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FAA response to mandatory maintenance intervals


sword_guy

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Hopefully, the chief counsel's new letter will address other requirements as well. To me these would include any inspection that is outside of the required Condition inspection interval or scope and detail, component replacements and training or other personnel requirements that the manufacturer may attempt to impose.

All of these have been previously vetted out, but a "one-stop shopping" opinion would be handy.

 

As long as the FAA has their pencils sharpened up, it would be nice if they would publish some guidance for the field, and for MFG's regarding Safety Directives (construct and purpose), and Condition inspection procedures (scope and detail).

 

Roger, maybe you could use some of your influence here?

 

Doug Hereford

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Trying to figure out when buying a used CTLS if I'm required to OH at 12 years or 2,000 hours.   I believe the 12 years will will happen before the 2,000 hours.  If I buy a 2008 model will I be required to OH in 2020 by either Rotax or the FAA?  If I don't, what are the possible repercussions to me?   I've read all these posts and need a little guidance   Did the FAA ever send a letter out?

 

TIA

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Thanks Roger.   I’ll have a pre purchase done by my guy when the time comes.  Prior to that the main items I’m looking for are:

Chute repack

Rubber replacement

2020 Compliant

NDH

Of course those can be priced into the sales price one way or the other.  

Any others?

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  • 4 months later...

Roger,

Our flying club is operating a CTLS and we are at the manufacturer's recommended TBO.

Did you ever receive a clarification letter from the FAA to validate that engines in LIGHT SPORT aircraft can legally be operated beyond the manufacturer's TBO?

Thanks.

John K

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There is a new legal interpretation about mandatory SB's. The original said they weren't mandatory. There is a new one coming out and it's already in the system coming this way. That is going to change. The TBO legal was submitted about 4 months ago, but may not be out for 1-2 years. There was two legal interpretations on TBO. The first one said it was mandatory, the second said no it wasn't which is the current one and maybe this new one will say they are again. This is because the FAA handles and rules TC'd aircraft and we are not so the rules may not apply. The other issue is the rules as written do not spell out a continuing maint. program for aircraft under ASTM rules. This may also mean that each LSA aircraft company may have to put out an acceptable on condition maint. schedule since it isn't controlled by the FAA. As it sits right now no one is making anyone do LSA TBO's.

 

Where will the shoe eventually drop?  Who Knows. Above my pay grade.

 

p.s.

If the FAA does rule in a year or two that TBO's are mandatory everyone agrees including the aircraft Mfgs. that there will be a mass exodus from SLSA to ELSA in the US.

 

p.s.s.

For you guys that are already down to ELSA it says in your new limitations that was given to by the FAA when you did that that you MUST comply with ALL time limited parts directed from the MFG. This means the Rotax 5 year is mandatory and the parachute, ect... Whatever has a time limit you must comply with, but at least you can do your own maint. and an annual condition if you have the 16 hr. class. I am presenting seeking becoming an instructor for that 16 hr. class. 

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A new rule set that is more restrictive and limits "on condition" maintenance could drive many more owners into the loving arms of ELSA.  I hope that is not the case; I like that there are two very good options for LSA owners, and would hate to see people feel forced into ELSA status when it's not really what they want.

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Are they saying "the manufacturer" in regards to the airframe manufacturer? Or is it including the parts that make up the airframe?

It would take an insane amount of research each inspection to check every component for compliance.

Roger, I am going to write a letter about this. I need to know if it's Ok City you've been talking to. I need to find out who to send this to voicing my concern that forcing service bulletin compliance without any definitive proof or evidence of that bulletin's necessity is going to create unreasonable burden. If it is necessary, then a safety alert should be issued to require corrective action.

As for the conditional maintenance stuff: 100% agree here. I really, really dislike LSA rules regarding maintenance. If a manufacturer disappears tomorrow and nobody has purchased the type rights, then there is no one to maintain airworthiness.

Vintage aircraft, on the other hand, are allowed to be maintained using industry standard practices even if there is no manufacturer to support them anymore.

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Directly to Oklahoma. Many I found out are not keeping up there and only 2-3 have kept up. They disbanded the LSA section and spread them out in other assignments.  I talked to one guy and he knew less than a newbie. Even the few in the know will not tell you specifics and no use on the TBO because it's in legal and may not come out for 1-2 years. 

There will be absolutely no reason to carry forward on any debate or even get upset because there are no rulings out as yet and anything further said is just speculation until legal makes the final decision AGAIN.

 

Here is one answer from another person.

"You can not apply standard certified aircraft rational to LSA aircraft because of the text found in part 91.  Clearly the manufacture of record is the only one who can exempt or change the Rotax mandatory requirement.  In part 91 the authority is clearly with the OEM (whomever signs the 8130-15 form) If, as most LSA OEM do, they say follow the Rotax manuals then that is exactly what they must do in regards to the relevant SB and other published data.  The OEM is required to send out a Safety Directive on any safety of flight issue and direct the owner to follow the relevant SB.  This is exactly the same process that the FAA uses with an AD, in that case the FAA takes on this responsibility on any TC product, they issue the AD of any safety of flight issue and direct the owner to comply with the SB.  There are many such cases of this and the OEM of LSA must follow up on all SB and determine the safety risk.  This is part of their requirements under the rule and ASTM standards."

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