FAA Order 8130.2K 8/28/2024 Operating Limits

[Jim Meade]

Those considering changing from SLSA to ELSA will have to comply with FAA Order 8310, currently edition 2K dated 8/28/2024.  It is worth study before you decide to go ELSA and before your DER writes your Operating Limits.  The DER has limited ability to choose or modify the elements, but if you study the Order ahead of time you may determine what may be authorized or required for your aircraft.  Changing to ELSA may not exempt you from some maintenance procedures you now consider onerous or optional.

https://www.faa.gov/documentLibrary/media/Order/8130.2K.pdf

[Anticept]

Many of these are also automatically applied in the application process. What used to theoretically be optional regarding ignoring safety directives and enforceable time limits is no longer optional without waivers.

[EricB]

In slogging through the lengthy and redundant document I found this:

(5) Maintenance and Inspection Procedures. (a) Verify that the maintenance and inspection procedures are with the aircraft and that they apply to the make, model and S/N of the aircraft being inspected per § 21.193(e)(3). (b) Verify the maintenance and inspection procedures address engine/powerplant maintenance. Overhaul procedures for the engine/powerplant are not mandatory. Engine/powerplant procedures may be incorporated within the aircraft maintenance manual entirely or by reference to a separate engine/powerplant manual (such as a manual from the engine OEM). I

 

That would imply that the Rotax "requirement" for overhaul or replacement at 15 years is not included in the shift to Experimental.

Thoughts, comments?

[Roger Lee]

I talked directly to one of the top FAA legal heads in Washington, DC about the TBO. They agreed with what I said and had me write it up and document everything. I ask this to be done quickly and make a decisive decision, but who knows when they will publish anything. Like they said Rotax doesn't make the rules. They do. Why would they allow certified to go on condition and not Light Sport that has a far better safety record. Hopefully it will come out sooner than later.

[Tom Baker]

It is my understanding that the TBO issues will go away with Mosaic, so I doubt that you will get a ruling from FAA legal on the issue. This info came from an industry stakeholder during a conversation about TBO.

[GlennM]

11 hours ago, EricB said:

 Overhaul procedures for the engine/powerplant are not mandatory.

That would imply that the Rotax "requirement" for overhaul or replacement at 15 years is not included in the shift to Experimental.

Thoughts, comments?

I read this as you do not need to have a copy of the engine overhaul manual with the aircraft.

 

I don't think light sport has as good of safety record regarding accidents as certified aircraft per flight hour. If Light Sport were the same as certified, they would be called certified and they would not have a whole category to themselves.

[Tom Baker]

9 hours ago, GlennM said:

If Light Sport were the same as certified, they would be called certified and they would not have a whole category to themselves.

They are issued an airworthiness certificate. That certificate certifies that they meet the applicable standards for issuance of the certificate. So they are in fact certified, it is just the certification is different than for standard category aircraft. The reason they are done differently according to my understanding is that Bill Clinton signed a law or made an executive order that says the FAA should get out certification business, and it should move to an international standard. The Light Sport category was the first where this happened. 

[Anticept]

I agree that they should get out of certification, but they SHOULD remain in oversight to make sure manufacturing and maintenance continues to be compliant with standards.

If anything, there's not enough enforcement on compliance.

[Jim Meade]

9 hours ago, Anticept said:

I agree that they should get out of certification, but they SHOULD remain in oversight to make sure manufacturing and maintenance continues to be compliant with standards.

If anything, there's not enough enforcement on compliance.

I'm not going to get in an argument, but speak for yourself, not me.

[Anticept]

I won't speak for anyone but myself, but I had seen enough crap to say there's some alarming stuff that get through because of mechanic shopping or pilots withholding info because they know it will get expensive, and the complacency of "it ain't broke yet" on items that can have nasty failure modes. That's where my opinion comes from.