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FAA LSA Special Considerations


paul m

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To all,

 

There may be an error in this document. Page 4 Note: States that owner/operator sport pilots (or higher level) can perform preventive maintenance as specified by the manufacturer. If this statement is intending to say that the manufacturer (SLSA) determines what constitutes preventive maintenance, this is incorrect. 14 CFR part 43 appendix A is what defines preventive maintenance.

 

Doug Hereford

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Yeah, I think so, too. FAR 43.3 (g) authorizes a pilot who owns an aircraft to perform preventative maintenance, and that includes sport pilots. What that is defined is in Appendix A. There was also a letter from the FAA legal office a little while back that addressed the issue and said the manufacturers could not impose maintenance training requirements stricter than the FAR on a certified mechanic or RLSM...not the issue here but would be surprised considering the above if the FAA would take a different stance with an owner.. Just shows you how much confusion there is about the light sport regs...

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Doug is right and has been that way for years now. It used to be the owners and aircraft MFG's that were confused, now it's more the owners, but it's getting better with more people become educated on the regs. Andy is right too, that letter I believe came out April 2010.

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The really frustrating part is that most of the confusion seems to have its source within the FAA (see above noted document at the beginning of this discussion). Last I checked, the CT maintenance manuals specify minimum levels of certification required for specific maintenance / preventive maintenance tasks. Legally speaking, these requirements can/should be ignored. In my opinion this information should not even be allowed to exist in the maintenance and inspection procedures manuals. There are numerous cases where FD allows pilots (sport pilots) to perform certain "inspection" items. Any pilot who performs a required inspection (or part of a required inspection) is in violation of the law (whether FD authorizes it or not).

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You are right again that most if not all the LSA Mfg's have failed terribly in having the right information in their manuals. Part of this comes form aircraft and manuals coming from overseas, but isn't an excuse since their are distributors in the US. That said many of the overseas Mfgs don't respond very well or quickly to US distributors. I can tell you that the FAA for at least a year or more has been going overseas and auditing LSA Mfgs. They give them a list of things to change or work on and if they fail to comply they can't sell LSA in the US. This is an on going process, but it is currently in progress and I believe it will make things better, but it may take a couple of years.

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There are numerous cases where FD allows pilots (sport pilots) to perform certain "inspection" items. Any pilot who performs a required inspection (or part of a required inspection) is in violation of the law (whether FD authorizes it or not).

Thanks for pointing this out. Can you cite one or two just to get me started? I'm not up on this.

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... I can tell you that the FAA for at least a year or more has been going overseas and auditing LSA Mfgs. They give them a list of things to change or work on and if they fail to comply they can't sell LSA in the US. This is an on going process, but it is currently in progress and I believe it will make things better, but it may take a couple of years.

 

Link to FAA report based on those audits.

http://photos.bydanjohnson.com/FAA_Final_LSA_Report.pdf

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Andy,

The letter that you mentioned was I believe, a direct result of a year and a half long argument I found myself involved in. Through the course if this process, I spoke with numerous individuals within the FAA and industry who were supposedly charged with knowing what they were talking about. Without exception, none of them did. In my opinion, most the misunderstandings that surround SLSA maintenance rules and requirements are as a direct result of these people's misunderstandings. My guess is that some of these same individuals are the ones doing these FAA audits of LSA manufacturers.

 

Jim,

Like Roger replied, examples run throughout the maintenance and inspection procedures manual section 3 inspection checklist. Sect 2.3 is devoted to minimum certification levels.

 

Not directly related to this discussion, but the section 3 Condition inspection checklist also has notations for inspection items to be performed during an annual condition inspection vs. a 100 hr. condition inspection (second and third columns from the right side of the checklist). This is also absolutely illegal, and these differences in inspection procedures should be ignored. There is only one condition inspection is the SLSA world.

 

Doug Hereford

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While we're at it, I have a question. Also in the FAA July 2013 Doc it says:

 

"[sLSA] aircraft may not be operated for compensation or hire except to tow a light-sport glider or an unpowered ultralight vehicle in accordance with 14 CFR § 91.309 or to conduct flight training."

 

Is it clearly stated anywhere that SLSA can be rented other than for purpose of flight training? (e.g. I take transition training and get checked out. I then rent the plane from the same flight school to fly solo. That would not seem to be "flight training" anymore to me.)

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