Sport Pilot Talk

nbjeeptj · Joined: 23 Jun 2011 Posts: 46 Location: Gilbert SC

Can I as the owner of a AMD zodiac 601xl / SLSA work on or replace the vhf radio in it or does the work have to be done by avionics tech. Long story short I just got started on my sport pilot training and the radio has failed. The tech at the airport I hangar at said it could be weeks. I am a master electrician with many, many years trouble shooting control circuit problems and am confident that I could find a wiring problem or replace the radio but do not want to do any thing that the FAA says I cant do.

roger lee · Posted: Fri Jul 08, 2011 7:52 pm Post subject: Radio work

If it's an Experimental LSA anyone can do the work. If it's an SLSA you are out of luck and most all work on the plane has to be a mechanic or in your case an avionics person.

drseti · Joined: 28 Nov 2009 Posts: 1390 Location: Lock Haven PA

roger lee wrote: If it's an SLSA you are out of luck

Not necessarily. If you are the owner/operator, and a licensed pilot (SP or above), then you can take the 16 hour course and get a repairman's certificate. I believe you can then do repairs in accordance with the mfgr's instructions or AC 43-13, and sign them off yourself using your LSRI-A number.

cogito · Joined: 24 Mar 2011 Posts: 29 Location: Los Angeles

drseti wrote: roger lee wrote: If it's an SLSA you are out of luck

Not necessarily. If you are the owner/operator, and a licensed pilot (SP or above), then you can take the 16 hour course and get a repairman's certificate. I believe you can then do repairs in accordance with the mfgr's instructions or AC 43-13, and sign them off yourself using your LSRI-A number.

Thought you had to take the 120 hr course and be a LSRM (not LSRI) to work on an SLSA. The 16 hr. course is so you can work on your own ELSA.

roger lee · Posted: Sat Jul 09, 2011 12:02 am Post subject: ELSA verses SLSA

Hi Paul,

The 16 hr. course is only for ELSA. If it is an SLSA it is the 120 hr. course LSRM-A or an A&P and he said it was an SLSA so the pilot owner is out.

16 hr. course doesn't count on an SLSA.

Jack Tyler · Posted: Sat Jul 09, 2011 6:10 am Post subject:

Roger, is it permissible for the owner of an S-LSA a/c to perform limited maintenance & upkeep on that a/c in the same way a non-A&P is allowed to do limited maintenance on his/her Part 23 a/c? Changing oil, e.g.? Your earlier answer is the overall correct one, as I understand it, but I've meant before to ask if 'minor maintenance' was allowed on S-LSA a/c but failed to do so. (Of course, 'radio repair' isn't 'minor maintenance'...). Thanks for any info you can share on that.

nbjeeptj, while I think Roger has given you the correct legal A to your Q, I don't think someone with your experience/qualifications is going to jeopardize a/c safety by doing some basic troubleshooting. After all, the problem could be something simple like a grounded coax or power supply wire. Doing some basic fault isolation hardly seems contrary to the intent of the ASTM standards and, in your shoes, I'd proceed to the point where the radio needed opening up (although in truth, I'd do it covertly). Sometimes rulebooks are there for general guidance moreso than explicit A's to every possible Q (IMHO of course).

nbjeeptj · Joined: 23 Jun 2011 Posts: 46 Location: Gilbert SC

Thanks for all the info. The maintenance manual states that I as an owner could pull the radio from the tray for repair or replacement, However I would have to have at least a sport pilot license. I an just a student at this point. I will just have to wait and get the A&P to do it. I can not wait to get my instruction from my CFI on how to pull this radio out as this task must be covered in the sport pilot program since AMD requires at least a sport pilot to do it. :lol: :lol:

drseti · Joined: 28 Nov 2009 Posts: 1390 Location: Lock Haven PA

roger lee wrote: 16 hr. course doesn't count on an SLSA.

I checked the regs, and Roger is indeed correct. (I shoulda known that!) :(

As for Jack's question, the regs distinguish between major repair, minor repair, and preventive maintenance. As I understood this from Carol Carpenter at Rainbow Aviation (the 120 hour course), a minor repair is anything for which instructions are published in the maintenance manual. A major repair is anything not covered in the manual.

What Jack is thinking about (owner/operator performed tasks) are preventive maintenance. There is a list of specific tasks in the appendix to AC 43-13, listing owner/operator approved tasks -- but (1) one must be a private pilot or above to perform them, and (2) the list doesn't apply to S-LSAs anyway, just certified aircraft.

Which doesn't mean an owner/operator with a SP certificate (or less) can't perform preventive maintenance on an S-LSA. The manufacturer's maintenance manual will dictate who can do what to whom. Some (as nbjeeptj found out) indicate you must be a Sport Pilot or above to do something as simple as pull a radio from a tray. Other manuals simply say "owner," and mine says "appropriately rated mechanic" (which I interpret as holder of an LSRM-A, which is why I went for that particular rating). The FAA leaves a lot in the hands of the manufacturer, so you have to read the restrictions the manufacturer places on each task in the manual.

If you want to cover all bases, take the 120 hour course!

drseti · Joined: 28 Nov 2009 Posts: 1390 Location: Lock Haven PA

nbjeeptj wrote: I can not wait to get my instruction from my CFI on how to pull this radio out as this task must be covered in the sport pilot program

Wow, I'm going to have to revise my SP curriculum! Good catch -- and thanks for the heads-up. :lol:

Jack Tyler · Posted: Sat Jul 09, 2011 8:15 am Post subject:

Thanks for the clarification, Paul.

comperini · Joined: 24 Feb 2008 Posts: 152 Location: California

drseti wrote:

What Jack is thinking about (owner/operator performed tasks) are preventive maintenance. There is a list of specific tasks in the appendix to AC 43-13, listing owner/operator approved tasks -- but (1) one must be a private pilot or above to perform them, and (2) the list doesn't apply to S-LSAs anyway, just certified aircraft.

You sure about that? 14 CFR 43.3(g) says:

"Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category."

Appendix A of 14 CFR 43 describes the preventive maintenance items

roger lee · Posted: Sat Jul 09, 2011 11:29 pm Post subject: Maint

Hi Bob,

Hi guys,
Bob's right

Quote:

"Except for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under part 121, 129, or 135 of this chapter. The holder of a sport pilot certificate may perform preventive maintenance on an aircraft owned or operated by that pilot and issued a special airworthiness certificate in the light-sport category."

drseti · Joined: 28 Nov 2009 Posts: 1390 Location: Lock Haven PA

Thanks, Bob and Roger, for correcting me. I didn't recall the second sentence of 43.3 (g).

Are you sure the list of preventive maintenance tasks in FAR 43 Appendix A applies to S-LSAs? I thought only the manufacturer could designate owner-approved PM tasks.

comperini · Joined: 24 Feb 2008 Posts: 152 Location: California

drseti wrote:
Are you sure the list of preventive maintenance tasks in FAR 43 Appendix A applies to S-LSAs? I thought only the manufacturer could designate owner-approved PM tasks.

The regulations still trump anything the manufacturer says. Part 43 would not even mention PM if they intended for the manufacturers to control it.

drseti · Joined: 28 Nov 2009 Posts: 1390 Location: Lock Haven PA

comperini wrote: [The regulations still trump anything the manufacturer says. Part 43 would not even mention PM if they intended for the manufacturers to control it.

Bob, are you sure this isn't a case of the regs not having kept pace with the reality? FAR 43 Appendix A (c) predates LSAs by several decades, so "intent" may not be relevant. FAA has clearly indicated that they defer to the mfgr and ASTM in areas regarding maintenance on S-LSAs. Unless the acft maint manual specifically says a particular task (or all preventive maintenance) can be performed by the owner, I was under the impression the PM task list in Appendix A would not apply. In fact, A (c) is only a definition of what tasks constitute PM, not (specifically) who can perform them. The only mention in Appendix A of who can perform any of the tasks appears in A (c) (30) (i), and that applies to primary category aircraft, not LSAs.

This sounds like a question for Carol Carpenter, as she was on the ASTM committee that wrote the rules.