Ask the DAR

Heeding manufacturer overhaul times, about the repairman certificate.


Question: I have been reading a lot here and online about the Van’s RV-12 as both an Experimental/Amateur-Built and as an Experimental Light Sport Aircraft (ELSA). What I don’t know is this: In the E/A-B world, we can choose to not follow recommended overhaul and replacement times, such as for the engine. If the TBO is 2000 hours, we don’t necessarily have to overhaul at that time. (I know this is also true for certified aircraft operated under FAR Part 91.)

What, then, are the maintenance rules for an RV-12 certified as an ELSA? Let’s assume that I assemble the kit exactly as Van’s has it laid out. I know that I can modify after I get the ELSA certificate, but do I have to follow all the maintenance for the RV exactly as stated by Vans and Rotax? Or can I, as the holder of a repairman certificate, decide?

Answer: The ELSA RV-12 in this case is in the Experimental category, like all ELSAs. Because of that, you are not bound by manufacturers’ recommendations, stated as mandatory or not. You as the owner may decide. Although it’s worth reiterating that if there’s an Airworthiness Directive on a part you have on your airplane, it’s prudent to at least investigate the reasons for the AD.

Also, to be clear, you can do all maintenance and/or modifications as the owner of either the E/A-B or ELSA version. The repairman certificate only pertains to the annual condition inspection, which, of course, can be farmed out to an A&P mechanic as well.

Question: As the builder of an ELSA, can I get the repairman certificate when I certify the airplane just like an E/A-B? Or do I have to take the 16-hour course?

Answer: If you certificate the aircraft as E/A-B, you may obtain the repairman certificate simply by applying. This will be good for this aircraft only. If you certificate the aircraft as ELSA, you must complete the 16 hr. course and apply for the certificate. This will be good for this airplane. Any future ELSA aircraft of the same category that you own may be added to the certificate without retaking the course.

Question: I have a Van’s RV-8 currently flying with a fixed-pitch propeller. That’s how it was built and flown through Phase I testing. I want to change the prop to a constant-speed unit. Aside from the obvious hardware involved, my question is this: After the change, do I need to go back into Phase I flight test? If so, for how long?

Answer: There should be a paragraph in your operating limitations that starts out: “After incorporating a major change…” This paragraph states that after making a major change, you must place the aircraft back into Phase I for a minimum of 5 hours. It goes on to state that if you are changing a fixed-pitch to or from a controllable-pitch propeller, you must submit a revised FAA form 8130-6 to update the information in the FAA Aircraft Registration Branch, AFS-750. This should be done through your local FSDO.

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Mel Asberry
Mel Asberry is an experienced Designated Airworthiness Representative specializing in Experimental/Amateur-Built aircraft. He and his wife, Ann, have built seven amateur-built airplanes including two ultralight types, a Moni Motorglider, a Dragonfly Mk2, two RV-6s and a Zenair CH 601HDS. They are currently building a scratch-built biplane.


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