A Heavy Dose of Light-Sport

An inside look at light-sport aircraft maintenance responsibilities

SLSA maintenance requirements: Mary Micrometer owns a small flight training school using airplane-class SLSA aircraft. She also employs two mechanics. Rusty holds a light-sport repairman certificate with a maintenance rating. Tim holds a light sport-repairman certificate with an inspection rating and is taking the 80-hour training course for a maintenance rating (glider class). Rusty delegates the responsibility for performing a 100-hour inspection of the flight school’s airplane-class SLSA to Tim so that it can be used later that day for a training flight.

Is Tim legal to carry out this task without a completed maintenance rating on his repairman certificate? Or, will he need to first complete his 80-hour course?

No, on both counts. Tim has a light-sport repairman certificate with an airplane class inspection rating and can perform an annual condition inspection on an aircraft owned by him, but he is not authorized to perform the 100-hour required by 14 CFR section 91.327. The 100-hour inspection requires a repairman certificate with maintenance rating. Although Tim has almost completed his 80-hour course for a maintenance rating, it is for glider class, which means that completing the course would still not authorize him to perform the 100-hour inspection on an airplane-class light-sport aircraft.

Airframe and Powerplant rating privileges: Using the same SLSA flight school above, Mary hires an A&P-rated mechanic, Stan, who has just begun training for a light-sport repairman certificate. Rusty asks Stan to replace a propeller on one of the school’s SLSA aircraft and return the aircraft to service. The propeller is not an FAA-approved part nor is the installation an FAA-approved procedure. Is Stan legal to perform this task?

Yes. An A&P rated mechanic can approve and return to service an airframe/powerplant/propeller, or any related part or appliance, of an SLSA aircraft after performing and inspecting a major repair or major alteration. This approval authority also extends to products that are not produced under an FAA approval, provided the work was performed under instructions developed by the manufacturer or a person acceptable to the FAA (see 14 CFR sections 65.85 and 65.87).

Safety directive compliance: Continuing with the same SLSA flight school example: Mary has received several safety directives (SDs) from the manufacturer of the flight school’s SLSA fleet. Mary realizes performing the work required by these SDs will significantly affect the peak summer season of flight training. Since the SDs are not FAA-issued, Mary plans to delay taking action until the fall, well past the established compliance date. Can Mary still operate the aircraft in her fleet?

Yes and no. Noncompliance with a manufacturer-issued SD will prohibit Mary from using the aircraft under SLSA airworthiness certificates. However, Mary can opt to surrender the SLSA airworthiness certificates to FAA and apply for ELSA airworthiness certificates instead. If approved, the aircraft can still be flown — but a consequence of flying them under ELSA operating limitations is that they can no longer be used for hire or for training.

Please note that Mary does have some options for complying with the SD. According to 14 CFR section 91.327(a) (4), she can:
(A) Correct the unsafe condition in a manner different from that specified in the SD provided the person issuing the directive concurs with the action; or
(B) Obtain an FAA waiver from the provisions of the SD based on a conclusion that the SD was issued without adhering to the applicable consensus standard.

Major repairs/alterations: Tommy Torque owns a weight-shift control SLSA aircraft with a type-certificated (TC) engine. He is a certificated light-sport repairman and has completed the 104-hour training course to receive a weight-shift control class maintenance rating. Tommy wants to install a new oil filter, for which there is a supplemental type certificate (STC). He installs the filter per the manufacturer’s procedures, notes the procedure in the logbook, but does not complete a Form 337. Is Tommy following proper procedures?

No. First, even though there is an STC to install a filter on a TC engine, Tommy must submit a request to the aircraft manufacturer for installation approval on that particular aircraft. Once approved and the procedure is completed, it must also be recorded on a Form 337 since it is an FAA-approved part. The ASTM data approved by the SLSA manufacturer for major repairs and alteration is FAA-accepted data and is required to be recorded in the aircraft records according to ASTM F 2483-05, section 9, 1-4. If it had been a non-FAA-approved part, a Form 337 would not be required.

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