The adoption of the Sport Pilot/Light Sport Aircraft Rule in 2004, and the FAA interpretation requiring, in some cases, “Manufacturer’s Factory Approved Training” to provide service and line maintenance to Special Light-Sport Aircraft (SLSA), caused some confusion among aviation maintenance professionals. The Rotax Factory Training Courses were at the center of this controversy. Therefore, Carol Carpenter wrote a letter to the Office of Chief Counsel for a determination.

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.”

Carpenter – (2012) Legal Interpretation (PDF)