Maintaining an LSA

[rgmwa]

A major advantage of a LSA aircraft is that it can be flown by a pilot with a recreational licence, however what about maintaining it?

 

I've been engaged in some interesting correspondence with CASA, and the upshot seems to be that while an owner-builder can maintain an aircraft that is classified as amateur built experimental or kit-built experimental, an Experimental LSA has to be LAME maintained (as does a factory-built S-LSA).

 

Basically CASA's reasoning is that because an E-LSA does not have to comply with the 51% rule, they cannot be sure that the owner-builder has sufficient knowledge of the aircraft's construction and systems to be able to maintain it to an acceptable safe standard. Consequently, an Experimental LSA is not mentioned in CASA 43/11, which is the instrument that grants the owner-builder authority to maintain an amateur built experimental or kit-built experimental aircraft, provided he/she has passed an approved Maintenance Procedures Course (MPC).

 

This is a quote from CASA regarding their view of an owner-builder maintaining a kit-built LSA (presumably under 43/11): "CASA may eventually consider those LSA kits (if any) that require more than 51% input by the owner-builder, but it will not happen any time soon and strict guidelines would apply. For instance, painting it wouldn't count."

 

My particular interest is in the RV-12, which the FAA in the US has assessed as complying with the 51% rule. CASA normally recognises FAA rulings, although frankly I'm not sure what their view of the RV-12 is. It seems to me from what CASA have said that the options are a) build AB-E so you can maintain it, or b) build E-LSA, but pay a LAME to keep it in the air. In either case, if VH registered you need a PPL to fly it, or an RAA-Aus Recreational licence if 19-reg (since CASA/SAAA don't yet have an equivalent).

 

Maybe I haven't got the full story so far, but I'd be interested to hear what other RV-12 builders are doing. CASA seems to be lagging behind the FAA when it comes to the LSA rules and regulations.

 

rgmwa

 

 

[Yenn]

SAAA have a maintenance approval, which allows experimental builders to do their own maintenance once they have passed the required test and have a certificate to prove it. I am not sure that this will apply to LSA but their members are building LSA. I will see if I can find out the details.

 

 

[rgmwa]

Thanks Yenn. I think you're referring to the Maintenance Procedures Course (MPC) which is run by SAAA, and which is required now by CASA in order for builders of VH registered Amateur Built Experimental AB(E) and older ABAA aircraft to fully maintain them. To do so, they must have also built at least 51% of the aircraft, and of course be prepared to take full legal responsibilty for maintaining them - not exactly a trivial consideration. Therefore some (maybe many) builders will choose to pay a LAME to do the work. Incidently, the builder can only legally maintain his/her own aircraft, not someone else's, even if it's identical.

 

However, the Builder's Maintenance Authority doesn't apply to E-LSA aircraft, even if the E-LSA kit can be shown to comply with the 51% rule required for AB(E) and ABAA kits. That's CASA's current position from what they have told me. Consequently E-LSA and S-LSA have to be LAME maintained. This is different to the USA where, as I understand it, both the original builder and any subsequent purchaser can maintain an E-LSA provided they have passed a two day `repairman' course. CASA doesn't allow this, and I'm not saying that's a bad thing, just that the FAA apparently takes a different approach. I'm not sure what maintenance priveleges RAA builders can exercise, so maybe someone can explain that for me.

 

However, maintenance aside, the big advantage of an LSA aircraft (E-LSA or S-LSA) is that you can fly one on a recreational pilot's licence. At the moment RAA-Aus is the only authority in Australia that issues these, although the SAAA has also taken some steps in that direction. Progress seems to be very slow though.

 

rgmwa

 

 

[Jack Tyler]

rgmwa (I know there's a first name in there somewhere...):

 

"This is different to the USA where, as I understand it, both the original builder and any subsequent purchaser can maintain an E-LSA provided they have passed a two day `repairman' course."

 

And of course, also attend a Rotax course (at least the first of the three they offer) to maintain the engine in that RV-12, at least insofar as Rotax views it.

 

My first reaction, after reading your CASA summary and your own comments, is to ask you what particular benefit(s) do you think the E-LSA classification will have *for you*. Building as an E-AB but following the same build instructions as the kits' manuals (for E-LSA classification), it seems like you would get the same plane you prefer, even if you are the mfgr. vs. Vans. When you sell (perish the thought, I know...), the E-AB class doesn't seem to offer less self-maintenance options to the buyer over the E-LSA class, provided CASA retains its limitations for E-LSA a/c. A full photo log per e.g. kitlog, a blog or your own software could provide the buyer with the assurance it's an E-LSA lookalike, when coupled with the manuals.

 

Personally - and as you know, I'm interested in the RV-12 as well, and wish to build it as an E-LSA - I can see some advantages to going E-AB. For one, I'd like to add a bit of add'l avionics so I can consider using it light IFR...and doing that during the construction vs. retrofitting things would be easier. And as you also know, going E-AB but not deviating hugely from the plans would allow the plane to remain an LSA and so eligible for use by Sport Pilots.

 

Lots of options, which is always nice...

 

Jack

 

 

[rgmwa]

rgmwa (I know there's a first name in there somewhere...):"This is different to the USA where, as I understand it, both the original builder and any subsequent purchaser can maintain an E-LSA provided they have passed a two day `repairman' course."

 

And of course, also attend a Rotax course (at least the first of the three they offer) to maintain the engine in that RV-12, at least insofar as Rotax views it.

 

My first reaction, after reading your CASA summary and your own comments, is to ask you what particular benefit(s) do you think the E-LSA classification will have *for you*. Building as an E-AB but following the same build instructions as the kits' manuals (for E-LSA classification), it seems like you would get the same plane you prefer, even if you are the mfgr. vs. Vans. When you sell (perish the thought, I know...), the E-AB class doesn't seem to offer less self-maintenance options to the buyer over the E-LSA class, provided CASA retains its limitations for E-LSA a/c. A full photo log per e.g. kitlog, a blog or your own software could provide the buyer with the assurance it's an E-LSA lookalike, when coupled with the manuals.

 

Personally - and as you know, I'm interested in the RV-12 as well, and wish to build it as an E-LSA - I can see some advantages to going E-AB. For one, I'd like to add a bit of add'l avionics so I can consider using it light IFR...and doing that during the construction vs. retrofitting things would be easier. And as you also know, going E-AB but not deviating hugely from the plans would allow the plane to remain an LSA and so eligible for use by Sport Pilots.

 

Lots of options, which is always nice...

 

Jack

Hi Jack,

 

Given the way that CASA apparently views E-LSA in Australia , I frankly can't see any benefit for me in registering the plane as an E-LSA, although I have every intention of building it as per Vans plans, with the exception of implementing some modifications along the way that a number of US builders have also done, but have had to wait until their C of A has been issued. I am also documenting the build as required for AB(E).

 

The US system has always struck me as a bit odd in that they insist on strict adherence to the plans until sign-off, but after that you can change what you like as long as the modifications don't take the plane outside the LSA performance parameters. That seems to undo the basic premise of E-LSA where the idea is to build an exact copy of the S-LSA original, but that's how it works over there. However, the good thing about E-LSA in the US is the easy accessibility of owner maintenance authority, although some might also argue that this is not such a good thing.

 

Certainly CASA doesn't allow that, and I can understand why they take a more conservative stance on this. At the end of the day, it's about safety. If you build AB(E) (51%), you can maintain it (assuming you consider yourself competent to do so). But if you sell it, the purchaser will be paying a LAME to maintain it because they haven't had the experience of building it and the knowledge that comes with that. If you build and register the plane as E-LSA, you have no choice but to pay a LAME.

 

I'm not saying that's necessarily a bad thing, because not every builder will want to take on the responsibility for maintenance. However for me, registering AB(E) but building E-LSA with a few relatively minor modifications seems like the best way to go. I can maintain it, it will be very close to Van's S-LSA factory-built, and as it will remain within LSA parameters (and ours are less restrictive than the US rules), a sport pilot can fly it.

 

Incidentally, CASA requires you to have a backup magnetic compass. In the US, this would be a deviation from the plans, and would require written permission from Vans in order to remain E-LSA eligible. I'm putting in the compass and some other backup instruments, but I don't have to ask anyone's permission.

 

As you say, it's nice to have options.

 

Robert (rgmwa)

 

 

[Jack Tyler]

Robert, given CASA's stance I think you've got exactly the right approach. It's better for you as the builder (re: maintenance) and no worse for the eventual buyer of your plane (than purchasing an E-LSA). And building to complete plans, while documenting deviations & additions, makes resale more comfortable for the buyer, I would think.

 

I think the FAA position on E-LSA's makes more sense if you look at it historically and politically, less so if you only consider the near-term introduction of the LSA & SP regulations. Not only are there many more pilots in the U.S. than Oz but also a broader presence of aviation history (consider it 'momentum') and politically powerful aviation organizations (AOPA, EAA, GAMA and so on...). So adding any totally new classification system in a vacuum just wasn't feasible. Consequently, the E-LSA rules ended up producing a hybrid: A new, tightly controlled build process (of approved plans which first produced a finished a/c) on the front end but with the ongoing flexibility of an Experimental a/c once the a/c is accepted. Given that many Sport Pilots were expected to be older, I can imagine it was argued that the builder of an experimental LSA might be more experienced than the experimental builder population as a whole. Or at least that's my sense of it, altho' we were sailing in/around Europe when the SP & LSA regulations were created, so I'm sure I'm missing at least some of it. Personally, I think there might be more risk inherent in the medical self-certification side of the SP rules than in the risks of modifying an E-LSA...but no doubt the stats will ultimately make that determination.

 

Jack