Who can inspect and maintain what types of LSA

[Paul Hamilton]

There is allot of confusion about what types of LSA are out there and who can inspect and maintain what.
Here is a summary of the types and who can inspect/maintain.

S-LSA –certified by FAA accepted ASTM consensus standards
• Annual condition inspection may be performed by:
o LSA Repairman with Maintenance rating (120 hour course)
o A&P or FAA certificated repair station
• 100 hour inspection if used for training, towing, hire or rental may be performed by:
o LSA Repairman with Maintenance rating
o A&P or FAA certificated repair station
• Maintenance*, repair and alterations may be performed by:
o LSA Repairman with Maintenance rating (as authorized by manufacturer)
o A&P or FAA certificated repair station (as authorized by manufacturer)

E-LSA – Ultralights (fat/2 place) transitioned before January 31, 2008 that meet the criteria of 21.191 (i) (1)
• Annual condition inspection may be performed by
o LSA Repairman with Maintenance rating (120 hour course)
o A&P or FAA certificated repair station
o Owner Repairman with Inspection rating (16 hour course)
• Owner can be trained in his/her own aircraft and does not need 100 hour inspection.
• 100 hour inspection if used for training, compensation or hire before January 31, 2010 (towing no end date) may be performed by:
o LSA Repairman with Maintenance rating
o A&P or FAA certificated repair station
• Servicing**, repair and alterations may be performed by:
o Anybody

E-LSA – Manufacturers Kits that meet the criteria of 21.191 (i) (2) (not amateur built)
• Annual condition inspection may be performed by
o LSA Repairman with Maintenance rating (120 hour course)
o A&P or FAA certificated repair station
o LSA Owner Repairman with Inspection rating (owner 16 hour course)
• Owner can be trained in his/her own aircraft and does not need 100 hour inspection
• Servicing**, repair and alterations may be performed by:
o Anybody

E-LSA – Converted from S-LSA that meet the criteria of 21.191 (i) (3)
• Annual condition inspection may be performed by
o LSA Repairman with Maintenance rating (120 hour course)
o A&P or FAA certificated repair station
o LSA Owner Repairman with Inspection rating (owner 16 hour course)
• Owner can be trained in his/her own aircraft and does not need 100 hour inspection
• Servicing**, repair and alterations may be performed by:
o § 43.1 (b) specifies LSA Repairman with Maintenance rating, A&P or FAA certificated repair station (as authorized by manufacturer). NOTE (opinion only): It is anticipated and hoped this 41.1 (b) will change in the near future to exclude LSA and allow anyone to maintain the aircraft similar to other Experimental aircraft.


Amateur built that meet the definition of LSA and criteria of 21.191 (g)
• Annual condition inspection may be performed by
o Original builder gets Repairman certificate for that specific airplane and can perform annual condition inspection:
o If owner was not original builder, Annual condition inspection may be performed by
 A&P or FAA certificated repair station
 Original builder
• Owner can be trained in his/her own aircraft and does not need 100 hour inspection
• Servicing**, repair and alterations may be performed by:
 Anyone


Standard category FAA certified that meet the definition of LSA
• Annual may be performed by:
o A&P with Inspection Authorization (IA) or FAA certificated repair station
• 100 hour inspection if used for training, towing or hire may be performed by:
o A&P or FAA certificated repair station
• Maintenance***, repair and alterations may be performed by:
o A&P or FAA certificated repair station


* Simple “Preventative maintenance” as specified by manufacturer can be done by the owner and operator of a S-LSA with a Sport Pilot or higher certificate.

** Maintenance is a common term but it is not used here because the FAA uses the word “Maintenance” to refer to a specific level of service required by properly trained mechanics.

*** Simple “Preventative maintenance” as specified in FAR Part 43 can be done by the owner and operator of the aircraft with recreational pilot and higher certificate



The following are the Part 21 rules referenced

§ 21.191 Experimental certificates.
Experimental certificates are issued for the following purposes:
(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.
(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.
(c) Crew training. Training of the applicant's flight crews.
(d) Exhibition. Exhibiting the aircraft's flight capabilities, performance, or unusual characteristics at air shows, motion picture, television, and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.
(e) Air racing. Participating in air races, including (for such participants) practicing for such air races and flying to and from racing events.
(f) Market surveys. Use of aircraft for purposes of conducting market surveys, sales demonstrations, and customer crew training only as provided in § 21.195.
(g) Operating amateur built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

{New-2004-17 (h) revised July 27, 2004, effective September 1, 2004. Was "(h) Operating kit-built aircraft."}
(h) Operating primary kit-built aircraft. Operating a primary category aircraft that meets the criteria of § 21.24(a)(1) that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder under § 21.184(a).

{New-2004-17 (i) added July 27, 2004, effective September 1, 2004}
(i) Operating light-sport aircraft. Operating a light-sport aircraft that--
(1) Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of § 103.1 of this chapter. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008;
(2) Has been assembled--
(i) From an aircraft kit for which the applicant can provide the information required by § 21.193(e); and
(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard; or
(3) Has been previously issued a special airworthiness certificate in the light-sport category under § 21.190.



§ 21.193 Experimental certificates: general.
An applicant for an experimental certificate must submit the following information:
(a) A statement, in a form and manner prescribed by the Administrator setting forth the purpose for which the aircraft is to be used.
(b) Enough data (such as photographs) to identify the aircraft.
(c) Upon inspection of the aircraft, any pertinent information found necessary by the Administrator to safeguard the general public.
(d) In the case of an aircraft to be used for experimental purposes -
(1) The purpose of the experiment;
(2) The estimated time or number of flights required for the experiment;
(3) The areas over which the experiment will be conducted; and
(4) Except for aircraft converted from a previously certificated type without appreciable change in the external configuration, three view drawings or three view dimensioned photographs of the aircraft.

{New-2004-17 (e) added July 27, 2004, effective September 1, 2004}
(e) In the case of a light-sport aircraft assembled from a kit to be certificated in accordance with § 21.191(i)(2), an applicant must provide the following:
(1) Evidence that an aircraft of the same make and model was manufactured and assembled by the aircraft kit manufacturer and issued a special airworthiness certificate in the light-sport category.
(2) The aircraft's operating instructions.
(3) The aircraft's maintenance and inspection procedures.
(4) The manufacturer's statement of compliance for the aircraft kit used in the aircraft assembly that meets § 21.190(c), except that instead of meeting § 21.190(c)(7), the statement must identify assembly instructions for the aircraft that meet an applicable consensus standard.
(5) The aircraft's flight training supplement.
(6) In addition to paragraphs (e)(1) through (e)(5) of this section, for an aircraft kit manufactured outside of the United States, evidence that the aircraft kit was manufactured in a country with which the United States has a Bilateral Airworthiness Agreement concerning airplanes or a Bilateral Aviation Safety Agreement with associated Implementation Procedures for Airworthiness concerning airplanes, or an equivalent airworthiness agreement.

[garyo1939]

Hi Paul,

Just wondering how the new requirement from Rotax will affect the 16 and 120 hr students and the courses they have already taken. Will any work or inspection of the Rotax engines need special training now in addition to the 2 week course's?

Thanks,

Gary
N181RL

[Paul Hamilton]

The new ROTAX requirement is in addition to the 16 hour and 120 hour repairman courses. I was suprised that they do not learn that much about the ROTAX specificly in the courses.