A bit of help regarding maintenance

[chacalextreme]

Hi there!

I'm knocking the door here to see if someone can help me a bit. I'm helping to modify some regulations regarding maintenance for LSA in my country, working with the local aviation authorities, and we are trying to follow FAA regulations as much as we can. My intent is to help to make the regulations safer, but at the same time open enough so it is accessible for almost anyone and avoids LSA extinction. I know this may sound weird or even funny, but in my country there are less than 100 LSA operating, and no EAA or such... We have made good progress defining experimentals, E-LSA and S-LSA categories basically as they are defined by the FAA, but I'm having issues finding some information:

1) If you decide to build a E-LSA kit or experimental, do you need any previous training/experience? If so, where you get that training and what it includes?

2) Do you need any authorization from the FAA to start your project? how often do they inspect progress and who does it? (which is the experience of the inspector?)

3) For your LSRI and your LSRM ratings, do you only need to take the trainings, or do you also need to show previous experience in aviation?


I have been digging through the FAA FAR's but I haven't found this info so far... If anyone can point me in the right direction I will really appreciate it.

Thanks in advance for all your help, these forums are great!!

Best regards,

Chacalextreme.

[DaleB]

1) If you decide to build a E-LSA kit or experimental, do you need any previous training/experience? If so, where you get that training and what it includes?
No previous training or experience is required. An inspection is done after construction to determine if the result is airworthy.


2) Do you need any authorization from the FAA to start your project? how often do they inspect progress and who does it? (which is the experience of the inspector?)
No prior approval is required. There is currently no requirement or provision for in-progress inspections in the USA, although I believe Canada requires inspection before "closing up" an assembly like a wing. A smart builder will get an EAA technical counselor to inspect from time to time, but it's not a requirement and any such inspection is not "official".


3) For your LSRI and your LSRM ratings, do you only need to take the trainings, or do you also need to show previous experience in aviation?
Just the training. I took the two-day LSRI class and got my repairman certificate without any further required training or examination. The LSRI class only teaches inspection, not maintenance, and much of it is by reference to FAA publications such as AC 43.13.

I believe the regulations have been loosened significantly over the years. I have heard that the FAA used to require periodic inspections during construction, but that was long ago. Now you are free to build whatever you want -- but it must pass FAA inspection before beling allowed to fly, and you have a "Phase I" test period when you're required to stay within a specified area (avoiding densely populated areas) while you do your flight testing. That's normally 40 hours for an Experimental - Amateur Built, but can be as little as 5 hours for E-LSA built from a kit, exactly per manufacturer's instructions.

[FlyingRon]

Dale is right. Just to add while training isn't required, you may find it advantageous to take some classes for certain skills (welding, fabric, composites, etc...) if such is required for your build or at least practice on something other than your airframe first.

Also, since there are no longer pre-closing or other inspections REQUIRED, you can still have someone who is knowledgeable look at your build as you go along which may save you some grief later. (This is the point of the EAA tech counsellor program, but even another builder or a mechanic with experience with homebuilts would help).

[DaleB]

Oh, absolutely. Training, experience and inspections are not required by regulation, but I would venture to say they are a practical necessity.

[chacalextreme]

Sorry for the delay in response, had a couple of busy days... Awesome info guys, thanks a lot! We are trying to implement at least two ratings for LSA maintenance as well, but I think we may have it backwards, since we are trying to have one for owners who want to maintain their planes, which requires around 120 hours training, and the next level would be inspector which can work commercially with few additional hours of training and can check planes yearly or make major repairs. In your case I think that after 16 hours of training you get an inspector rating for your own plane right? what are you allowed to do with such rating? this is important because a lot of people here have expressed that after building your plane you know it quite well that you could do anything on it, which is not that far off right? that's why our initial training is considering so many hours... Thanks again for your help, this is very valuable for us here.

Best regards,

Chacalextreme.

[Dana]

To avoid confusion, it would be best to clarify the different types:

Experimental - amateur built (E-AB) planes can be scratch built from the builder's original design, purchased plans, or a kit, with no restrictions on design. If a kit or plans, you can modify it any way you want. The only requirement is that the "major portion" (the so-called "51% rule") must be built by an amateur, for "recreation or education". Some of the factory quick build and builder assist programs skirt very close to the "major portion" line. There are few restrictions on the build or maintenance, anybody can build one, anybody can maintain one, no in-process inspections are required (though they were required at one time). Once the complete plane is inspected, there is a test period (usually 25 or 40 hours) before you can carry passengers, fly over populated areas, etc. The primary builder (only) can apply for the "repairman certificate" for that particular plane, which is really just an inspection certificate since anybody can work on it. The annual condition must be done by the holder of the repairman certificate, or a licensed (A&P) mechanic.

Experimental - light sport (E-LSA) are built from an approved kit exactly to plans, or "converted" from a Special Light-Sport (factory built) aircraft. No modifications from the original design are allowed. Being experimental, anybody can work on it, but a light-sport repairman with an "inspection rating" or A&P has to do the annual condition inspection. The owner can take a 16 hour course to get the inspection authorization for any E-LSA he owns (unlike the E-AB repairman certificate that lets him do the inspection on only one particular plane, even if he sells it to somebody else). From what I've heard, the 16 hour course is is much about the paperwork as actually inspecting the plane.

Special light sport are factory built planes. To work on one (or do the annual inspection) you need to take the 120 hour course to get the light-sport repairman with a "maintenance" rating. This allows you to work on other people's planes, too, for pay.

For sake of completeness, I'll mention ultralight vehicles, which are a class unique to the US as far as I know. Single seat only, under 254# empty weight, and some other restrictions... no requirements for maintenance or inspections at all, just some operating restrictions designed to protect other people (no flying over congested areas, etc.)

Consider what you want to achieve with regulation. The idea behind the E-AB and ultralight rules is that you're free to do anything that gets you yourself hurt or killed, as long as you don't hurt anybody else (thus single seat only ultralights and the 40 hour solo test period over sparsely populated areas for E-AB). The light-sport rules are designed to limit the damage you can do (light aircraft, low speeds, only one passenger), but also to limit the skills required due to the low performance.

[chacalextreme]

Thanks a lot Dana, very interesting indeed!!

Seems almost unbelievable that the regulations are so open in the US, and that it has worked well so far! We in fact are trying to follow US rules because they have been proved to work, and not only that, your experimental community is huge and most of the planes that are being imported here come from the US.

Now, a more specific question, how does it work for engines overhaul? you have all kinds of crazy combinations... An airplane model could fit a rotax, a subaru, a corvair, HKS, lycoming, or even a geo metro or chevrolet corvette engine!! when is time to overhaul such engine, who can do it? any need to have a special rating for that? because here we are starting to certify some mechanics in rotax, but seems unrealistic to have factory training for every brand...

[Dana]

Seems almost unbelievable that the regulations are so open in the US, and that it has worked well so far! We in fact are trying to follow US rules because they have been proved to work...

The general attitude here, dating back to the revolution, was traditionally one of self reliance and limited government interference in our daily lives. Sadly, that's changing, but this isn't the place for political discussion...


Now, a more specific question, how does it work for engines overhaul? you have all kinds of crazy combinations... An airplane model could fit a rotax, a subaru, a corvair, HKS, lycoming, or even a geo metro or chevrolet corvette engine!! when is time to overhaul such engine, who can do it? any need to have a special rating for that? because here we are starting to certify some mechanics in rotax, but seems unrealistic to have factory training for every brand...

It depends. For E-AB, for the most part, anything goes. You could power your plane with a twisted rubber band if you wanted to, and anybody can work on any engine. I believe you can get a shorter initial test period if you use a certified aircraft engine, if so then you need a licensed mechanic to work on the engine. SLSA needs a licensed mechanic for aircraft or engine work. I'm not sure what the rules are for E-LSA engines. As for overhauls, pretty much whoever can work on them can legally overhaul them, whether they should is another matter.

[DaleB]

The LSRI certificate is good for one thing and one thing only. It allows you to perform the inspections on an ELSA that you own. Nothing else. You don’t need it perform maintenance, repairs and modifications to an ELSA, because it’s an Experimental - therefore, anyone can do those things.

[Sam Buchanan]

It depends. For E-AB, for the most part, anything goes. You could power your plane with a twisted rubber band if you wanted to, and anybody can work on any engine. I believe you can get a shorter initial test period if you use a certified aircraft engine, if so then you need a licensed mechanic to work on the engine.

Just for clarification, the shorter Phase One test period (25 hrs vs 40 hrs) is available if the engine and prop were originally certificated as a combination. But even if that is the case, anyone can do any maintenance on the engine because there really isn't any such animal as a certificated engine in an aircraft with an experimental airworthiness certificate. An A&P is only needed for the logbook endorsement for the 12-month Condition Inspection.

[chacalextreme]

I understand. So, a couple of quick examples to check if I got it:


Let's say that I buy a Zenith CH750 kit. I can build it at my garage without training, of course following every single detail of the manuals, and getting help from experienced friends or an EAA chapter if possible. I can buy a used rotax 912 or a used continental and overhaul it by myself or with help of any non certified mechanic with enough knowledge , and put it all together. After that, I request an FAA inspection and if everything goes well, I can proceed to test flights and after that regular flights. After that I can continue giving full maintenance to that aircraft during its lifetime, and If I take the 16 hours inspection training I can sign off the logbook every year and that's it. Pretty much no third party should touch that bird ever... I'm I right on that example?




For the experimental case, lets say that I buy a set of plans of a DR109, I could build it at mi garage per the manual, take a lycoming 540 removed from a certified aircraft and overhaul it by myself or with help of someone non certified that knows the stuff, put it all together, get it inspected by the FAA and if everything is right, proceed to the 40 hours test flights, and then I would be ready to go? and after that, I can continue giving maintenance to the aircraft during its lifespan, with annual inspections signed off my me if I made the 16 hours training or by an A&P if I didn't. Of course I know that a project like this is a different animal that could take around 3500 hours of good workmanship, and a pilot with experience flying extras or pitts, but overall, from a legal and technical perspective, that would be the way to do it? right? (I'm using that example because I have here at my country a set of drawings from Todd Ashcraft for that plane, LOL)


Thanks to all of you responding to this thread, I have some good friends and a couple of aviation authorities following along!


Thanks again!!

[Sam Buchanan]

For the experimental case, lets say that I buy a set of plans of a DR109, I could build it at mi garage per the manual, take a lycoming 540 removed from a certified aircraft and overhaul it by myself or with help of someone non certified that knows the stuff, put it all together, get it inspected by the FAA and if everything is right, proceed to the 40 hours test flights, and then I would be ready to go? and after that, I can continue giving maintenance to the aircraft during its lifespan, with annual inspections signed off my me if I made the 16 hours training or by an A&P if I didn't. Of course I know that a project like this is a different animal that could take around 3500 hours of good workmanship, and a pilot with experience flying extras or pitts, but overall, from a legal and technical perspective, that would be the way to do it? right? (I'm using that example because I have here at my country a set of drawings from Todd Ashcraft for that plane, LOL)


Thanks to all of you responding to this thread, I have some good friends and a couple of aviation authorities following along!


Thanks again!!

The 16-hr training course does not apply to maintaining an aircraft with an experimental (E-AB) airworthiness certificate. Airframe and engine maintenance may be performed by anyone but the twelve-month Condition Inspection must be performed by either an A&P or the holder of a Repairman Certificate for that particular aircraft. A Repairman Certificate is customarily obtained by the original builder of the aircraft or the builder who completes the aircraft prior to final inspection by the FAA. This is the case regardless of whether or not the aircraft was constructed from plans or a manufactured kit. Obtaining this certificate does not require a training course, only a demonstration of knowledge of that aircraft during a personal interview with an FAA inspector.

Aircraft that are registered in the ELSA and SLSA categories do require maintenance to be performed by individuals who have received specific training, the 16 hr course being one of those paths. It gets a little more complicated with the ELSA and SLSA aircraft, I suggest you obtain documents from the EAA or FAA for that information. These documents can be found with a bit of time spent on Google.

[chacalextreme]

Excellent Sam, thank you very much for your answers! I will do more research, but now I have a way better understanding of what to look for and what to expect to find. It's great to have the chance to post this questions here, you guys are really willing to help, that is what makes the EAA so awesome. Thanks again!

Best regards,

Chacalextreme

[DaleB]

Aircraft that are registered in the ELSA and SLSA categories do require maintenance to be performed by individuals who have received specific training, the 16 hr course being one of those paths. It gets a little more complicated with the ELSA and SLSA aircraft, I suggest you obtain documents from the EAA or FAA for that information. These documents can be found with a bit of time spent on Google.
I have to disagree with you on a couple of points here.

First, no training or certification is required, at least by regulation, to perform maintenance, repairs or modifications to an E-LSA. It's an experimental. The LSR-I (16 hour course) or an A&P certificate is required only for performing the condition inspection.

Second, the LSR-I training and certificate won't get you anywhere at all with an S-LSA. An A&P or LSR-M (120 hour course) is required for maintenance (other than preventive maintenance allowed by the manufacturer), repairs and alterations as well as inspections on S-LSA.

[Sam Buchanan]

I have to disagree with you on a couple of points here.

First, no training or certification is required, at least by regulation, to perform maintenance, repairs or modifications to an E-LSA. It's an experimental. The LSR-I (16 hour course) or an A&P certificate is required only for performing the condition inspection.

Second, the LSR-I training and certificate won't get you anywhere at all with an S-LSA. An A&P or LSR-M (120 hour course) is required for maintenance (other than preventive maintenance allowed by the manufacturer), repairs and alterations as well as inspections on S-LSA.

We are making the same points, you went into more detail than I. Thank you for the additional info.