[Denny of Oakland]

I assume the FAA sent you a letter saying 90-days to retest. I am sorry I don’t have an answer why you have to wait 90-days. I would suggest you contact the FAA Inspectors’s and asked them directly.

As you may know pilots, and mechanics hold rating and yes it is a privilege and they are required to take tests that are published except for the Inspection Authorization. An applicant for a repairman certificate will normally be employed by a certificated repair station, manufacturer's maintenance facility, or a certificate holder operating under the provisions of FAR Parts 121, 127, or 135, and are not required to take a written, oral, or practical test as pilots and mechaincs do.

You received your repairman certifiate based on a letter of recommendation from your repair station employer clearly stating that you the applicant meets the requirements of 14 CFR part 65, § 65.101. The letter should of describe the specialized jobs you the applicant will perform or supervise as a repairman. This letter indicated you were specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which you were employed. You were required to complete formal training that was acceptable to the Administrator (FAA), and was specifically designed to qualify you for the job in which you were to be employed. This is not the case for pilots and mechanics we are required to have a broader knowledge and required to take special required training then pass the written, oral, and practical tests. Repairmen are not required to take these type of tests to be certificated.

You will be tested on your special skills and knowledge of FARs per your employment recommendations by the repair station. Knowing the FARs is what your test is going to be on and I would assume the repair station manual RSM and QCM would be included.

Please remember Title 49 of the UnitedStates Code (49 U.S.C.) § 44709 (formerly 609 of the FA Act of 1958) authorizes the Administrator to reexamine any airman at any time. The reconsideration of an airman's competence is a serious issue and requires that there be ample cause.

Reference material:
FAR 65 Section 65.101 Eigible for a repairman certificate
AC 65-24 Certification of a Repairman (General)
FAA Order 8300.10 Vol. 2 Chapter 24 Certifiate Repairman
FAA Order 8300.10 Vol. 3 Chapter 18 Conduct a Reexamination Test

FAR 65 § 65.103 Repairman certificate: Privileges and limitations.

(a) A certificated repairman may perform or supervise the maintenance, preventive maintenance, or alteration of aircraft or aircraft components appropriate to the job for which the repairman was employed and certificated, but only in connection with duties for the certificate holder by whom the repairman was employed and recommended.

(b) A certificated repairman may not perform or supervise duties under the repairman certificate unless the repairman understands the current instructions of the certificate holder by whom the repairman is employed and the manufacturer's instructions for continued airworthiness relating to the specific operations concerned.

(c) This section does not apply to the holder of a repairman certificate (light-sport aircraft) while that repairman is performing work under that certificate.

[Doc. No. 18241, 45 FR 46738, July 10, 1980, as amended by Amdt. 65-45, 69 FR 44879, July 27, 2004]

Just one A&P/IA opinion.