There have been multiple questions from Airframe and Powerplant (A & P) mechanics and Special Light Sport Aircraft (S-LSA) owners about proper authorization for performing maintenance and inspection in S-LSA aircraft in the field- especially on the Cessna Skycatcher and PiperSport. The general assumption is that an A & P is a certified aircraft mechanic therefore he is authorized. Most A & Ps are surprised to learn how this new world works. The truth is maybe they are authorized, but maybe they are not.
The Light Sport Rule is still relatively new and was a large, sweeping change in the regulations. There is a lot to learn and understand. I have had many conversations with A&Ps and most are surprised and shocked to learn about the differences between the rules for maintenance and inspections on S-LSA compared to type certificated aircraft.
The main areas of confusion for A & P mechanics include the S-LSA compliance link to the ASTM Consensus Standards, the significance of the manufacturer’s manuals, factory required training, and the process for any alteration or repair to an S-LSA. The authority given to the manufacturer of the S-LSA is a world of opposites to an A & P. Manufacturers list levels of certification in their maintenance manual and can even require factory training. One A & P compared the S-LSA manufacturer’s authority to “the fox watching the hen house.” The concept of manufacturer control is so completely foreign to an A &P who is use to maintaining type certificated aircraft that , in fact, it seems wrong.
The salient point that any A & P mechanic must keep in mind: The S-LSA is a completely different animal. You must have a solid light sport foundation if you want to incorporate this category into the aircraft that you service. There are many opportunities for an A & P to unknowingly render an S-LSA out of compliance making the airworthiness certificate invalid.
So what is required? First, the A & P level of certification must be listed in the manufacturer’s maintenance manual. If factory training is required, the A & P must complete that factory training. The consensus standard requires the manufacturer to determine what additional training is required for the technician to be qualified to perform those tasks and the A & P must comply. Remember, all authorization must be in writing, either listed in the manual or in a letter of authorization from the manufacturer. If an A &P needs to modify or repair an S-LSA, the mechanic must contact the manufacturer to determine if the major repair or major alteration is authorized and determine if additional training is needed.
One example of factory training is the Rotax Training Course. The Rotax 912 is by far the most popular engine used in S-LSAs. Rotax requires factory training to perform service or maintenance on Rotax engines. So an A&P mechanic is required to have this Rotax factory training to perform any work on a Rotax engine. The engine is manufactured to, and must comply with, the ASTM standards to be used in the S-LSA aircraft. The compliance statement from Rotax states that the engine will be in compliance only if it is maintained according to the manuals and the technician has completed the Rotax training. In addition, there are Rotax guidelines published that go much further and state the intent and scope of training and its limitations within the specialty programs.
The A &P must have authorization for each and every task he or she performs on an SLSA. For example, I know an A & P IA who also has his LSRM and all 3 levels of Rotax certification and yet one S-LSA manufacturer released a service bulletin, which requires a factory approved service center to perform the work. In this case, the A &P IA cannot perform the repair required by that service bulletin.
If the authorization for a major repair or alteration allows an A & P to complete a major repair, the mechanic must remember that when working on S-LSA, the aircraft’s consensus standard, maintenance manual, and instructions for continued airworthiness must be used instead TC data.
Furthermore, on special light sport aircraft, both Part 43 and the general privileges and limitations of FAR section 65.81, still apply. To satisfy the requirements of § 65.81, the mechanic must be able to prove to an FAA inspector that he or she performed that work at an earlier date, was trained to do the work, or was supervised by another mechanic or repairman performing that task, in addition to complying with the manufacturer’s training requirements and having the authorization in writing.
In order to add new equipment (or to modify anything) on an S-LSA, the maintenance technician or owner of the S-LSA must make a specific request to the manufacturer. It is completely up to the manufacturer to allow anyone to install the equipment (or make the modification). There is no FAA involvement.
If the S-LSA has a type certificated engine or Technical Standards Order (TSO) product installed, major repairs and major alterations on these FAA-approved products will require compliance with the recording requirements to document such changes contained in Part 43.
S-LSA aircraft must comply with ASTM Consensus Standards as well as Federal Aviation Regulations. S-LSA aircraft are issued a statement of compliance based on ASTM standards. So it is essential for an A &P to understand this new world. It is very common for A & Ps to service, repair, modify, and/or inspect an S-LSA and not understand the requirements, rendering the S-LSA out of compliance.
The bottom line is that for an S-LSA, any service, inspection, modifications or repair must be approved in writing- either listed in the manual or by written manufacturer’s approval including level of certification to perform the task. This includes installation of new avionics or any propeller changes. Finally, all documentation must be included in the logbook records.
Maintenance of aircraft is a lot like speeding on the highway, you can get away with it a lot of the time. Once in a while you run into a speed trap and get caught or you will have an accident. When the cause is found to be excessive speed or some other violation, you pay.
Our Light Sport Repairman Maintenance Seminar is designed for aircraft maintenance professionals, including A & Ps who are interested in servicing the LSA fleet. An increasing number of A & Ps are taking advantage of this opportunity to learn all that is required to service this new category of aircraft. A recent graduate emailed the following comment, “As a A&P, and I.A., I highly recommend your course for all A&P's. I would also recommend that A&P's be warned of the differences between the regular GA maintenance, the LSA world, and the Rotax engine. . .”
One additional benefit: the course meets the recent experience requirements for those mechanics that have been inactive. If you haven't been active with your A&P for over 6 months, you would have to work under an A&P to supervise you for 6 months before you could work independently and release an aircraft to service. This three week LSA specialty class may be just what you are looking for.
For more information or to inquire about the Light Sport Repairman Training course, contact Rainbow Aviation Services or visit www.rainbowaviation.com.