Maintenance and Modification of Light-Sport Aircraft

by Edsel W. Ford Jr
Reprinted with permission from FAA Aviation News

Maintenance is one of the less glamorous facets of aviation, but it is one of the most important. This is no different in the sport pilot arena. The goal of this ongoing series of articles is to provide you with information about different areas important to this still very young community. This article covers the area of maintenance and modification.

There are two ways of certifying a light-sport aircraft. It can be certified as either a special light-sport aircraft (SLSA) or as an experimental light-sport aircraft (ELSA). Each is certified under different sections of Title 14 Code of Regulations (14 CFR) part 21, and therefore has different maintenance and modification procedures.

The following excerpts highlight regulations that differentiate the two types of light sport aircraft. Depending on how your light-sport aircraft is certified, you could face very different maintenance requirements. The information to follow starts with a short explanation of what each of those certifications is and lists applicable regulations covering maintenance and modification. As always with regulation issues, the regulations listed here are up to date at the time this article was written, but for current regulations you should check the Web at https://ecfr.io/Title-14/under Title 14, Aeronautics and Space, parts 21 and 91, sections cited later in the text.

Title 14 Code of Federal Regulations (14 CFR) '21.190, Issue of a special airworthiness certificate for a light-sport category aircraft, is the industry developed consensus standards and is the basis for certification and complied with by the manufacturer. Compliance is recorded and submitted on the FAA form 8130-15 'Statement of Compliance.' The maintenance and modification requirements are given in the applicable sections of 14 CFR parts 43 and 91. For a light-sport category aircraft, it is found in '91.327. The maintenance and inspection requirements for aircraft are usually in '91.400s, so '91.327 is not a typical place where mechanics and operators would look. In addition, the operating limitations that are issued with the special airworthiness certificate have maintenance and inspection requirements. The highlighted areas are the requirements for modification of a 'special light-sport aircraft.' These modification requirements are different from what the mechanic and operator have complied with in the past. They place the manufacturer in control of any modification or repair beyond the scope and detail of the maintenance manual. The manufacturer authorizes the modification or repair, and a letter from the manufacturer must be included in the aircraft records.

14 CFR Section 91.327 - Aircraft having a special airworthiness certificate in the light-sport category:

Operating limitations: No person may operate an aircraft that has a special airworthiness certificate in the light-sport category unless-

(1) The aircraft is maintained by a certificated repairman with a light-sport aircraft maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station in accordance with the applicable provisions of part 43 of this chapter and maintenance and inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA;

(2) A condition inspection is performed once every 12 calendar months by a certificated repairman (light-sport aircraft) with a maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station in accordance with inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA;

(3) The owner or operator complies with all applicable airworthiness directives;

(4) The owner or operator complies with each safety directive applicable to the aircraft that corrects an existing unsafe condition. In lieu of complying with a safety directive an owner or operator may-

(i) Correct the unsafe condition in a manner different from that specified in the safety directive provided the person issuing the directive concurs with the action; or

(ii) Obtain an FAA waiver from the provisions of the safety directive based on a conclusion that the safety directive was issued without adhering to the applicable consensus standard

(5) Each alteration accomplished after the aircraft's date of manufacture meets the applicable and current consensus standard and has been authorized by either the manufacturer or a person acceptable to the FAA;

(6) Each major alteration to an aircraft product produced under a consensus standard is authorized, performed and inspected in accordance with maintenance and inspection procedures developed by the manufacturer or a person acceptable to the FAA; and

(7) The owner or operator complies with the requirements for the recording of major repairs and major alterations performed on type-certificated products in accordance with '43.9 (d) of this chapter, and with the retention requirements in '91.417.

(8) No person may operate an aircraft issued a special airworthiness certificate in the light-sport category to tow a glider or un-powered ultra light vehicle for compensation or hire or conduct flight training for compensation or hire in an aircraft which that persons provides unless within the preceding 100 hours of time in service the aircraft has-

(a) Been inspected by a certificated repairman with a light-sport aircraft maintenance rating, an appropriately rated mechanic, or an appropriately rated repair station in accordance with inspection procedures developed by the aircraft manufacturer or a person acceptable to the FAA and been approved for return to service in accordance with part 43 of this chapter; or

(b) Received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

(9) Each person operating an aircraft issued a special airworthiness certificate in the light-sport category must operate the aircraft in accordance with the aircraft's operating instructions, including any provisions for necessary operating equipment specified in the aircraft's equipment list.

Experimental light-sport aircraft (ELSA) are certificated under 14 CFR '21.191 and have three options to qualify under. The maintenance requirements of part 43 are not applicable to aircraft issued airworthiness certificates under '21.191(i)(1) and (2). However, '43.1(b) states, 'This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.' This is referring to the SLSA that has been converted to an ELSA. The FAA has issued a previous certificate, so part 43 would still apply. However, the maintenance requirements of '91.237 would not apply. Aircraft having experimental airworthiness certificates are covered under '91.319 and the operating limitations issued to the aircraft.

14 CFR Section 21.191 - Experimental certificates

Experimental certificates are issued for the following purpose - operating light-sport aircraft that [Note: The experimental certificate is not a category but a purpose of operation.]:

(a) Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of '103.1 of this chapter. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008;
[Note: This option is for the aircraft the FAA has been calling the 'existing fleet.' However, this can be applied to any aircraft that meets the definition of light sport even if the aircraft would typically be amateur built.]

(b) Has been assembled-

(i) From an aircraft kit for which the applicant can provide the information required by '21.193 (e); and

(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard;
[Note: This option is not available at the time of this writing. The kit consensus standards are just now complete but have not been accepted by the FAA. When you look up the dictionary definition of a kit, it says a box of parts that assembled into an aircraft would be defined as a kit. However, in the case of light sport, the kit is required to have a kit statement of compliance and be a bolt for bolt copy of a special light-sport aircraft at the time of original certification. A box of parts today that is assembled into an aircraft would be considered to be part of the existing fleet. Modification of the 'light-sport kit' aircraft can be at will after original certification.] or

(iii)) Has been previously issued a special airworthiness certificate in the light-sport category under '21.190.
[Note: This option is for the special light sport that no longer meets the consensus standards and the manufacturer's statement of compliance. This aircraft can be modified at will and then certificated as experimental. The only way that this aircraft can be converted back to a special light-sport aircraft is for the manufacturer to issue a new statement of compliance.]

The maintenance and modification of light-sport aircraft has changed the method with which a mechanic or repairman should approach the job. There are many new things to learn as the industry delivers more aircraft to the market. Also, the number of experimental certificated aircraft that will be added to the general aviation fleet will present mechanics and repairmen alike with new challenges.