On Tue, 02 Aug 2005 05:21:29 GMT, (sleepy6) wrote:

In article ,
says...

Experimental LSAs, like Experimental Amateur-Built aircraft, are gover
ned by the
operating limitations issued at the time the plane is certified. The
ELSA
operating limitations specified in 8130-2F Change 1 certainly imply th
at major
changes may be performed ("All major changes or modifications will be
listed in
the aircraft records...") but make no stipulation on the minimum requi
rements
necessary to perform such a modification.

It's not in the operating limitations, it's in the repairman
certification.

When you get the repairmans certificate for your amature built
experimental it gives you certain privleges.

The LSA repairmen certificates give them a different set of privleges.
For instance, you can attend a 16 hour school to get a LSA repairman
certificate with an inspection rating. That allows you to perform the
annual condition inspection but does not allow you to perform any work.

But neither does the Repairman Certificate for an Amateur-Built aircraft...see
65.104 (b):

"(b) The holder of a repairman certificate (experimental aircraft builder) may
perform condition inspections on the aircraft constructed by the holder in
accordance with the operating limitations of that aircraft. "

That's all that the Amateur-built aircraft Repairman Certificate covers. It
does not authorize the holder of the Repairman Certificate to maintain the
aircraft, nor does it authorize him or her to modify it.

There *are* no regulations specifying who may maintain or modify an Experimental
Amateur-Built aircraft. Hence, anyone can. I maintain my Fly Baby, despite
holding neither an A&P license or Repairman Certificate.

The same regulatory void exists for Experimental Light Sport Aircraft. Yes, FAR
65.107 specifies that the older of an LS-I or LS-M Repairman Certificate *may*
perform the annual inspection. But FAR 65 does not apply to aircraft; its topic
is certification for airman other than flight crew members. And read 14CFR Part
1.3 to see what 'may' means.

Look at the "Light-Sport Aircraft Maintenance and Certification Requirements"
table in the FAA's initial Sport Pilot release (page 27 of the Word document) it
clearly states that ELSAs are owner-maintained. Not regulatory, of course, but
it clearly indicates the FAA's intent, and there are no regulations that
contradict it.

You can attend a 120 hour school to get an LSA repairman certificate
with a maintaince rating. That allows you to do certain work but
states "(excluding a major repair or a major alteration..."

Pardon me, but you didn't finish the quote: "(excluding a major repair or major
alteration ON A PRODUCT PRODUCED UNDER FAA APPROVAL)" (emphasis added). In other
words, if the LSA mounts a certified O-235, a person with an LS-M cannot perform
major repair or alteration on it. But the airframe of an LSA, and the engine
(if it was certified as conforming to the consensus standard) are NOT produced
under FAA approval. Hence the exception does not apply.

It may be possible for an A&P to make modifications to ELSA but the LSA
repairmen can't do it themselves.

Sorry, but as indicated above, I see no such prohibition in the regulations.

Ron Wanttaja