New LSA rules

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

In article ,
says...

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

In article ,
says...

Experimental LSAs, like Experimental Amateur-Built aircraft, are gov
er
ned by the
operating limitations issued at the time the plane is certified. Th
e
ELSA
operating limitations specified in 8130-2F Change 1 certainly imply
th
at major
changes may be performed ("All major changes or modifications will b
e
listed in
the aircraft records...") but make no stipulation on the minimum req
ui
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 th
e
annual condition inspection but does not allow you to perform any wor
k.

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

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

That's all that the Amateur-built aircraft Repairman Certificate cover
s. 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 Ex
perimental
Amateur-Built aircraft. Hence, anyone can. I maintain my Fly Baby, d
espite
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 Certifica
te *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 Requir
ements"
table in the FAA's initial Sport Pilot release (page 27 of the Word do
cument) it
clearly states that ELSAs are owner-maintained. Not regulatory, of co
urse, but
it clearly indicates the FAA's intent, and there are no regulations th
at
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 repai
r 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 cann
ot 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 L
SA
repairmen can't do it themselves.

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

Ron Wanttaja


I see it a little different Ron. Instead of an FAA written approval
process, the FAA approved and accepted the procedures in the consensous
standards for LSA. The FAA had to publish that official approval in
the federal register. They have also stated that if other consensous
standards from other sources were written, the FAA could approve or not
approve those standards for the design and construction of LSA as well.
Without that FAA approval, the consensous standards (and standards
approved by other countries) mean nothing.

In other words, I think the planes produced under the consensous
standards are "produced under FAA approval" the same as type certified
planes are produced under FAA approval.

Not just the airframe either. There is a consensous standard for the
design and testing of engines for LSA planes. That also was approved
by the FAA.

On Tue, 02 Aug 2005 18:53:26 GMT, (sleepy6) wrote:


I see it a little different Ron. Instead of an FAA written approval
process, the FAA approved and accepted the procedures in the consensous
standards for LSA. The FAA had to publish that official approval in
the federal register. They have also stated that if other consensous
standards from other sources were written, the FAA could approve or not
approve those standards for the design and construction of LSA as well.
Without that FAA approval, the consensous standards (and standards
approved by other countries) mean nothing.

In other words, I think the planes produced under the consensous
standards are "produced under FAA approval" the same as type certified
planes are produced under FAA approval.

Sorry, can't agree. In the initial publication of the LSA/Sport Pilot Rules and
the logic behind them, the FAA has this key statement:

"The use of Form 337 is not required because special light-sport aircraft will
be built to a consensus standard "accepted" by the FAA, but not "approved" by
the FAA." (page 136 of the Word document).

This is echoed by FAA Order 3120-2F Change one, Paragraph 121 d:

"d. Light-Sport Aircraft Construction. The manufacturer of an aircraft for
airworthiness certification in the light-sport category must manufacture the
aircraft to the design requirements and quality system of the applicable
consensus standard that has been accepted by the FAA and published through a
notice of availability in the Federal Register."

"Accept" is not the same as "Approve." Imagine your best friend saying to you,
"I'm gay." Responding, "I accept" is a HECK of a lot different than saying "I
approve." :-)

Ron Wanttaja

In article ,
says...

On Tue, 02 Aug 2005 18:53:26 GMT, (sleepy6) wrote:


I see it a little different Ron. Instead of an FAA written approval
process, the FAA approved and accepted the procedures in the consenso
us
standards for LSA. The FAA had to publish that official approval in
the federal register. They have also stated that if other consensous

standards from other sources were written, the FAA could approve or n
ot
approve those standards for the design and construction of LSA as wel
l.
Without that FAA approval, the consensous standards (and standards
approved by other countries) mean nothing.

In other words, I think the planes produced under the consensous
standards are "produced under FAA approval" the same as type certifie
d
planes are produced under FAA approval.

Sorry, can't agree. In the initial publication of the LSA/Sport Pilot
Rules and
the logic behind them, the FAA has this key statement:

"The use of Form 337 is not required because special light-sport aircr
aft will
be built to a consensus standard "accepted" by the FAA, but not "appro
ved" by
the FAA." (page 136 of the Word document).

There is a lot in that document that isn't anything like the present
rules so I don't put much faith in it anymore.

Also the statement you quote could be interpreted as saying that
because the planes are built to the consensous standards, no changes
are permitted. There are now provisions where all changes must be
approved by the manufacturer. There is also a system simular to ADs
that the manufacturer handles instead of the FAA.


This is echoed by FAA Order 3120-2F Change one, Paragraph 121 d:

"d. Light-Sport Aircraft Construction. The manufacturer of an aircraft
for
airworthiness certification in the light-sport category must manufactu
re the
aircraft to the design requirements and quality system of the applicab
le
consensus standard that has been accepted by the FAA and published thr
ough a
notice of availability in the Federal Register."

"Accept" is not the same as "Approve." Imagine your best friend sayin
g to you,
"I'm gay." Responding, "I accept" is a HECK of a lot different than s
aying "I
approve." :-)

Ron Wanttaja

You are correct about the gay part but you might be splitting hairs
when it comes to the FAA. There must be other references in the FARs
and 8130. I hope you are right Ron but I'm gonna reserve judgement
until I see it in operation. The FAA has continued to make changes and
clarifications as the problems have shown up. This issue just hasn't
been in the spotlight yet because the last I heard, there has only been
one 16 hour class and no 120 hour classes yet. Blakely has talked
about 44 sport pilots so far and another source said 100. Either way
it's gonna be a while before this becomes an issue.

As long as a SP can fly the lighter weight experimental amature built
planes, I don't expect to ever get involved with the consensous
standards planes anyway.

When we did the S-LSA certification on the Aerostar Festival, the FAA
required us to add a statement to the maintenance manual, "Repairs or
modifications to the airplane not described in this manual must be
approved by the manufacturer". This basically means that the
manufacturer will have to be consulted on a modification and do the
necessary engineering in order to approve it. Similar to the 337
process but just not done by the FAA.

Rick Pellicciotti
LightSportFlying.com

Hey Rick,
So how much is gonna cost me to come over and fly that thing?! Do you
plan on flying over to TRI or the area? I'd love to meet you and see the
plane.

Patrick
student SPL
aircraft structural mech

"rpellicciotti" wrote in message
ups.com...
When we did the S-LSA certification on the Aerostar Festival, the FAA
required us to add a statement to the maintenance manual, "Repairs or
modifications to the airplane not described in this manual must be
approved by the manufacturer". This basically means that the
manufacturer will have to be consulted on a modification and do the
necessary engineering in order to approve it. Similar to the 337
process but just not done by the FAA.

Rick Pellicciotti
LightSportFlying.com

We will take the airplane on tour this fall. We will be in Union City,
Tn on the 15th of september. Calhoun, Ga on the following weekend, the
US Sport Aviation expo in Sebring, FL the end of October and the AOPA
Expo the following week in Tampa.

Perhaps will will get over to your area in there somewhere. Why don't
you just come over to Memphis most anytime and fly the thing? Just give
me a call first and make sure we are going to be in town.

Rick Pellicciotti
LightSportFlying.com


W P Dixon wrote:

Hey Rick,
So how much is gonna cost me to come over and fly that thing?! Do you
plan on flying over to TRI or the area? I'd love to meet you and see the
plane.

Patrick
student SPL
aircraft structural mech

"rpellicciotti" wrote in message
ups.com...

When we did the S-LSA certification on the Aerostar Festival, the FAA
required us to add a statement to the maintenance manual, "Repairs or
modifications to the airplane not described in this manual must be
approved by the manufacturer". This basically means that the
manufacturer will have to be consulted on a modification and do the
necessary engineering in order to approve it. Similar to the 337
process but just not done by the FAA.

Rick Pellicciotti
LightSportFlying.com

That sounds about right......I hold a Repairmans Certificate for the
plane that I built, but I cannot make repairs on it.

Neal

wrote in message
ups.com...
That sounds about right......I hold a Repairmans Certificate for the
plane that I built, but I cannot make repairs on it.

Neal


Uh, Why?

Actually, I was referring to Ron's mentioning of FAR 65.104(b). Yes, I
actually do make the repairs, but you would think the FAR would also
mention that I COULD make the repairs and not just do the inspectiion (
since it is a Repairmans Certificate. ) According to Ron, I ( or
anyone else ) am not restricted from making the repairs.

Neal