4059546500 we're going to leave this up here for a few minutes because we're just about finished there's an email address there that you can email questions or the mailing address there my presentation is over I want to talk about the have three operations inspectors in the back of the class here Rich Michaels Jim Lam and and Robbie Whitesell they can help me with any questions in the operational side of the house if you have any questions at this time I want to to say if you have any more questions let's get them asked and we'll we'll see if we can get you some answers from it okay right here in the front what's an A&P need to do to do the maintenance and the inspection an A&P yeah A&P can do the maintenance and inspection on the aircraft now there are some limitations as to what an A&P can do road tracks road tax has come out and said that anyone who's going to sign off a road tax engine has to go to the road tax school so you can't do a sign off on a road tax engine return to service unless you've been to that school also in the SLSA aircraft they have a the the manufacturer designates in his manual what can be done and who can do it if he says that an an SLSA repairman can do this work like changing a tire and he didn't include an A&P or something like that then an A&P can't do that work that's correct and you know when we talked about the they got back with the manufacturers and and said well why did you limit this just to the repairman they said well we meant repairman or hire well there is no hire in the airworthiness side of the house the certificate for an airworthiness is not like an operational certificate when you have an operational certificate you could have rec pilot private pilot commercial pilot an ATP and an ATP can do anything a private can he can do anything a rec pilot can but in the airworthiness side of the house you have to have an A&P you have a separate repairman certificate you have a separate IA so it's not on the same certificate so if the manufacturer in his manual does not state that an A&P can do this he can't do it and some of the manufacturers are all are looking at this probably going to be changing their manuals that probably needs to come out in an AC or some other order so A&Ps really know what they can do what they can't do and because there's a lot I know there's a lot of confusion out there I'm an A&P and the guys I talk to a lot of them don't even want to do it because they don't want to you know well see it's really up to the manufacturer who they want to do this work to give you an example there there are operations inspectors fly and in the the maintenance manual for that aircraft it says that a repairman can change the tire now if they have a flat on that aircraft these guys can't change it as the pilot I can't go out there as an A&P and change it we have to get a repairman or a representative from the manufacturer to come into Oklahoma City and change that tire and it was just a misunderstanding of the of the way that the certificates work on the part of the manufacturer because if you know if they thought it would meant a repairman or higher then an A&P could do it but like I said there's there's no hierarchy of ratings in the airworthiness side of the house so they have to state A&P or maintenance yeah whoever maintenance qualified for it okay got a question back Rich is up here the one thing that we that we've talked about is whenever an A&P is doing work on a light support aircraft that they call the manufacturer if they can't find that information because all they would need is just a usually in most cases the manufacturer is willing to have the A&P do the work they would just end up getting a faxed letter of authors they should say yes the A&P can work on it and then they that would go ahead that's the way we tell the A&P's now right now is to contact the manufacturer on whatever aircraft they're going to be working on to get approval and there would have to be no previous training or anything like that if the manufacturer says that there was no previous training then that would be that would be correct it's all it's all up to the manufacturer of that aircraft and that would apply for a condition inspection also if the manufacturer says the condition inspection yes yep how about in general with a condition inspection what do you mean in general for an A&P to do a condition as the manufacturer says so as long as it's either in the book or you get yes okay when we get that Michael we couldn't hear the last part of those questions would you repeat that last question that you asked Rick I yeah for the condition inspection what the A&P need to do for a condition inspection and the same thing get okay from the manufacturer right okay are there any other questions okay Robby let's get your microphone back there just a comment Tom just wanted to make sure that the they understand the phone number for our branch it's the 6400 I think you said 6500 no one to make sure that they knew that it was yeah okay 6400 right thank you Tom I want to thank you very much for sharing this information it went beautifully and the people that were fortunate to be here have learned a great deal thank you very much we're going to switch over to Cheryl in Studio B and proceed on with a very special day at Sun and Fun thank you all for coming and thank you Tom thank you appreciate the opportunity thank you anybody who's interested in answering or talking to Tom personally come on up we'd like to stay here and see you and greet you so come on we'll talk to you okay