Differential Leak-Down Compression Values: A Lesson Learned

[3Dreaming]

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).

I did specifically say SLSA. As was already brought up 43 does cover sport pilots and SLSA's.

[3Dreaming]

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.

Paul, I'm sorry, but I am going to disagree with you on this too. The FAA is the governing agency for aviation in this country. They are the ones who grant privileges and limitations. A manufacturer can not limit or add to those privileges, the FAA does not give them that right.

[drseti]

Tom, didn't you take Rainbow's LSRM course? Carol Carpenter was very clear on how the FAA empowers SLSA manufacturers to set maintenance standards and requirements. Since she serves on ASTM committee F39, I'll defer to her on this one.

[Wm.Ince]

Tom, didn't you take Rainbow's LSRM course? Carol Carpenter was very clear on how the FAA empowers SLSA manufacturers to set maintenance standards and requirements. Since she serves on ASTM committee F39, I'll defer to her on this one.

Gentlemen,

Can we get some clarification on this?

[roger lee]

3Dreaming is correct.
An SLSA Mfg can only allow what the FAR's allow. The MFG can not add additional restrictions or give away the farm from what the FAR's already state.

[FastEddieB]

Note that this says absolutely nothing about the type of airworthiness certificate issued. Ergo, the Ercoupe I sometimes instruct in is an LSA.

Professor,

Just to be clear...

...this does represent a change in your position since I took your "stepping up" class at Lock Haven last year?

As an aside...

My Sky Arrow AMM says an LSRM or A&P is required to change the battery. But changing and servicing the battery is included in Part 43 as Preventive Maintenance an owner can do.

Where does that leave an owner if he screws up a battery install which leads the FAA to investigate?

And might violating the AMM restrictions be called up in a civil suit?

This is academic for me now since my conversion to Experimemtal, but could certainly affect others

[drseti]

...this does represent a change in your position since I took your "stepping up" class at Lock Haven last year?

Yes it does, Eddie. Tom convinced me that the FAR 1.1 definition applies. I'm willing to learn from others.

My Sky Arrow AMM says an LSRM or A&P is required to change the battery. But changing and servicing the battery is included in Part 43 as Preventive Maintenance an owner can do.

This is where I disagree with Tom and Roger. I believe the AMM takes precedence. The manufacturer's legal authority to make this restriction comes from the FAA, in the form of the Operating Limitations they provided, that bear an FAA signature. The SLSA OLs say, among other things, that maintenance must be performed in accordance with the manufacturer's instructions. Seems to me this trumps Part 43.

[roger lee]

Hi Paul,

"The SLSA OLs say, among other things, that maintenance must be performed in accordance with the manufacturer's instructions. Seems to me this trumps Part 43."


This is correct, but the MFG must stay within the FAR's regs when writing their preferences for their product. No MFG can over ride the FAR's. No MFG can superseded the FAR's or all the MFG's could write and do whatever they wanted with impunity. The aircraft MFG has no regulatory authority. This was a problem in everyone's understanding of MFG's manuals for years until it got ruled on. This came out of a paper issued from the FAA legal department a few years back.

If MFG's could over write part 43 what teeth or authority would part 43 carry any longer.

[FastEddieB]

I hate to ever side with the more restrictive interpretation, but...

...imagine that 3i or FD or whoever looked critically at peculiarities involved in changing out their battery (complicated disassembly of structure to access, or specialized tools or test equipment needed, or whatever), would it not make sense for them to have a means to require certain certification for certain tasks?

Like I said, I'm hesitant to argue this position since it was a thorn in my side while I was S-LSA. I mean, one dzus and two bolts to swap batteries, yet the AMM required me to call and probably pay an A&P or LSRM-A to accomplish it.

One of the many joys of being Experimental is not worrying about any of this.

But I've also shown that something as simple as replacing a battery can be royally screwed up by a "gumption trap"!

[roger lee]

On an SLSA you are allowed to do the preventative maint. allowed in the FAR's. For the most part anything not listed there would require a mechanic. If the procedure is not described in the maint. manual then technically your are supposed to call the MFG for guidance. This last part though shows where many SLSA MFG's are lacking in their manuals which puts many owners or mechanics on the spot. Most also don't know that if they make an authorized change to an aircraft that deviates from the original MFG setup that they are supposed to send to the MFG a "Major repair or alteration" form. (similar to a 338) Some MFG's really lag here. FD has them on their website. The MFG is supposed to keep that on file for that particular aircraft.

The LSA world is not through with trudging through its rules, regs and MFG issues, but at least they are working on it.

[3Dreaming]

Tom, didn't you take Rainbow's LSRM course? Carol Carpenter was very clear on how the FAA empowers SLSA manufacturers to set maintenance standards and requirements. Since she serves on ASTM committee F39, I'll defer to her on this one.

I did not take Rainbow Aviations class, I am one of those old A&P's who knows nothing about LSA's
I don't know, but I'm pretty sure the Rotax ruling kind of goes against that line of thinking.