Differential Leak-Down Compression Values: A Lesson Learned

H. Paul Shuch is a Light Sport Repairman with Maintenance ratings for airplanes, gliders, weight shift control, and powered parachutes, as well as an independent Rotax Maintenance Technician at the Heavy Maintenance level. He holds a PhD in Air Transportation Engineering from the University of California, and serves as Director of Maintenance for AvSport of Lock Haven.

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drseti
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

Tom, there's a disconnect in the Part 43 appendix on preventive maintenance. It specifies what an owner/operator can do, if he or she happens to be a private pilot or above. So, it doesn't govern a Sport Pilot with an SLSA, any more than it governs anyone doing any kind of maintenance on any kind of experimental. In the former case, the Operating Limitations apply. In the latter, there are no limitations whatever on maintenance.
I think it's fair to say that FAR 43 applies only in those cases where FAR 43 applies. :(
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
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VL Roberts
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by VL Roberts »

FAR 43.3(g) permits the holder of a Sport Pilot certificate to perform preventive maintenance on an LSA.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

Not exactly. What it says is:
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.
Now, we all agree that certain Cubs, Champs, Ercoupes, T-Craft, Luscombes, and other antiques are LSAs. However, they have standard airworthiness certificates, so a Sport Pilot is prohibited from doing preventive maintenance on them (even though he or she can fly them).
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by roger lee »

I agree with Paul,


"Now, we all agree that certain Cubs, Champs, Ercoupes, T-Craft, Luscombes, and other antiques are LSA's."

These aren't LSA's, just fall within the sport pilot license restriction to fly.

Sport Pilots can't work on a standard category certificate aircraft. That's the problem in the language. The aircraft may be flown by a Light Sport pilot if it meets the LSA requirements, but you can't work on it as a sport pilot because of its standard certification. These would all have to have an LSA special airworthy certificate.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by VL Roberts »

drseti wrote:Tom, there's a disconnect in the Part 43 appendix on preventive maintenance. It specifies what an owner/operator can do, if he or she happens to be a private pilot or above. So, it doesn't govern a Sport Pilot with an SLSA, any more than it governs anyone doing any kind of maintenance on any kind of experimental. In the former case, the Operating Limitations apply. In the latter, there are no limitations whatever on maintenance.
I think it's fair to say that FAR 43 applies only in those cases where FAR 43 applies. :(
I was addressing your statement above, that part 43 doesn't govern a Sport Pilot with an SLSA.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

roger lee wrote:These aren't LSA's, just fall within the sport pilot license restriction to fly.
I used to harbor that belief myself, Roger, until Tom convinced me otherwise by pointing me to the definition in FAR 1.1:

Light-sport aircraft means an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:

(1) A maximum takeoff weight of not more than—

(i) 1,320 pounds (600 kilograms) for aircraft not intended for operation on water; or

(ii) 1,430 pounds (650 kilograms) for an aircraft intended for operation on water.

(2) A maximum airspeed in level flight with maximum continuous power (VH) of not more than 120 knots CAS under standard atmospheric conditions at sea level.

(3) A maximum never-exceed speed (VNE) of not more than 120 knots CAS for a glider.

(4) A maximum stalling speed or minimum steady flight speed without the use of lift-enhancing devices (VS1) of not more than 45 knots CAS at the aircraft's maximum certificated takeoff weight and most critical center of gravity.

(5) A maximum seating capacity of no more than two persons, including the pilot.

(6) A single, reciprocating engine, if powered.

(7) A fixed or ground-adjustable propeller if a powered aircraft other than a powered glider.

(8) A fixed or feathering propeller system if a powered glider.

(9) A fixed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyroplane.

(10) A nonpressurized cabin, if equipped with a cabin.

(11) Fixed landing gear, except for an aircraft intended for operation on water or a glider.

(12) Fixed or retractable landing gear, or a hull, for an aircraft intended for operation on water.

(13) Fixed or retractable landing gear for a glider.
Note that this says absolutely nothing about the type of airworthiness certificate issued. Ergo, the Ercoupe I sometimes insteuct in is an LSA.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

VL Roberts wrote: I was addressing your statement above, that part 43 doesn't govern a Sport Pilot with an SLSA.
I concede that point, VL.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
[email protected]
AvSport.org
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by VL Roberts »

So, to take it a step further, if the manufacturer of an SLSA says one must have a repairman certificate to change spark plugs, but the FAA states in Part 43 that the owner of an SLSA who holds a pilot certificate can change spark plugs, which governs?

Not an issue for me, I own a Skycatcher and Cessna has deferred to Part 43 as regards preventive maintenance , but I would be interested to know what owners of other SLSA's do when confronted with conflicting rules. Seems similar to the issue of who can perform work on a ROTAX.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

This plays out at several different levels. There's no physical way for a manufacturer to prevent an owner from performing preventive maintenance. Legally, the FARs are on the side of the owner/operator. However, a manufacturer can decide that the warranty is void if all work is not performed by their authorized person. In the event of damage, the insurance company could probably make a case for voiding coverage if the insurance policy says all manufacturer's maintenance requirements must be followed. And if an accident results in a lawsuit, you can be sure that plaintiff's counsel will raise this issue. Juries are less interested in the FARs than they are in "justice" for victims.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
[email protected]
AvSport.org
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by dstclair »

I know we've opined on this in the past but I can't find the the thread.

What is the current thought on the case where the S-LSA manufacturer specifically allows the owner/operator to do maintenance beyond the narrow list contained in FAR 43? Does the S-LSA maintenance manual over-rule the FAR?
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

Yes, it does, Dave. In the case of an SLSA, the FAA gives the manufacturer considerable discretion. But, of course, the owner/operator is obligated to follow the exact procedures outlined in the manufacturer's maintenance instructions.

Edit: Most SLSA manufacturers are very hesitant to give the owner/operator broad powers beyond what's generally considered normal preventive maintenance.
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
[email protected]
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by VL Roberts »

drseti wrote:This plays out at several different levels. There's no physical way for a manufacturer to prevent an owner from performing preventive maintenance. Legally, the FARs are on the side of the owner/operator. However, a manufacturer can decide that the warranty is void if all work is not performed by their authorized person. In the event of damage, the insurance company could probably make a case for voiding coverage if the insurance policy says all manufacturer's maintenance requirements must be followed. And if an accident results in a lawsuit, you can be sure that plaintiff's counsel will raise this issue. Juries are less interested in the FARs than they are in "justice" for victims.
Most aircraft warranties are valid for how long, maybe a year ? So not an issue for most owners. I've never seen an aircraft insurance policy that said all manufactures maintenance requirements must be followed . Every policy I've seen only requires the policy holder to comply with FAR's, if a policy required otherwise I wouldn't buy it. As for an accident, all sorts of issues can be raised, so best to be well insured and structure your personal assets to protect against losses.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

VL Roberts wrote:Most aircraft warranties are valid for how long, maybe a year ?
Two, tops.
I've never seen an aircraft insurance policy that said all manufactures maintenance requirements must be followed.
Common for commercial policies; not usually an issue for the private owner. But, read your policy carefully! :wink:
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
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VL Roberts
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by VL Roberts »

drseti wrote:
VL Roberts wrote:Most aircraft warranties are valid for how long, maybe a year ?
Two, tops.
I've never seen an aircraft insurance policy that said all manufactures maintenance requirements must be followed.
Common for commercial policies; not usually an issue for the private owner. But, read your policy carefully! :wink:
If by "commercial policy" you mean a policy that flight schools operate under, still haven't seen an insurance requirement to comply with " all manufactures maintenance requirements". If that clause was in a flight schools policy I would think there would be issues with claims since most owners ignore " mandatory service bulletins" issued by manufactures for FAA certified aircraft.
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Re: Differential Leak-Down Compression Values: A Lesson Lear

Post by drseti »

It's in my policy, and I do indeed comply with all "mandatory" service bulletins, even if not regulatory. I figure the manufacturer knows better than I how best to keep my plane operating at peak performance. And although I realize that most private owners ignore much of this, I sincerely hope that most flight schools don't!
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
Prof H Paul Shuch
PhD CFII DPE LSRM-A/GL/WS/PPC iRMT
AvSport LLC, KLHV
[email protected]
AvSport.org
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