What is needed by “us the owner” to change the operating limitations? Do I need any specific information to give to the fisdo or will they be able to look everything up via my N number? I’d like to get whatever I need ready so when I get the return email or call I can give it to them.
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MOSAIC LSRI course completed
- Thread starter FinnFlyer
- Start date
I finally got my LSRI today. After waiting over a month just to have the Atlanta FSDO cancel (and not allow me to reschedule), I decided to try another FSDO. I called Birmingham first. They were really nice, but ultimately wouldn't help since I live in Georgia. Next I tried Nashville. Emailed them late Thursday, got a reply Friday, and had a virtual appointment Monday afternoon! It's amazing how drastically different the experience with the FAA can be when you get a hold of the right people.
You would think that would be easy. I’m now discussing this with my FSDO and I’m educating them on how and what needs to be changed in my Ops limits. They don’t seem to know how to do it just yet. Other than asking me what do I want to change in my Ops limits when I told them I want 8130.2L #18…
You will need to apply for an amended Airworthiness and Op Lims.
For example, I’m trying to explain to them that #10 on my current ops limits is not sufficient even though they are saying it is. They are now checking with management. They said if everyone needs to change this in their ops limits that they may not have the capacity to support this for all. Haha… that’s a funny.
I understand the ops limitation change but why a new airworthiness?
Did you take the LSRI repairman course?
I'm fairly sure that it would cover the fact that the operating limits are part of the AWC.
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Because your Op Lims are a part of the Airworthiness Certificate. If you have the older "Pink" Airworthiness, your Op Lims are referenced on it.
And the issue date will change to the current date preceded by "A".
Thanks Mel... My question wasn't clear. I know the OPs are part of the Airworthiness Certificate. My question should have been is anything changing on the Airworthiness Certificate itself. Yes mine is older style Pink one on the RV10 and it references the Ops Limitations. Both are combined in the same document now, that is how it's been for my last 2 builds.
Yes I did take the course. I was really just interested in what changes specific to the AC portion.
I have an appointment next week with the local FISDO
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As Mel said, the pink Airworthiness references the Ops Lims “Dated XX/XX/XXX” (or should, if it was done correctly…), so since you’ll get NEW Ops Limes with a NEW date, the previous AWC would now be in error - hence, a new AWC for any Ops Lims change.
Resubmitting my AWC amendment application on the AWC portal.
Table B-2 of 8130.2L requires FAA Form 8100-1 attached. Would seem to be an error in the table (Experimental -- Amateur-Built line) but how do I convince the inspector that he doesn't have to forward that to the registry?
Or do I simply fill it out with data from condition inspection -- one line for whole aircraft?
Edit: And where can I find a copy of the original 8130-12? Is there some way I can access FAA Registry documents?
Table B-2 of 8130.2L requires FAA Form 8100-1 attached. Would seem to be an error in the table (Experimental -- Amateur-Built line) but how do I convince the inspector that he doesn't have to forward that to the registry?
Or do I simply fill it out with data from condition inspection -- one line for whole aircraft?
Edit: And where can I find a copy of the original 8130-12? Is there some way I can access FAA Registry documents?
You will need to fill out an AWC application requesting an amended certificate. Then include a new program letter requesting the change to your operating limitations #18. If your test area is not your home airport I would suggest you change that also while they are making changes.
No! With "replacement" the op lims must be exactly the same as the ones being replaced. To change any part, an amended is required.
I'm sorry but if that's what she said, she was mistaken. Below quote is taken directly from Order 8130.2L.
c.Replacement.(1)Eligibility. The FAA may issue a replacement airworthiness certificate when acertificate is declared lost, has been mutilated, is no longer legible, or contains inaccurate and/or erroneous information or when the aircraft registration number has changed. If the “inaccurate and/or erroneous information” was a result of errors induced or not detected by the assigned inspector (or designee) within 6 months of the most recently submitted airworthiness file, the inspector (or designee) should make the necessary corrections and resubmit the certification file to the Registry. If the “inaccurate and/or erroneous information” was detected within 6 months of the most recently submitted airworthiness file, the assigned inspector (or designee) should direct the applicant to create a new application for a replacement airworthiness certificate to correct the error(s). When issuing a replacement special airworthiness certificate, the operating limitations issued with the original airworthiness certificate must be issued with the replacement special airworthiness certificate, or an amended application should be created.
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So, is it correct to say -- the pink AWC remains unchanged, while your separate operating limitations document, which accompanies the pink AWC, gets replaced by an updated operating limitation document that has the addition of "a light-sport repairman certified under 65.107 (in accordance with their privileges under 65.109)" in line item No. #18 of your new operating limitation document?
No. You will receive a new Airworthiness Certificate with Op Lims attached. The old certificate will be returned to Oklahoma City.
The pink AWC will be returned to Oklahoma City by the inspector.
I don't know how to be any clearer, the pink AWC will be marked "VOID" and returned to FAA Registration.
Okay -- you didn't answer my question Mel.
So, then does this happen after you issue a completely new AWC (both pink and Ops Lims document) or after it's marked "void" and sent back to Oklahoma City? And, does the date of issuance on this new pink copy show a new date of issuance, becoming a completely new AWC? Seems like very important questions.
I believe this has been covered. A new A/W certificate is issued and the old one is marked VOID and returned to FAA Registration. You cannot hold 2 AWC for the same aircraft. The new certificate will have the current date preceded by an "A" to show that it is an amended certificate.
That seems right to me.
It looks to me that we will indeed be asking for an amended airworthiness certificate, and that we are eligible for that because we seek a "change in the operating limitations for an aircraft with a special airworthiness certificate." 8130.2L 2-4.a(1)(C).
2-4 tells us that the procedure for doing this is set forth in 8130.2L 2-3, except (a) "A complete review of aircraft records perparagraph 2-3.e of this order is not required. Review aircraft records as necessary in consideration of the reason for the amendment" and (b) "A complete aircraft inspection per paragraph 2-3.f of thisorder is not required. Inspect the aircraft as necessary in consideration of the reason for the amendment." 2.4.a(2)(a)-(b). Moreover, "all operating limitations must be issued per the current version of this order; Appendix D, Table D-1." Note that the current version of Table D-1 has the language we (allegedly...) must have.
Okay, so now let's see what 2-3 requires, keeping in mind that we are already off the hook somewhat with respect to 2-3.e and 2-3.f.
The FAA helpfully gives us a flow chart for 2-3:
We're going to need an application: "A properly completed FAA Form 8130-6, Application for U.S. AirworthinessCertificate, is required to begin the process of issuing an airworthiness certificate." 2-3.b(1).
Then the person who is going to issue the certificate (I'll call that person the "issuer") has to "Access the Registry to verify that the aircraft is currently registered per 14 CFR Part 47." 2-3.c(1).
The issuer also must "check the Electronic Document RetrievalSystem (EDRS), the Civil Aviation Registry Electronic Service (CARES), or order a copy of the aircraft record to determine if the FAA previously issued a denial for this aircraft." 2-3c(2).
The issuer must then "Identify Potential Safety Hazards." 2-3(d). This means the issuer must "Review available information as necessary to familiarize you with the aircraft, aircraft engine, propeller models, and potential safety hazards. For example, review information as applicable and necessary to understand the manufacturer/builder; configuration; installed equipment; novel or unique features, characteristics, or systems; recent customer findings for new aircraft deliveries; recent quality escapes for new aircraft; histories of service difficulties, incidents, and accidents; ownership history of the aircraft; and potential for degradation from long-term storage. Designees should review the designee alert system for any pertinent information."
With any luck the "as necessary" language here will let the issuer largely skip this part if all they are doing is updating op lims to permit LSRI LSRM inspections, but who knows what a zealous bureaucrat might make of this command.
Now we're on to 2-3.e, so per 2-4 the issuer must only review aircraft records "as necessary."
Same with 2-3.f, per 2-4 the issuer must only inspect "as necessary"
Now the issuer must "Document all completed reviews and inspections on FAA Form 8100-1, per the instructions on the form. Verify that the applicant corrects all unsatisfactory findings and document those corrections on FAA Form 8100-1 before issuing an airworthiness certificate." 2-3.g.
Next the issuer should issue the certificate (assuming it's not being denied). But note that the issuer must first "find the aircraft airworthy"!! Seems like a silly requirement for this type of amendment, but rules are rules, and I see no exemption. Who knows what, if anything, that will entail. Looks like they can send it to you by e-mail, so that's a plus.
Finally, the issuer has to review and forward certification files "per Appendix B." 2-3.j. Reviewing Appendix B makes me glad I don't do this for a living.
Easy peasy!!
That makes too much sense.
I was on the FAA AWC web site todayand could not figure out how to navigate to request an update to my Operating Limitations. Has anyone. Successfully navigated it and is willing to walk me through it via an online meeting.
I think from what Mel is saying, you would need to apply for an appended AWC, which appears to require completing FAA Form 8130-6 (Application for U.S. Airworthiness Certificate). You then receive a brand new "pink copy" AWC and new operating limits document, and the old AWC is marked as "VOID" and sent back to Oklahoma City. The new AWC will have the new date of issue, with an "A" to designate that it's an amended AWC.
I was able to do what I was told was required. I did not do it the way Mel said. I do not think anyone has successfully completed the full process yet.
Thanks. That clarifies it for me. I don't have to do that form, the FAA inspector does and submits it to FAA Registry with the rest of the docs.
As for the Repairman cert, I got this today from Tampa FSDO:
"We do not do these type appointments via Zoom. It requires in person appointment due to wet ink signature requirements."
Shows you how each FSDO is different. Waiting for call from inspector when assigned, to set the appointment.
"Thank you for your appointment request. We will process it for assignment to an inspector who will reach out to you and schedule a date/time based on their availability."
Don't know if succesful yet, but:
Select application for Amended AWC.
When you have gone through the steps and gotten to the "Documents" tab, you select "Document type", select the file from your computer and add.
(On some of them you are required to add a comment first)
You'll need scans, PDF files or pictures of:
Registration
Current AWC
Current Oplims
Your program letter (explain why you want an amended AWC, 8130.2L No. 18 in Appendix D table.)
8130-6 filled in and signed
3D drawing from your build manual.
...
See table B-2 in 8130.2L (pages B-3 thru B6), lines Experimental -- Amateur-Built -- the columns that have "R" in them (but as applicable).
I guess it would be cool if someone here were able to do a youtube video of it, but the above should get you started.
Edit (again): I suspect it will vary by FAA inspector how many of the documents he'll require you to have uploaded. You could say that he's probably able to look up everything except the new program letter and new 8130-6, but elsewhere in the instructions it says the applicant must submit all required documentation and the inspector is just to verify them.
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Thanks. I may try to generate a video. Please let me know your status as it progresses.
I just received my new AWC as well as the new operating limitations this morning. I have been working with my local fesdo and the guy I was working with was very helpful.
I thought the wording would be a little different saying LSRI able to do the inspection.
Does this look correct?
Section 9.
I thought the wording would be a little different saying LSRI able to do the inspection.
Does this look correct?
Section 9.
Attachments
Nope. Op Lim #(18) should read: . An experimental aircraft builder certificated as a repairman for this aircraft under §65.104, a light-sport repairman certificated under §65.107 (in accordance with their certificate privileges under §65.109), an appropriately rated FAA-certificated mechanic, or an appropriately rated FAA certificated repair station may perform the condition inspection required by these operating limitations. (18)
This is IAW the new Order 8130.2L. Airworthiness issued after 01/30/2026 should be issued under the new Order.
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Also I notice that Op Lim #13 should be there. This is the limit prohibiting "Towing" and "Parachute jumping".
Your inspector needs to read up on 8130.2L.
Mel - is there a good template for typical experimental Ops Limits?
Mine are over 23 years old (and were issued to the original builder).
Will we need to submit a proposed draft of the new Ops Limits (I need to change my description of the test area, as well as add the new #18 verbiage allowing LSRI Condition Inspection)? Or is that something that the FSDO will (should?) do?
And, while I’m asking- is there a typical format and content for a program letter for submitting a request for an amended AWC to add #18?
I suspect there’s a lot of us about to do that.
FAA Order 8130.2L, Table D-1 lists all Operating Limitations. Each limitation shows its' application. For amateur-built you are looking for §21.191(g).
Not real easy to muddle through. Typically amateur-built uses limitations # 1-5, 7, 11, 13, 15, 18, 20, 22, 25, 38, 39, 41-49, 53.
Forgive me if I missed 1 or 2.
Does anyone know where or how to get a 8100-1 Conformity Inspection Record for this Amended AW? I have Amended an AW with a DAR in the past and I never had to provide this form. The FSDO I’m working with is actually helping and I’ve got to the point where I’m submitting the required docs in FAA AWC but the office said I must submit everyone marked “R” on the 8130.2L Appendix B table B-2 for the “Amended” column. I emailed them asking this question too. I’ll report back what I find out.
You don’t provide it (the 8100-1) - the inspector or DAR who issues the new AWC fills it out. It’s sort of a worksheet that we fill out to make sure we have checked all the boxes in the process.
In regards to what they are asking…..different FSDO’s, different Inspectors…and something that they rarely do (E-AB) in their daily pile of work…..
Mconner7
Well Known Member
I got the LSRI rating today from the Tampa FSDO.
They would not work with me on the Ops limits even though I was sure I had all of the paperwork in hand. They said I would have to log onto the AWC portal and then it would be assigned to an inspector. I spent the afternoon trying to muddle through the portal and gave up. I will call them tomorrow for some help with the AWC process.
They would not work with me on the Ops limits even though I was sure I had all of the paperwork in hand. They said I would have to log onto the AWC portal and then it would be assigned to an inspector. I spent the afternoon trying to muddle through the portal and gave up. I will call them tomorrow for some help with the AWC process.
The document upload is the hardest part. They want everything marked “R” in the 8130.2L Appendix B table B-2 for the “Amended” column.
The rest is simple. At the very end you pick your FSDO region and office and click submit.
This was covered in posts #82 and 86 above.
