A Heavy Dose of Light-Sport
An Inside Look at Light-Sport Aircraft Maintenance Responsibilities
Martin Bailey
Reprinted with permission from FAA Aviation News
Are you confused about some of the maintenance regulations for light-sport aircraft (LSA)? Don’t worry, you’re not alone. In this article, we’ll look at some examples that illustrate the “do’s and don’ts” for LSA maintenance, as well as some the significant differences you’ll find among experimental light-sport aircraft (ELSA) and special light-sport aircraft (SLSA).
What Exactly Is a Light-Sport Aircraft?
With today’s stressed economic environment, general aviation has taken quite a hit in terms of growth and activity. The one bright spot, however, has been the growth of the LSA industry. Figures from the recent 2009 FAA Aviation Forecast Conference show the LSA market growing at a rate of 12 percent annually from now until 2012. Reduced costs of purchasing and building, as well as less restrictive regulations for maintaining and training in an LSA has caught the eye of many an aviator.
Plainly stated, an LSA is a simple, low performance, low energy, and single-engine aircraft with a maximum weight of 1,320 pounds (1,430 pounds if used for water operations). It is designed for one or two occupants and must meet the parameters specified for a light-sport aircraft in Title 14 Code of Federal Regulations (14 CFR) part 1.1. Because of these unique restrictions, the FAA has been able to develop policies and regulations outside the traditional regulations for general aviation. Among the significant differences are the requirements for maintenance procedures.
SLSA versus ELSA
Aircraft characterized as ELSA do not fall under part 103 operations. They are often assembled from a kit and are certificated under Title 14 Code of Federal Regulations (14 CFR) section 21.191(i) (1), (2), (3). Aircraft characterized as SLSA, on the other hand, are manufactured to an industry standard, sold as “ready-to-fly,” and certificated under 14 CFR sections 21.190. Both ELSA and SLSA are issued a special (pink) airworthiness certificate (Form 8130-7 with attached operating limitations).
Because LSAs can involve federal and/or manufacturer-based regulations and limitation standards, there are differing levels of restriction and distinct maintenance requirements for each of the two. The following scenarios are intended to highlight key differences in maintenance procedures for ELSA and SLSA:
Logbook Entry for Annual Condition Inspection
Johnny Wrench, a certificated A&P, just completed an annual condition inspection on an ELSA powered parachute. He documented the following in the maintenance logbook:
“I certify that this aircraft has been inspected on July 1, 2009, in accordance with the scope and detail of Appendix D to part 43, or the manufacturer’s maintenance and inspection procedures, and was found to be in an airworthy condition.”
Is Johnny’s logbook entry correct?
No. When performing a condition inspection on an ELSA or SLSA aircraft, the word airworthy is not used. Instead, Johnny should have noted the aircraft was in a “condition for safe operation.” SLSA and ELSA aircraft do not have FAA-approved type designs, so the term “airworthy” is not used. You can also check the operations limitations issued with the airworthiness certificate for the correct wording to use.
ELSA Maintenance Requirements
Ronnie Rivet was flying his new ELSA gyroplane when he noticed a crack in the windshield. Ronnie is familiar with this type of repair but is not an A&P or certificated light-sport repairman. Can he perform the windshield repair by himself?
Yes. Any individual, regardless of his or her certification level, can perform this procedure, or for that matter, any maintenance, preventive maintenance, repairs, or alterations to ELSA. Keep in mind, however, that Ronnie should perform the maintenance in accordance with standard practices.
SLSA Maintenance Requirements
Mary Micrometer owns a small flight training school using airplane-class SLSA aircraft. She also employs two mechanics. Rusty holds a light-sport repairman certificate with a maintenance rating. Tim holds a light-sport repairman certificate with an inspection rating and is taking the 80-hour training course for a maintenance rating (glider class). Rusty delegates the responsibility for performing a 100-hour inspection of the flight school’s airplane-class SLSA to Tim so that it can be used later that day for a training flight. Is Tim legal to carry out this task without a completed maintenance rating on his repairman certificate? Or, will he need to first complete his 80-hour course?
No, on both counts. Tim has a light-sport repairman certificate with an airplane-class inspection rating and can perform an annual condition inspection on an aircraft owned by him, but he is not authorized to perform the 100-hour required by 14 CFR sections 91.327. The 100-hour inspection requires a repairman certificate with maintenance rating. Although Tim has almost completed his 80-hour course for a maintenance rating, it is for glider class, which means that completing the course would still not authorize him to perform the 100-hour inspection on an airplane-class light-sport aircraft.
Airframe and Power plant Rating Privileges
Using the same SLSA flight school above, Mary hires an A&P-rated mechanic, Stan, who has just begun training for a light-sport repairman certificate. Rusty asks Stan to replace a propeller on one of the school’s SLSA aircraft and return the aircraft to service. The propeller is not an FAA-approved part nor is the installation an FAA-approved procedure. Is Stan legal to perform this task?
Yes. An A&P rated mechanic can approve and return to service an airframe/power plant/propeller, or any related part or appliance, of an SLSA aircraft after performing and inspecting a major repair or major alteration. This approval authority also extends to products that are not produced under an FAA approval, provided the work was performed under instructions developed by the manufacturer or a person acceptable to the FAA (see 14 CFR sections 65.85 and 65.87).
Safety Directive Compliance
Continuing with the same SLSA flight school example, Mary has received several safety directives (SD) from the manufacturer of the flight school’s SLSA fleet. Mary realizes performing the work required by these SDs will significantly affect the peak summer season of flight training. Since the SDs is not FAA-issued, Mary plans to delay taking action until the fall, well past the established compliance date. Can Mary still operate the aircraft in her fleet?
Yes and no. Noncompliance with a manufacturer-issued SD will prohibit Mary from using the aircraft under SLSA airworthiness certificates. However, Mary can opt to surrender the SLSA airworthiness certificates to FAA and apply for ELSA airworthiness certificates instead. If approved, the aircraft can still be flown—but a consequence of flying them under ELSA operating limitations is that they can no longer be used for hire or for training.
Please note that Mary does have some options for complying with the SD. According to 14 CFR sections 91.327(b) (4), she can:
Correct the unsafe condition in a manner A) different from that specified in the SD provided the person issuing the directive concurs with the action; or
Obtain an FAA waiver from the provisions B) of the SD based on a conclusion that the SD was issued without adhering to the applicable consensus standard.
Major Repairs/Alterations
Tommy Torque owns a weight-shift control SLSA aircraft with a type-certificated (TC) engine. He is a certificated light-sport repairman and has completed the 104-hour training course to receive a weight-shift control class maintenance rating. Tommy wants to install a new oil filter, for which there is a supplemental type certificate (STC). He installs the filter per the manufacturer’s procedures, notes the procedure in the logbook, but does not complete a Form 337. Is Tommy following proper procedures?
No. First, even though there is an STC to install a filter on a TC engine, Tommy must submit a request to the aircraft manufacturer for installation approval on that particular aircraft. Once approved and the procedure is completed, it must also be recorded on a Form 337 since it is an FAA-approved part. The ASTM data approved by the SLSA manufacturer for major repairs and alteration is FAA-accepted data and is required to be recorded in the aircraft records according to ASTM F 2483-05, section 9, 1-4. If it had been a non-FAA-approved part, a Form 337 would not be required.
Questions?
Many resources exist to help you answer questions like the ones above. Check out the resources listed under “For More Information” for a list of the key documents.
Martin Bailey is manager of Flight Standards Service’s Repair Station branch.
Tom Hoffmann and Caleb Glick contributed to this article. Hoffmann is a private pilot and holds an A&P certificate. Glick is an aviation safety inspector (airworthiness) with the Flight Standards Service’s General Aviation and Avionics Branch and is the point-of-contact for light-sport maintenance.
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