Pros and cons changing to E-LSA

[Tom Baker]

Preventative maintenance may be performed by a sport pilot only on an S-LSA in which he/she owns or operates. (Experimental can be done by anyone). This is in contrast to standard aircraft, which require at least a private certificate.

 

Additionally, S-LSAs do not have required annuals, they have condition inspections, but annuals can be used instead if so desired. These inspections require an A&P, or an LSA repairman with an inspection rating. Maintenance may only be performed by an LSA repairman with a maintenance rating. All LSA repairman ratings are aircraft class specific.

 

Your answer is not complete, and part of it is wrong. Maintenance on a SLSA can be performed by anyone under supervision of an A&P, and the A&P can do maintenance on any SLSA provided the A&P has had training or performed the task before.

[Roger Lee]

Hi Tom,

I agree, but here are the two scary parts.

 

"performed by anyone under supervision of an A&P, and the A&P can do maintenance on any SLSA provided the A&P has had training or performed the task before."

 

Too many A&P's don't know what they are doing on an SLSA or a Rotax, but they get to supervise someone that may know even less.

Too many don't have training or performed a task on a Rotax which may be totally different than a Cont. or Lycoming.

 

You and I get to see this on a regular basis.

[Tom Baker]

Hi Tom,

I agree, but here are the two scary parts.

 

"performed by anyone under supervision of an A&P, and the A&P can do maintenance on any SLSA provided the A&P has had training or performed the task before."

 

Too many A&P's don't know what they are doing on an SLSA or a Rotax, but they get to supervise someone that may know even less.

Too many don't have training or performed a task on a Rotax which may be totally different than a Cont. or Lycoming.

 

You and I get to see this on a regular basis.

 

Roger, I didn't say it was a good idea, just that it could be done.

[Roger Lee]

I know. The FAA said the same thing. (I didn't say it was a good idea)

I think you and I are on the same page with this stuff. We get to see the results on a regular basis.

[Anticept]

Your answer is not complete, and part of it is wrong. Maintenance on a SLSA can be performed by anyone under supervision of an A&P, and the A&P can do maintenance on any SLSA provided the A&P has had training or performed the task before.

 

If you want to be picky, your response is incomplete too . Only certain tasks spelled out in part 43 can be completed under supervision. MAJOR alternations and MAJOR repairs can ONLY be performed by rated personnel, as well as inspections only being allowed to be completed by rated personnel (by a literal reading of regs).

 

EDIT: My previous response didn't take my edit last night. I tried to add in a line stating there are some nit-picky stuff, but I would end up rewriting the rules trying to type them all

[Tom Baker]

If you want to be picky, your response is incomplete too . Only certain tasks spelled out in part 43 can be completed under supervision. MAJOR alternations and MAJOR repairs can ONLY be performed by rated personnel, as well as inspections only being allowed to be completed by rated personnel (by a literal reading of regs).

 

EDIT: My previous response didn't take my edit last night. I tried to add in a line stating there are some nit-picky stuff, but I would end up rewriting the rules trying to type them all

 

You said maintenance. Major repairs and major alterations are not considered maintenance, they are listed as separate items in the regulations.

[Anticept]

You said maintenance. Major repairs and major alterations are not considered maintenance, they are listed as separate items in the regulations.

 

Touché! I would like to make a point though, that it should have still been mentioned, because common language considers major work as maintenance, even if the regs don't!

 

Let's not even get into manufacturer maintenance etc. That's a whole other ball of yarn. As said, if we wanted to get really crazy with the nitpicking, we could just copy 43 to this thread

[FastEddieB]

 

The MFG may put that in the book, but the MFG can not make additional policies or rules above what the FAA has in place. So the SLSA owner/pilot may do any preventive maint. that is listed under the FARs and in this particular case same as a GA pilot

 

This is not the first time this has been discussed, but there are new members here, I'm sure.

 

My specific case was needing to replace the battery in my S-LSA Sky Arrow. Part 43 lists this as Preventive Maintenance, and allowed.

 

My AMM says, under battery removal/replacement, something like "Certification required - LSRM or A&P".

 

This brings up a couple thoughts:

 

1) Suppose there was something really tricky and exact about the battery installation on a Sky Arrow? Something requiring special tools and procedures? There's not, but how would one know?

 

2) Suppose I forgot to tighten the single dzus fastener holding the battery in place, it came loose, shorted, started a fire and a crash. What would my having disregarded the AMM's requirements look like in civil court if a passenger sued? I could make the case that it was legal for me to swap batteries, but I wonder what a jury of peers might think.

 

As an aside, a reputable shop put in a non-specified battery without any LOA that I know of. In addition, the one time I had a problem, it was from a loose battery terminal causing hard starting - AFTER maintenance by approved mechanics of an unapproved battery:

 

 

You can see the arcing the loose terminal caused.

[Tom Baker]

Touché! I would like to make a point though, that it should have still been mentioned, because common language considers major work as maintenance, even if the regs don't!

 

Let's not even get into manufacturer maintenance etc. That's a whole other ball of yarn. As said, if we wanted to get really crazy with the nitpicking, we could just copy 43 to this thread

 

Major work could be maintenance, but it could be something else. Replacing the timing belt on a car at 90,000 miles is major work, but it would still be maintenance. If the timing belt breaks then it is major work and a repair. Now if you remove the timing belt and install gears instead, that would be major work and an alteration.

 

BTW, there is still more to the answer as to who can do the annual on a light sport aircraft.

[Anticept]

Tom Baker: Any Light sport repairman with an inspection rating (edit: on an aircraft that they own), any A&P (IA not required), or an Authorized Repair Station. Also, forgot to previously mention, Repairmen certified in a repair station, depending on their ratings, can also perform maintenance and major work.

 

FastEddieB: It doesn't matter if you are trained or not. If you weren't trained, they would sue you for negligence. If you were trained, they would say you should have known better! The only opt

[Tom Baker]

Tom Baker: Any Light sport repairman with an inspection rating, any A&P (IA not required), or an Authorized Repair Station.

 

FastEddieB: It doesn't matter if you are trained or not. If you weren't trained, they would sue you for negligence. If you were trained, they would say you should have known better!

 

Do you want to try again, or do you want the correct answer?

[Anticept]

Any light sport repairman with an inspection rating on an aircraft that they own*

 

EDIT: Apparently they won't even allow one that you operate. That leaves open a hell of a gray area for those who LEASE S-LSAs, or when a company owns an S-LSA and the repairman owns the shares of the company. That's why I am getting my A&P. I get to avoid all that crap!

 

EDIT 2: Just because we're nitpicking, §65.107 is the reference for anyone who is curious about it.

[Tom Baker]

Rather than drag this out I'll give you the answer. Only an IA can perform an annual inspection on a light sport aircraft. I'll let you think about that a bit before I explain.

[Anticept]

Rather than drag this out I'll give you the answer. Only an IA can perform an annual inspection on a light sport aircraft. I'll let you think about that a bit before I explain.

 

Yes, I know only an IA/rated repair station can write it as an "annual inspection", whereas everyone else has to call it an "Annual condition inspection". Again, comes down to nitpicking the language used while having our discussion .

 

To be fair, you didn't specify which type of annual you meant!

[Tom Baker]

I'll try and do this as short as I can. 91.409 covers inspections. It says to operate an aircraft it must have an inspection within the last 12 calendar months. The inspection must be in accordance with part 43, and signed off by someone who is authorized by 43.7, or the issuance of an airworthiness certificate is OK too. This inspection must be entered as a "annual" inspection in the aircraft records. It also goes on to cover 100 hour inspections. The annual inspection requirements do not apply to an aircraft that carries a special flight permit, a current experimental certificate, or a light-sport or provisional airworthiness certificate. Those aircraft require a condition inspection which needs to be signed off annually, and should not be signed off as annual inspections.

 

CFR 1.1 gives the definition of a light sport aircraft. All aircraft which meet these requirements are light sport aircraft just like all aircraft that more than one engine are multi engine aircraft. The fact that a Piper J3 Cub, Taylorcraft, or other aircraft were built before the definition was created does not mean that it doesn't apply to them. They are in fact light sport aircraft because they fit the definition.

 

The inspection required for a light sport aircraft is defined by the type of airwortiness certificate that it holds. A light sport aircraft that was built under a type certificate and that holds a standard airworthiness certificate must have an annual inspection, and it can only be done by an IA.

 

Other types of airworthiness certificates that can be issued to light sport aircraft are special issue in the light sport category, experimental in the light sport category, experimental amateur built, experimental exhibition category, and there may be others.

[Anticept]

I'll try and do this as short as I can. 91.409 covers inspections. It says to operate an aircraft it must have an inspection within the last 12 calendar months. The inspection must be in accordance with part 43, and signed off by someone who is authorized by 43.7, or the issuance of an airworthiness certificate is OK too. This inspection must be entered as a "annual" inspection in the aircraft records. It also goes on to cover 100 hour inspections. These requirements do not apply to an aircraft that carries a special flight permit, a current experimental certificate, or a light-sport or provisional airworthiness certificate. Those aircraft require a condition inspection which needs to be signed off annually, and should not be signed off as annual inspections.

 

In the most literal reading, yes, this is true. It eludes me at the moment, but I remember seeing an FAA document which states they accept an annual inspection in-lieu of a condition inspection, as they achieve the same thing. Just like an annual can be used in lieu of a 100 hour inspection, but that one is stated right in the FARs

 

Also, I just wanted to verify, you know 100 hour inspections are still required for LSA aircraft when using them for flight instruction, right?

 

CFR 1.1 gives the definition of a light sport aircraft. All aircraft which meet these requirements are light sport aircraft just like all aircraft that more than one engine are multi engine aircraft. The fact that a Piper J3 Cub, Taylorcraft, or other aircraft were built before the definition was created does not mean that it doesn't apply to them. They are in fact light sport aircraft because they fit the definition.

 

The inspection required for a light sport aircraft is defined by the type of airwortiness certificate that it holds. A light sport aircraft that was built under a type certificate and that holds a standard airworthiness certificate must have an annual inspection, and it can only be done by an IA.

 

Other types of airworthiness certificates that can be issued to light sport aircraft are special issue in the light sport category, experimental in the light sport category, experimental amateur built, experimental exhibition category, and there may be others.

 

I was very particular about calling an aircraft S-LSA when explaining. I am aware of the particulars related to certification. While Taylorcraft, Piper J3's, and even the Wright Flier(!) may be flown under the definition of light sport aircraft, the definition is is in place so that certificated sport pilots may fly aircraft which fit the definition, and as a guideline for DARs to write the airworthiness certificate. As you stated, it is the airworthiness certificate that dictates the inspections required, since the regs refer to the issued airworthiness certificate when setting the operating limitations related to inspection.

[Tom Baker]

In the most literal reading, yes, this is true. It eludes me at the moment, but I remember seeing an FAA document which states they accept an annual inspection in-lieu of a condition inspection, as they achieve the same thing. Just like an annual can be used in lieu of a 100 hour inspection, but that one is stated right in the FARs

 

Also, I just wanted to verify, you know 100 hour inspections are still required for LSA aircraft when using them for flight instruction, right?

 

 

 

I was very particular about calling an aircraft S-LSA when explaining. I am aware of the particulars related to certification. While Taylorcraft, Piper J3's, and even the Wright Flier(!) may be flown under the definition of light sport aircraft, the definition is is in place so that certificated sport pilots may fly aircraft which fit the definition, and as a guideline for DARs to write the airworthiness certificate. As you stated, it is the airworthiness certificate that dictates the inspections required, since the regs refer to the issued airworthiness certificate when setting the operating limitations related to inspection.

 

Yes, I know that 100 hour inspections are still required if the aircraft is used for commercial purposes. I went back and edited my post to reflect that. While the FAA may except a sign off with annual inspection that is still not correct. The operating limitations that go with a special issue airworthiness certificate provide the wording that should be used for the sign off. The words don't have to match exactly, but they should be similar.

 

I also was very particular when I said light sport aircraft and annual inspection. Your statement, "may be flown under the definition of light sport aircraft", and others like "meets the requirements of a light sport aircraft" are creating confusion. Not so much for the pilots because they know what they can fly, but for the mechanics. I had a mechanic tell me that a Taylorcraft that once had a controlable pitch propeller installed could be flown by a sport pilot because it was not a light sport aircraft, and the CFR 1.1 definition didn't apply to the airplane. The way the regulations are written the FAA considers anything that meets the requirements of the CFR 1.1 definition to be a light sport aircraft. Part 61 allows sport pilot to fly light sport aircraft. There is no mention of aircraft that meet the requirements. Part 43 says that a sport pilot can perform preventive maintenance on a aircraft that is owned or operated by tha pilot, and issued a special airworthiness certificate in the light-sport category. They didn't just say light sport aircraft. Part 21 even talks about issuing a special airworthiness certificate in the light-sport category to operate a light-sport aircraft. The light sport category was created to issue airwortiness certificates to light sport aircraft that had never had a different type of airworthiness certificate issued either here or in another country. For a pilot any thing that meets the CFR 1.1 definition is a light sport aircraft. For maintenance the light sport aircraft are divided even further to include how the airwortiness certtificates were issued.

[Anticept]

I'm right there with you. I wish they would have separated the term "light sport" aircraft from "sport pilot". Ultralight would have been a great term, if we didn't already use it for what should have been called microlights.

 

As for the wording: I also agree, do it right. But, if someone writes it off as an annual, and it isn't caught before an ASI does, at least you know it's technically OK (assuming I can find that document with an FAA signature).

[FastEddieB]

I also was very particular when I said light sport aircraft and annual inspection. Your statement, "may be flown under the definition of light sport aircraft", and others like "meets the requirements of a light sport aircraft" are creating confusion.

 

Prof Shuch gives an interesting seminar called "Stepping up to Light Sport". I sat in on it at the Cub Fly-In in Lock Haven.

 

To avoid the confusion, I think the term he used was "Light Sport Compliant". IOW, neither a Cub nor a Champ nor an Ercoupe are Light Sports in any sense of the word - they are just regular certified planes that happen to meet criteria where they can be flown by Light Sport pilots.

 

But, again, can everyone see that discussions such as these would be a real turn-off to a potential pilot? Its all far too complicated - people have a romantic vision of the freedom of flight. All this crap really tarnishes that image, IMHO of course.

[Tom Baker]

Prof Shuch gives an interesting seminar called "Stepping up to Light Sport". I sat in on it at the Cub Fly-In in Lock Haven.

 

To avoid the confusion, I think the term he used was "Light Sport Compliant". IOW, neither a Cub nor a Champ nor an Ercoupe are Light Sports in any sense of the word - they are just regular certified planes that happen to meet criteria where they can be flown by Light Sport pilots.

 

But, again, can everyone see that discussions such as these would be a real turn-off to a potential pilot? Its all far too complicated - people have a romantic vision of the freedom of flight. All this crap really tarnishes that image, IMHO of course.

 

Those are the terms put out there by EAA and AOPA, but it is not supported by the way the regulations are written. Just because people keep saying it that way doesn't make it right. Like I said before pilots know what they can fly it is the maintenance side that has a bigger problem.

[Tom Baker]

I'm right there with you. I wish they would have separated the term "light sport" aircraft from "sport pilot". Ultralight would have been a great term, if we didn't already use it for what should have been called microlights.

 

As for the wording: I also agree, do it right. But, if someone writes it off as an annual, and it isn't caught before an ASI does, at least you know it's technically OK (assuming I can find that document with an FAA signature).

 

The operating limitations that go with the airworthiness certificate say the sign off must contain these or similar words ,and then go on to provide the wording.

[Anticept]

 

 

The operating limitations that go with the airworthiness certificate say the sign off must contain these or similar words ,and then go on to provide the wording.

 

Thanks for the discussion by the way!

[Tom Baker]

Thanks for the discussion by the way!

 

Your welcome. I am going to talk to my FSDO to see if I might be able to do a presentation at our IA renewal clinic next year.

[Dan Kent]

"Visual contact with the surface" means you cannot fly above ceilings (scattered, broken, or greater, according to FAA interpretation). This is a carry over term from the days of "VFR on-top".

 

Been away from the forum for a while and started reading to catch up on what I missed. Is Scattered considered a ceiling by the FAA? I was taught that broken and overcast were ceilings, but scattered, few and clear (obviously) were not.

[FastEddieB]

You can find the definition of ceiling in FAR Part 1.

 

But, no, a scattered layer is not a ceiling.

 

You can clearly fly on top of a scattered, or even a broken, cloud layer and still have reference to the surface.