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Tracking thread for Op Lim updates and new Light sport certs

R

RNB

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Several of the threads I follow pertaining to Mosaic have gone awry. I'm frustrated hoping and wanting updates on new processes.
Someone recently posted a document from the FAA about them saying new Op Lims are needed.

Please utilize this thread to share actual experiences or new data.
Things needed:
1. FAA Order 8130-2L to replace the K version. Post when updated please.
2. For now there might be anecdotal info about getting Operating Limitations updated. Please share knowledge about this process as you learn. I've looked for info on updating mine, all of the last updated dates for anything close seem to be from September 2024: https://www.faa.gov/aircraft/air_cert/aw_cert/special_aw_certificates. Please share and update when the FAA updates info or releases official processes. If you get yours, share what worked.
3. Light sport certificate holders please share your experience for others so they know how to get inspection and/or maintenance certificate. I expect this will closely follow along with the above #2.

I think that this ought to encompass that which is needed.
 
We are still waiting for FAA Order 8130.2L for the answer to E-AB Operating limitation, but the wording in most E-AB Operating Limitations will likely take precedence and very likely need to be updated to add LSRI to the list of qualified condition inspection types. See News link below for the latest on this.

News

News
www.eaa.org www.eaa.org
 
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Here's a guy, who owns but didn't built a Cozy Mark IV (Scott MacLean of the "Canard Boulevard" channel). He video documented his actual recent experience in taking the two day LSRI course. More interestingly are his observations and FAA experience after taking the two day LSRI course.

 
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I had an appt to get my certificate right after the shutdown ended and the guys at my local FSDO were not aware of the proper procedure and were only minorly aware of the new rules. I sent them the full FAA document that spelled out the changes and they called me the next day to tell me the certificate was good to go, I just need to go back and sign it.

The operating limitations were still an open question when I talked to them just prior to Thanksgiving. The guy I was working with was going to be traveling for a couple weeks and I didn't want to bother him over the holiday. I'll post back if I hear from them.
 
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From another forum, not sure what form this is but


"Got an email from Carol Carpenter today:
The FAA plans to have the guidance and the new form done by the end of this month."
 
This is from the Lancair forum, the admin is currently at the class and supplying some commentary on his forum.

"We expect to obtain the certificates in January but we will have 120-day temporary certificate upon completion of the course and those can also be extended for 120 days until the permanent is supplied. During that temporary certificate period, we will be able to exercise the privileges of the LSRM certificate by signing with certificate "Pending" and the date of temporary issuance. Good to go out of the gate"

This answers one of my big concerns, just need to learn more about Op Lim changes.
 
Another good update from Cozy Mark IV owner, Scott MacLean of the "Canard Boulevard" channel, describing recent FAA guidance document and the need to change Operating Limitations on most EAB's to allow LSRI and LSRM Repairman to perform CI's. Answer appears to be clearly "Yes -- you do".

 
RNB said:
I'm still not seeing anything about updating operating limitations.
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Perhaps they’re rethinking the whole misbegotten endeavor but… I doubt it. 🤣 Probably just bureaucratic delays.
 
Dugaru said:
Perhaps they’re rethinking the whole misbegotten endeavor but… I doubt it. 🤣 Probably just bureaucratic delays.
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It seems like a simple amendment printout would suffice. Could set it up on automatic, or maybe flag some clerk to confirm the experimental aircraft. Prefilled form kind of thing with tail number, serial number, and date being the only blanks to auto fill.
 
RNB said:
It seems like a simple amendment printout would suffice. Could set it up on automatic, or maybe flag some clerk to confirm the experimental aircraft. Prefilled form kind of thing with tail number, serial number, and date being the only blanks to auto fill.
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You would think—and I can actually imagine some real benefits from standardizing the mishmash of op lims out there in this fashion. But they’ve already made this much much harder than it needs to be, so I guess I’ll hope to be pleasantly surprised. 🤣
 
Is anybody hearing any rumors with regards to getting operating limitations updated?
 
RNB said:
Is anybody hearing any rumors with regards to getting operating limitations updated?
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We can't do anything until the new Order is published. I've heard rumors that it will be by the end of the month but I'm not holding my breath!
 
RNB said:
From another forum, not sure what form this is but


"Got an email from Carol Carpenter today:
The FAA plans to have the guidance and the new form done by the end of this month."
Click to expand...
Carol Carpenter manages the Rainbow Aviation Services, Repairman Inspection (LSA) work shop in Kingsville MO.
 
Dugaru said:
You would think—and I can actually imagine some real benefits from standardizing the mishmash of op lims out there in this fashion. But they’ve already made this much much harder than it needs to be, so I guess I’ll hope to be pleasantly surprised. 🤣
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Operating have been "Standardized" since way before I started do them in 1999. The "mishmash" you refer to is Op Lims that were issued not in accordance with the Order. And I think you will find that 95% of those were issued by an FAA ASIs.
 
Mel said:
Operating have been "Standardized" since way before I started do them in 1999. The "mishmash" you refer to is Op Lims that were issued not in accordance with the Order. And I think you will find that 95% of those were issued by an FAA ASIs.
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Interesting - what percentage of the Op Lims out there do you estimate fall into the ASI/mishmash category?

Before we got into the MOSAIC issue, I just assumed they were all pretty much the same.
 
Dugaru said:
Interesting - what percentage of the Op Lims out there do you estimate fall into the ASI/mishmash category?

Before we got into the MOSAIC issue, I just assumed they were all pretty much the same.
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I can’t give you a percentage, but I can tell you that there are some pretty old Ops Lims out there in pretty old airplanes that can provide hours of amusing reading. The original Ops Lims of the original Stits Playboy that became the RV-1 had just seven one-line bullet points…and the seventh was “no smoking in the cockpit in flight”….yeah, they were pretty liberal.

The problem with the “standardized” ones is that there have been many revisions to the “standards - and all of them issued under older standards are still valid until you going asking for something that requires a re-issue (like a change in Phase 1 test area if you’re putting the airplane back in Phase 1). Any Revision to your Ops Lims triggers an upgrade to the latest standards. We are now at version “K” of the standards, so there have been ten(ish) different versions, each amending the previous slightly. As always, YOUR Ops Lims apply to YOUR airplane.
 
Ironflight said:
I can’t give you a percentage, but I can tell you that there are some pretty old Ops Lims out there in pretty old airplanes that can provide hours of amusing reading. The original Ops Lims of the original Stits Playboy that became the RV-1 had just seven one-line bullet points…and the seventh was “no smoking in the cockpit in flight”….yeah, they were pretty liberal.

The problem with the “standardized” ones is that there have been many revisions to the “standards - and all of them issued under older standards are still valid until you going asking for something that requires a re-issue (like a change in Phase 1 test area if you’re putting the airplane back in Phase 1). Any Revision to your Ops Lims triggers an upgrade to the latest standards. We are now at version “K” of the standards, so there have been ten(ish) different versions, each amending the previous slightly. As always, YOUR Ops Lims apply to YOUR airplane.
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Paul’s final line above is very important, and the reason why a lot of the comments people make regarding specific operating limitations details are very often irrelevant or at least incorrect for a specific airplane.
Limitations have changed a lot over the past 30 years that a lot of RV’s have been completed. Some probably still have a limitation that prohibits flight over populated areas except for during takeoff and landing as just one example.
Insider info I got recently indicates that the industry working group has already begun discussions around change recommendations to Order 8130.2M so release of 8130.2L should be coming sometime in the near future, but until it is released ( and assuming it contains direction for issuing a limitation with a different requirement for the certification required to complete an annual condition inspection) the current limitation requirements will still be issued.
 
Brian said Carol checks every hour for 8130.2L. Host suggested it is close. Brain said any time now.
 
RNB said:
Brian said by end of the month or early next month
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Sounds like “end of this month, maybe early next month.”

I’ve been speaking to my local FSDO and I think it will be a painless thing, hopefully that’s true.

Getting my LSRI certificate was a painless transaction.
 
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1. I have been searching for the updated order via a method that it does not show yet. It does show on the dynamic regulatory system DRS

Dynamic Regulatory System

drs.faa.gov drs.faa.gov
Choose the 6th topic on the left, other orders, the orders.
Scroll to search term 8130.2L, then apply.
If you want to read it click the right link.
 
2. The new AWC comes from https://awc.faa.gov/AWCExternalApplicant/Splash/Index
I logged in today and completed the form asking for a replacement certificate, in comments I put “updated operating limitations”
This was done under the direction of someone involved in the mosaic process but is in disagreement with Mel, a DAR here.
I did not select a specific person, just my fsdo.
I did not upload any documents.

It would be nice if folks share their process here and tell what works. Mel has 4 pending.

I’ve reached out to a kind employee at the GSO fsdo but could not take his call when he called me back today. I hope to talk to him on Thursday, will report back anything new.

is there a charge for this?
 
My application seems to have changed from replacement certificate to amended certificate
 

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RNB said:
My application seems to have changed from replacement certificate to amended certificate
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As it should be.

A replacement certificate is exactly what it says… Replacing a previously issued certificate that was lost, damaged, etc. It would be issued with the exact same operating limitations that you previously had.

An amended certificate is a new certificate with changes, based on the premise that another certificate had already been previously issued to the aircraft.
 
RNB said:
2. The new AWC comes from https://awc.faa.gov/AWCExternalApplicant/Splash/Index
I logged in today and completed the form asking for a replacement certificate, in comments I put “updated operating limitations”
This was done under the direction of someone involved in the mosaic process but is in disagreement with Mel, a DAR here.
I did not select a specific person, just my fsdo.
I did not upload any documents.

It would be nice if folks share their process here and tell what works. Mel has 4 pending.

I’ve reached out to a kind employee at the GSO fsdo but could not take his call when he called me back today. I hope to talk to him on Thursday, will report back anything new.

is there a charge for this?
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Unless you included a 8130-6 I don't think you'll get very far. ;)
 
Ironflight said:
AWC actually fills out the 8130-6 for you based on the information that you enter. No one coudl ever figure out the darn form, so they built the AWC App to do it for you…..😉
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Thanks for this. It did indeed appear to be nearly identical in content.

Can you add colour as to what happens once someone puts in the paperwork? My “can’t see thru the fog” viewpoint is this ought be a point click print kind of thing as prior op lims are handed over. What actually happens or would I need to learn this from a fsdo rep?
 
2-4. Amendments, Exchanges, Replacements, Surrenders, and Transfers.


a. Amendment.


(1) Eligibility. An airworthiness certificate may be amended when there is—


(a) A change in the aircraft model specified on an airworthiness certificate.


(b) An alteration to the aircraft, such as one approved by a supplemental type


certificate (STC) or amended TC, that changes the aircraft category specified in block 4 of the


standard airworthiness certificate.


(c) airworthiness certificate.


A change in the operating limitations for an aircraft with a special


(2) Procedures for Amending an Airworthiness Certificate. Follow the procedures


in paragraph 2-3 of this order except as follows:


(a) Review Aircraft Records. A complete review of aircraft records per


paragraph 2-3.e of this order is not required. Review aircraft records as necessary in


consideration of the reason for the amendment.


(b) Inspect Aircraft. A complete aircraft inspection per paragraph 2-3.f of this


order is not required. Inspect the aircraft as necessary in consideration of the reason for


the amendment.


Note: In amending a special airworthiness certificate, all operating limitations must be


issued per the current version of this order; Appendix D, Table D-1.


b
 
RNB said:
Thanks for this. It did indeed appear to be nearly identical in content.

Can you add colour as to what happens once someone puts in the paperwork? My “can’t see thru the fog” viewpoint is this ought be a point click print kind of thing as prior op lims are handed over. What actually happens or would I need to learn this from a fsdo rep?
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You basically showed the process in your post #33. But behind that - once you submit an application on AWC, it has to be processed either by a FSDO Inspector or a Designee. Since you didn;t request a Designee, the Inspector will add it to his/her “todo” list (which can be quite long…..). If you selected a Designee, the Inspector has to radically “assign” it to eh Designee, who can’t see your application until that happens. Once the Designee sees it, they can process it - that involves verifying all the appropriate documentation is there, building new Operating Limitations (which right now, for version “L”, would have to be done by hand because AWC does not yet have the templates for it), then doing a bunch of housekeeping below your AWC is ready. Depending on the Designee’s Managing Specialist, it MIGHT involve an aircraft inspection - especially as folks are going they’ll the new process for the first time.

I have not takes over the process for getting folks the new Ops Lim for inspections with a Light Sport course - its on our list to figure it out.
 
In case anyone is interested in what change was incorporated into the revised Order 8130.2L that authorizes an experimental amateur built owner to complete a condition inspection on their aircraft...
the added text that was not present in earlier versions is what is highlighted in blue below.

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)

 
I applied for the LSRI in November and update to my op lims. This was just after the government shutdown ended. About a week ago I got my new op lims, prior ones were from 1991 and these new ones are very different. I have a meeting next week to get the repairman cert completed.

The FSDO said in Nov that they were waiting on guidance from up above before they could update the op lims and the shutdown slowed them down til the new year basically it seems. That blocked my ability to get the repairman cert I guess. So assuming your FSDO is on top of it, I would bet if you apply youll get your stuff updated within a couple weeks. FSDO guy who picked up my stuff was on top of it with responses within a day or two always. Im out of Portland FSDO.
 
My FSDO guy is working on mine right now. It has been a pain. He says that the system wants Form FAA 8100-1 - Conformity Inspection Record.
I didn't build the plane. I don't have that form. He is trying to work it out. The system needs all these documents which is rediculous. He is frustrated with the process which in his words is to "just change one paragraph in the Op lims." I hope for all our sakes the FAA figures a sreamline method to getting this done as there are thousands of us needing this done.
 
Tooch said:
My FSDO guy is working on mine right now. It has been a pain. He says that the system wants Form FAA 8100-1 - Conformity Inspection Record.
I didn't build the plane. I don't have that form. He is trying to work it out. The system needs all these documents which is rediculous. He is frustrated with the process which in his words is to "just change one paragraph in the Op lims." I hope for all our sakes the FAA figures a sreamline method to getting this done as there are thousands of us needing this done.
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The 8100-1 has been required for years. That form is filled out by the inspector, not the applicant.
And there is no way to change "one paragraph". The entire Op Lims must be updated to the latest version.
 
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Tooch said:
The system needs all these documents which is rediculous.
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It is, in fact, objectively ridiculous. The whole exercise has been largely nonsense from the beginning. But, like the entree Mom chooses for dinner, it’s what we’re having whether we like it or not. 😂

The old tradition of FSDOs doing things unpredictably differently for no reason whatsoever appears to be in full effect, so that’s a cherry on top.
 
Ironflight said:
Depending on the Designee’s Managing Specialist, it MIGHT involve an aircraft inspection - especially as folks are going they’ll the new process for the first time.
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That’s how I read the regs. There is some “as necessary” language that affords wiggle room regarding inspections, but the person issuing the amended AWC still has to make a finding that the aircraft is airworthy. How that can happen without an inspection, I have no idea, but bureaucracies are sometimes creative when it comes to avoiding labor, so I’m keeping hope alive. 🤣
 
Dugaru said:
That’s how I read the regs. There is some “as necessary” language that affords wiggle room regarding inspections, but the person issuing the amended AWC still has to make a finding that the aircraft is airworthy. How that can happen without an inspection, I have no idea, but bureaucracies are sometimes creative when it comes to avoiding labor, so I’m keeping hope alive. 🤣
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Minor correction. The inspector does NOT "make a finding that the aircraft is airworthy". The inspector only finds that the aircraft is up to date and meets the requirements of the certificate being requested. Finding that the aircraft is "in a condition for safe operation" is up to the owner.

The inspector must inspect the maintenance logs to insure that the aircraft is up to date and has a current Condition Inspection.
 
Mel said:
Minor correction. The inspector does NOT "make a finding that the aircraft is airworthy". The inspector only finds that the aircraft is up to date and meets the requirements of the certificate being requested.
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That makes sense to me, especially in experimental land, but how do we get around the first few words of 8130.2L 2-3.h?

h. Issue Airworthiness Certificate. If you find the aircraft airworthy and all other requirements are met for the requested certificate:
 
Dugaru said:
That makes sense to me, especially in experimental land, but how do we get around the first few words of 8130.2L 2-3.h?

h. Issue Airworthiness Certificate. If you find the aircraft airworthy and all other requirements are met for the requested certificate:
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By inspection of the maintenance records. The inspector who signed off the latest condition inspection has made that determination.
 
Mel said:
Minor correction. The inspector does NOT "make a finding that the aircraft is airworthy". The inspector only finds that the aircraft is up to date and meets the requirements of the certificate being requested. Finding that the aircraft is "in a condition for safe operation" is up to the owner.

The inspector must inspect the maintenance logs to insure that the aircraft is up to date and has a current Condition Inspection.
Click to expand...
The stuff I pulled from the order, posted above, I think post 33, seems to contradict this “must inspect” statement.
What about just getting the current op lims would require log inspection?
My inspection is expired as of Feb 1…and I need the lsrm and the op lims…
 
Mel said:
By inspection of the maintenance records. The inspector who signed off the latest condition inspection has made that determination.
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So the person issuing the airworthiness certificate (“you” in 2-3.h) DOES find the aircraft to be airworthy—but does so by inspecting the maintenance records and relying on the latest CI signoff?
 
Dugaru said:
So the person issuing the airworthiness certificate (“you” in 2-3.h) DOES find the aircraft to be airworthy—but does so by inspecting the maintenance records and relying on the latest CI signoff?
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Correct!
 
RNB said:
What about just getting the current op lims would require log inspection?
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I agree that the “as necessary” carve-outs in 2-4 would seem to remove this inspection requirement. The problem is that the person issuing the airworthiness certificate under 2.3.h (somehow, through some process) must find that the plane is airworthy first. Reg is clear as day on that point.
 
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Mel said:
The 8100-1 has been required for years. That form is filled out by the inspector, not the applicant.
And there is no way to change "one paragraph". The entire Op Lims must be updated to the latest version.
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Why should an 8100-1 be required to ammend Op lims. Ad Yes, We know all that but he was just saying it woud be good if you had an easier way. And I was told by my FSDO guy that my A&P that has beed doing my inspections can fill out the form.
 
Mel said:
Correct!
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I feel like the interpretation has shifted somewhat from post 41 though:

Mel said:
The inspector does NOT "make a finding that the aircraft is airworthy".
Click to expand...

The more I read this 2.3.h thing, the more eyebrow-raising it gets. With how much people worry about liability in small-airplane world, I can’t believe people are issuing airworthiness certificates for experimentals under a provision that (quite clearly) requires them to first make a finding that the plane is airworthy. No matter how that is accomplished (reliance on a CI, etc.) the cross-examination questions practically write themselves. Yikes.
 
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Dugaru said:
I can’t believe people are issuing airworthiness certificates for experimentals under a provision that (quite clearly) requires them to first make a finding that the plane is airworthy.
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But how can these people ever find an experimental aircraft to be "airworthy." ;)
 
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