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.