J

Jack Tyler

Well Known Member
My wife & I have been off sailing, during which time the LSA class of aircraft was created. We're now re-entering aviation and considering an RV-12 to replace our previous Grumman AA-5. I've been climbing the learning curve on LSA's and on the ASTM standards which define them, and my understanding of the 'groundrules' which define their use is summarized below. I'm posting them here for a 'sanity check' from you -12 builders/owners, in part because I haven't found any 100% agreement from local builders and experimental a/c pilots on what's below. However, after a fair bit of digging I think all of the following is correct...but please challenge where you disagree:

-- An E-LSA a/c only 'begins life' after its builder first designs and builds the first unit as an S-LSA. This S-LSA a/c must be in compliance with the ASTM standards, and is then inspected and accepted as an 'approved' S-LSA by the FAA.
-- Following this, the builder can either continue to build identical S-LSA a/c and/or build and sell kits that will in turn produce the same a/c as approved. The finished kit would be considered an E-LSA class a/c.
-- When the builder sells an E-LSA kit, the buyer of the kit has two basic choices: The kit could be built 100% to the E-LSA's plans (and the Airworthiness Certificate sought from the FAA would be for the E-LSA class). Alternatively, the kit builder could modify the design and/or deviate from the plans, in which case an E-AB class AC would be sought from the FAA and the a/c would not be considered an LSA class a/c. Instead, it would be 'just another Experimental'.
-- Whether the S-LSA a/c is built abroad and imported (with approval as an LSA a/c being sought from the FAA by its U.S. distributor) or built domestically, all owners of this S-LSA are not allowed to make any subsequent modifications to the hull, engine or permanently installed equipment without approval from the builder, who in turn may well have to seek that approval from the FAA.
-- The home builder of the E-LSA kit, after AC issuance, can make changes to the a/c as s/he deems desirable without any factory approval - let's use the example of changing the prop on the engine. An annual inspection is required for this E-LSA a/c amd must be completed by a licensed A&P. And this is when it would be determined if any mods (e.g. that new prop) deviated from the ASTM standards and took the a/c out of its AC class.
-- If this same a/c owner completes a 16 hr. LSA Repairman Certificate course (such as http://www.sportair.org/workshops/Repairman (LSA) Inspection-Airplane.html), then the owner can do the annual condition inspection for this (and any other) LSA a/c which s/he owns (even including S-LSA's).

Have I got it about right?

Interestingly, it looks like we end up with a bit of the 'Fox guarding the hen house' when the E-LSA owner both is allowed to decide on adding the new prop and also is allowed to decide that the new prop does not invalidate the AC class. No gripe from me; just an observation.

Jack
 
A few additional comments

I think you are correct with one exception. The 16 hour repairman course allows one to perform the condition inspection on any E-LSA they own but they cannot do the inspection on a factory-built S-LSA (the link you provided specifies this as well). The S-LSA requires an A&P for sign-off (but not an IA like FAA certified aircraft).

One additional comment- as of right now, I think the RV-12 is the only kit being sold in the US that can be built as an E-LSA. Other kits that qualify as LSAs are being sold for E-AB certification instead (e.g. Rans S-19, Zenith, etc.).

Jeff
 
One minor thing you left out is that an S-LSA may be re-certificated as an E-LSA. After that, modifications may be made to the aircraft just like any other experimental.
 
Part of your 3rd point is not entirely correct. You wrote:

Alternatively, the kit builder could modify the design and/or deviate from the plans, in which case an E-AB class AC would be sought from the FAA and the a/c would not be considered an LSA class a/c. Instead, it would be 'just another Experimental'.

If the kit builder registers the completed A/C with Weights and Speeds within the LSA rules, the 'Experimental' aircraft can be flown as an LSA under LSA flight rules. The Sonex is a good example of this.
 
Yes, but No! Terminology!

gpiney said:
If the kit builder registers the completed A/C with Weights and Speeds within the LSA rules, the 'Experimental' aircraft can be flown as an LSA under LSA flight rules. The Sonex is a good example of this.
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As long as the aircraft meets light-sport parameters, the aircraft may be flown by a sport pilot, but it will never be an LSA (Light-Sport Aircraft). Even certified aircraft meeting light-sport parameters can be flown by a sport pilot, but that does not make them an LSA.
 
Jeff,

The S-LSA manufacturer determines the level of certification required to do work on and inspect S-LSA. Most specify an A&P or a Light Sport Repairman with a maintenance rating (LSRM). The LSRM differs fron the 16 hour course in that it requires 120 hours. With a LSRM in the airplane category (LSRM-A), the holder can legally hang out a shingle and do work/inspections on any S-LSA or E-LSA airplane unless specified otherwise by the manufacturer. Might not be the smartest thing to do, depending on the holders experience, but it is legal.

I don't know about E-LSA, but in the case of S-LSA any work not covered in the Maintenance Manual can only be done as approved by the manufacturer to include method, materials and who (they might name the shop, license level, or a person by name) on a case by case basis.
 
Interesting!

How do you manage that?

Our instructors in Oklahoma City tell us that we can re-certificate any S-LSA as an E-LSA under the provisions of 14CFR part 21.191(i)(3).
 
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I'm with Mel. I know of one owner in the CT world who converted his S-LSA CT to E-LSA and I saw where a Sky Arrow owner converted his. This is second hand knowlege on a subject which I know nothing about.
 
LSA

As long as the aircraft meets light-sport parameters, the aircraft may be flown by a sport pilot, but it will never be an LSA (Light-Sport Aircraft).
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Hmm, I thought that any aircraft that meets light-sport parameters IS an LSA. According to the EAA, "The FAA defines a light-sport aircraft as an aircraft, other than a helicopter or powered-lift that, since its original certification, has continued to meet the following:"
See http://www.sportpilot.org/learn/final_rule_synopsis.html
Perhaps you were thinking S-LSA?
There are no aircraft registered as LSA. Aircraft can be registered as S-LSA, E-LSA, E-AB, type certificated, and etc. No matter how an aircraft is registered, if it meets the above parameters, it is an LSA and can be flown by a sport pilot. Let me know if I have this wrong.
Joe
 
I stand corrected!

It does seem that 14CFR part 1.1 does indeed define light-sport compliant aircraft as LSA.

S-LSA are certificated as "Light-Sport" category. E-LSA are certificated as "Experimental" category.
 
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Mel said:
How do you manage that?

Our instructors in Oklahoma City tell us that we can re-certificate any S-LSA as an E-LSA under the provisions of 14CFR part 21.191(i)(3).
Click to expand...

After reading the reg that Mel mentions, I have to admit it sounds pretty clear cut to me...I should be able to request an experimental certificate for a previously issued SLSA. Learn something new everyday. I have always believed as the salesmen and manufacturers insist....that an LOA could be issued but no way could it be made experimental. Haven't found one that matches up with the RV12 yet...but it could happen. And of course, it will be out of my price range. It would be fun to work on an experimental Skycatcher though...lol.
 
An interesting exercise...

...and it obviously served a purpose. From the sidelines, I find it interesting that a class of aircraft has now existed for 5+ years and yet a dialogue is needed among an informed pilot community like you folks to have common agreement on LSA definitions and options. This was exactly the same experience I had recently (altho' without the apparent agreement) when I raised this question to some Experimental builders/pilots.

I'll add the relevant additions/corrections discussed above, try to focus on the E-LSA category since that's our interest here, and restate what I 'think' we now all agree on. (Perhaps this will be useful to others in the future).

-- An E-LSA a/c only 'begins life' after its builder first designs and builds the first unit as an S-LSA. This S-LSA a/c must be in compliance with the ASTM standards, and is then inspected and accepted as an 'approved' S-LSA by the FAA.
-- Following this, the builder can either continue to build identical S-LSA a/c and/or build and sell kits that will in turn produce the same a/c as approved. The finished kit would be considered an E-LSA class a/c. (NB: S-LSA's are certificated as "Light-Sport" category. E-LSA are certificated as "Experimental" category).
-- When the builder sells an E-LSA kit, the buyer of the kit has two basic choices: The kit could be built 100% to the E-LSA's plans and an Airworthiness Certificate (AC) sought from the FAA that would be for the E-LSA class. Alternatively, the kit builder could modify the design and/or deviate from the plans, in which case an E-AB class AC would be sought from the FAA. If the kit builder registers the completed a/c with weights and speeds within the LSA rules, this 'Experimental' aircraft can then be flown under LSA flight rules.
-- Whether the S-LSA a/c is built abroad and imported (with approval as an S-LSA a/c being sought from the FAA by its U.S. distributor) or built domestically, so long as the a/c remains an S-LSA the owner is not allowed to make any subsequent modifications to the hull, engine or permanently installed equipment without approval from the builder.
-- However, an S-LSA may be re-certificated as an E-LSA. After that, modifications may be made to the a/c just like any other experimental.
-- The home builder of the E-LSA kit, after AC issuance, can make changes to the a/c as s/he deems desirable without any factory approval - let's use the example of changing the prop on the engine. An annual inspection is required for this E-LSA a/c and would be completed by a licensed A&P. And this is when it would be determined if any mods (such as that new prop) deviated from the ASTM standards and took the a/c out of its AC class.
-- If this same a/c owner completes a 16 hr. LSA Repairman Certificate course (such as http://www.sportair.org/workshops/Re...-Airplane.html), then the owner can do the annual condition inspection for this (and any other) E-LSA a/c which s/he owns. (In the case of S-LSA a/c, its manufacturer determines the level of certification required to do work on and inspect that a/c).

Again, corrections/additions welcome if needed - and thanks to everyone for helping me frame this out fully. Special thanks to Mel, who's PM-coached me a couple of times on this and is no doubt tired of the topic by now.:)

Jack
 
Hey, I seldom tire of talking airplanes. The more I talk and listen, the more I learn. On the Light-Sport scene, much of the misunderstanding is caused by the misuse of terms.
I talk with the guys in Oklahoma City quite often to keep up with everything.
 
E-LSA

Jack,
What you posted is basically correct, although you do not use the same terminology as the FAA. Only a lawyer can do that. :D
An annual inspection is required for this E-LSA a/c and would be completed by a licensed A&P. And this is when it would be determined if any mods (such as that new prop) deviated from the ASTM standards and took the a/c out of its AC class.
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Actually the home-builder or pilot determines if the aircraft meets LSA requirements. If you install a constant speed prop or retractable landing gear, then it is obviously no longer an LSA. But if you make other more subtle changes like reducing drag or increasing HP so that the aircraft cruises faster than the speed limit, it is not the A&P's responsibility to determine if the aircraft meets the LSA parameters. Only the pilot could make that determination by test flying the aircraft.
Joe
 
Joe:

Perhaps subtle changes might not be recognized by the A&P, but in researching this summary one of my resources was the Tech Counselor group at AOPA. Their view is that the A&P's responsibilities, when doing the annual inspection, includes determining if the aircraft is being kept in class, and their sign-off implicitly confirms this (even if not overtly stated). Seems a reasonable conclusion to me, altho' this isn't mutually exclusive with your point.

Jack
 
I stand corrected!

I was wrong to say that it is not the A&P's responsibility to determine if the aircraft meets the LSA parameters. I do not know what their responsibility is besides making sure the aircraft is airworthy.
Joe
 
All that Mel stated is correct. So I am just clarifying everything said. ANY aircraft may be operated under the LSA rules if it meets the definition of a light-sport aircraft under FAR 1. The only exception to this rule is any aircraft that at some time in its life was modified to the extent that it was out of LSA parameters. Even if it is re-modified to now meet LSA standards it may not be flown under LSA rules. This goes for any aircraft under any category.

SLSA aircraft may only be worked on per the aircraft maintenance manual and inspected by a Repairman with a maintenance rating or higher. No modifications are allowed without the manufacturer's permission.

An SLAS may be convert to an ELSA at which time ELSA rules apply.

AN ELSA (after certification) may be worked on by anyone and modified as desired without the manufacturer's permission. The owner, licensed as a repairman with an inspection rating, may conduct the yearly condition inspection.

An ELSA kit, such as Van's RV-12, MUST be built exactly according to the plans unless you have an authorization to deviate from the manufacturer. If you want to deviate from the plans without the manf. authorization then it MUST meet the Amateur-Built rules (51%) but could be operated under the LSA rules if it met those rules under FAR 1 at the time of initial certification.

If anyone has any questions on this, as the rules can be complicate, please feelfree to drop me a line at [email protected].
 
Further clarification...

mrobert569 said:
AN ELSA (after certification) may be worked on by anyone and modified as desired without the manufacturer's permission. The owner, licensed as a repairman with an inspection rating, may conduct the yearly condition inspection.
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If any mod made to an E-LSA removes the aircraft from the LSA definition (part 1.1), then the airworthiness certificate becomes invalid. And the aircraft is not eligible for re-certification
 
Not specifically mentioned, but an A&P rating allows one to work on any of them, to include condition inspections.
 
As far as I know, solely having an A&P does not authorize that person to work on a S-LSA. The manufacturer has to specify who can work on it. That was a problem with some manufacturers at one time and they had to make modifications to their manuals to allow A&P's to work on them.

Also, if the task to be done is not listed in the S-LSA manual, then nobody can perform the task without the manufacturer approval which may include method, materials and who. In cases like this, even if the A&P routinely does similar tasks on a C-182 or other "normally" certified airplane, they need manufactures approval before they can legally do that work on a S-LSA.. This may not seem logical, fair or correct but S-LSA are "different" in this respect.
 
John is correct. The mechanic must have whatever credentials the manufacturer requires. Most approve an A&P for just about everything.

One fairly common exception is that some require the A&P to have specific Rotax training in order to perform maintenance on the 912 installed in their aircraft.

I think the main point of discussion is that an IA is not required for any light-sport aircraft inspections.
 
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It can get confusing. Somewhere a ways back, I THOUGHT I understood that I could not work on a Rotax unless I did some Rotax training. My recollection was that restriction applied to EAB or ELSA as well. Not sure about that now, and does that restriction also apply to condition inspections?. I find this all interesting, I have not yet definitely decided to make my RV12 EAB or ELSA.
 
On an amateur-built, you are the manufacturer. No one can restrict who can do maintenance. The only consequence could be that Rotax might void your warranty.

An S-LSA is not experimental. It's "Light-Sport Category". The manufacturer can incorporate whatever restrictions he likes.
 
mrobert569 said:
All that Mel stated is correct. So I am just clarifying everything said. ANY aircraft may be operated under the LSA rules if it meets the definition of a light-sport aircraft under FAR 1. The only exception to this rule is any aircraft that at some time in its life was modified to the extent that it was out of LSA parameters. Even if it is re-modified to now meet LSA standards it may not be flown under LSA rules. This goes for any aircraft under any category.

SLSA aircraft may only be worked on per the aircraft maintenance manual and inspected by a Repairman with a maintenance rating or higher. No modifications are allowed without the manufacturer's permission.

An SLAS may be convert to an ELSA at which time ELSA rules apply.

AN ELSA (after certification) may be worked on by anyone and modified as desired without the manufacturer's permission. The owner, licensed as a repairman with an inspection rating, may conduct the yearly condition inspection.

An ELSA kit, such as Van's RV-12, MUST be built exactly according to the plans unless you have an authorization to deviate from the manufacturer. If you want to deviate from the plans without the manf. authorization then it MUST meet the Amateur-Built rules (51%) but could be operated under the LSA rules if it met those rules under FAR 1 at the time of initial certification.

If anyone has any questions on this, as the rules can be complicate, please feelfree to drop me a line at [email protected].
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Clarification please? First I read that if the builder/owner completes a 16 hr. LSA Repairman Certificate course (such as http://www.sportair.org/workshops/Re...-Airplane.html), then the owner can do the annual condition inspection for his/her E-LSA. Then Mike (from the FAA) stipulates "The owner, licensed as a repairman with an inspection rating, may conduct the yearly condition inspection."
Does one get the "repairman license WITH INSPECTION RATING" from the 16 hr LSA Repairman Course???? Was not aware that there was an "Inspection Rating" required to do one's own Annual on an E-LSA which we built if we had the repairman license ???????
 
YES!

Dpellet100 said:
Does one get the "repairman license WITH INSPECTION RATING" from the 16 hr LSA Repairman Course???? Was not aware that there was an "Inspection Rating" required to do one's own Annual on an E-LSA which we built if we had the repairman license ???????
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Passing the 16 hr course gets you the repairman certificate with inspection rating. This allows you to sign off your annual condition inspection.
Passing the 120 hr course (fixed wing) gets you the repairman certificate with maintenance rating. This allows you to sign off maintenance and 100 hr inspections for S-LSAs.
Since the 100 hr is only required for commercial operations, it is not required for E-LSA.
 
One thing to keep in mind is your Rotax warranty. When you have a problem (I lost a $1000 ignition module) they do want to see a copy of your logbook and proof that you performed all of the Rotax recommended inspections up to that point. Not required as an ELSA but certainly important during your warranty timeframe.
 
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