Part 23 Certification Bill Leaving LSA Out?

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MrMorden
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Part 23 Certification Bill Leaving LSA Out?

Postby MrMorden » Mon Nov 18, 2013 9:39 am

The new Part 23 rewrite bill that simplifies certification appears to simplify maintenance as well, allowing single engine aircraft under 2700lb to go into a "non-commercial" category that will essentially allow maintenance and installation of non-certified systems (autopilots, EFIS, etc) very much like E-AB aircraft. My question is, does this apply only to Part 23 aircraft, or LSA as well. If only Part 23, this is going to lead to a weird situation where "certified" airplanes have more latitude in maintenance and installed equipment than "non-certified" LSA.

Don't you love bureaucracy?!?
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby drseti » Mon Nov 18, 2013 9:53 am

Andy, as I interpret it, the ASTM rules already permit installation and maintenance of non-certified systems in an LSA. In the case of an E-LSA, pretty much anything goes, as long as the LSA performance limits are not exceeded. For an S-LSA, it is up to the original manufacturer to issue a Letter of Authorization, which they can do for non-certified equipment.
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby dstclair » Mon Nov 18, 2013 10:40 am

Andy,

There is no restriction against a LSA manufacturer getting a current S-LSA design certified under the new Part 23 rules. There are probably more costs involved than ASTM but could open other markets like the oft bemoaned MTOW. I have no idea whether the increased costs would be covered by increased sales.
dave

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MrMorden
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby MrMorden » Mon Nov 18, 2013 10:49 am

I'm not as confused by the installation of non-cert devices (that is WAY long overdue for certified airplanes), but more about the maintenance, which as I understand it (which could be wrong) is that if you enter this new category (non-commercial), you can keep your airplane as a Part 23 airplane and yet still do all your own maintenance (minus annuals) very much like an E-AB. The only way to do that with an LSA is to go experimental, which has some issues (for example, I cannot make my airplane E-LSA because my finance company will not finance experimental aircraft).

I'd like to be able to do much more of my own maintenance without the implications of going experimental. This bill seems to allow that for Part 23 airplanes, but not LSA. I know, you can't have everything, but I can still want it! :D
Andy Walker
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby MrMorden » Mon Nov 18, 2013 10:51 am

dstclair wrote:Andy,

There is no restriction against a LSA manufacturer getting a current S-LSA design certified under the new Part 23 rules. There are probably more costs involved than ASTM but could open other markets like the oft bemoaned MTOW. I have no idea whether the increased costs would be covered by increased sales.


Since many are already saying LSA are overpriced for what they are and what they do, I think they'd lose sales on that deal with increased compliance costs. Maybe not though if there are some real advantages.
Andy Walker
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2007 Flight Design CTSW E-LSA

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Re: Part 23 Certification Bill Leaving LSA Out?

Postby Merlinspop » Mon Nov 18, 2013 10:56 am

MrMorden wrote:The only way to do that with an LSA is to go experimental, which has some issues (for example, I cannot make my airplane E-LSA because my finance company will not finance experimental aircraft).

I'd like to be able to do much more of my own maintenance without the implications of going experimental. This bill seems to allow that for Part 23 airplanes, but not LSA. I know, you can't have everything, but I can still want it! :D

I thought the 16 hour course (or is it the long one?) gets you certification that will allow you to do all your own mx on an S-LSA?
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drseti
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby drseti » Mon Nov 18, 2013 11:12 am

Merlinspop wrote:I thought the 16 hour course (or is it the long one?) gets you certification that will allow you to do all your own mx on an S-LSA?


Here's my understanding, Bruce:

Anyone can do maintenance (major repair, minor repair, or modification) on any experimental aircraft (either E-AB or ELSA), with no FAA certificate required at all. The 16 hour LSRI course will allow anyone (not just the owner) to do the condition inspection on an ELSA (but not an E-AB -- that still has to be an A&P, or the original builder with a Repairman's Certificate).

To do maintenance or condition inspection on an S-LSA, one must take the 120 hour LSRM course.

<shameless plug>
All of this will be covered in my upcoming EAA Webinar, "LSA Maintenance," on Tuesday night, 26 November, at 8 PM EST. Sign up here for Wings or AMT Award credit: https://www2.gotomeeting.com/register/189238434
</shameless plug>
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby Jack Tyler » Mon Nov 18, 2013 12:21 pm

<shameless plugs> are welcome from you, Paul. You da man!
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby 3Dreaming » Mon Nov 18, 2013 1:17 pm

Paul, the 16 hour course only allows you to work on ELSA aircraft you own of the same type for which you received training.

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Re: Part 23 Certification Bill Leaving LSA Out?

Postby FastEddieB » Mon Nov 18, 2013 5:54 pm

3Dreaming wrote:Paul, the 16 hour course only allows you to work on ELSA aircraft you own of the same type for which you received training.


Yes.

The certificate I got is specific to my N number and Serial No.

But the training was generic - not type-specific.

And it only covers condition inspections, not maintenance, since no certificate is needed to work on an E-LSA.

To work on any S-LSA requires the 120 hour course, as the professor pointed out.

Clear?
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby drseti » Mon Nov 18, 2013 7:42 pm

3Dreaming wrote:Paul, the 16 hour course only allows you to work on ELSA aircraft you own


Tom, I'm not sure that's entirely true. Yes, the LSRI is for one specific aircraft, by N number. But I'm not so certain you have to be the owner. Several schools have built ELSAs, and all the students were able to get LSRIs for it.
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby FastEddieB » Mon Nov 18, 2013 8:34 pm

From the EAA site (bolded mine):

"This rating allows you to conduct the annual condition inspection on an E-LSA you own. It requires the successful completion of an FAA accepted, 16-hour course on the inspection of your particular class of LSA."

http://www.sportpilot.org/maintenance/lsa_maintenance_requirements.html

Not an official source, of course, so let's investigate further.

Anyway, here's mine:

Image

I don't recall if I had to show the FSDO ownership info or not.
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby FastEddieB » Mon Nov 18, 2013 8:37 pm

65.107 (in part):

(b) The holder of a repairman certificate (light-sport aircraft) with an inspection rating may perform the annual condition inspection on a light-sport aircraft:

(1) That is owned by the holder;

(2) That has been issued an experimental certificate for operating a light-sport aircraft under §21.191(i) of this chapter; and

(3) That is in the same class of light-sport-aircraft for which the holder has completed the training specified in paragraph (a)(2)(ii) of this section.
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby drseti » Mon Nov 18, 2013 8:44 pm

Well, Eddie, the FAR seems pretty clear. I wonder how those schools managed to get each of their students an LSRI?
The opinions posted are those of one CFI, and do not necessarily represent the FAA or its lawyers.
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Re: Part 23 Certification Bill Leaving LSA Out?

Postby FastEddieB » Mon Nov 18, 2013 8:48 pm

drseti wrote:I wonder how those schools managed to get each of their students an LSRI?


You've got me.

Image

At least we know it's not lupus.
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