The light sport aircraft (LSA) category includes gliders, airplanes, gyroplanes, powered parachutes, weight-shift and lighter-than-air aircraft. There are two general types of LSAs: Special (SLSA) and Experimental (ELSA). The SLSA are factory built and the ESLA are kit-built. This new category of aircraft was added to the regulations in 2004. (Refer to 14 CFR sections 21.190, 65.107, and 91.327, all dated July 27, 2004.)
Just as industry standard specifications have replaced many of the military standards to define products that are destined to be part of the Department of Defense (DoD) inventory, so too have industry standards come into the FAA sights for documenting certain information. Quality is one example. The Society of Automotive Engineers (SAE) has developed AS 9100 and AS 9110 as auditing standards for aerospace facilities and specifically repair stations. Likewise, ISO 9001 is being adopted by the FAA as a system of measuring their performance. Therefore, it was logical that when the FAA looked to develop the standards for this newest category of aircraft, they again looked to industry, and this time it was the American Society for Testing and Materials (ASTM).
The ASTM developed a comprehensive list of consensus standards for use by manufacturers, regulators, maintenance facilities, LSA owners, and service providers. It is unique that these standards are the first ones in over 100 years to solely address the issue of recreational aircraft use. It is also the first complete set of industry consensus standards covering the design, manufacture, and use of recreational aircraft that was developed by a non-government agency. The ASTM committee that developed these LSA standards did so to ensure the quality of products and services to support both the national and the international regulatory structures for LSAs. Over 20 standards have been generated, and more are being developed to cover this diversity of aircraft. This text only incorporates a review of F2483-05, “Standard Practice for Maintenance and the Development of Maintenance Manuals for Light Sport Aircraft (LSA)” a six-page document comprised of the following 12 sections:
- Referenced Documents
- Significance and Use
- Aircraft Maintenance Manual
- Line Maintenance, Repairs, and Alterations
- Heavy Maintenance, Repairs, and Alterations
- Major Repairs and Alterations
- Task-Specific Training
- Safety Directives
The scope of that document is basically twofold:
- To provide guidelines for the qualification necessary to accomplish various levels of maintenance on LSA.
- To provide the content and structure of maintenance manuals for aircraft and their components that are operated as LSAs.
Some additional definitions from section 3, Terminology, that help to better explain the LSA concepts are:
- Annual condition inspection—defined as a detailed inspection accomplished once a year in accordance with instructions provided in the maintenance manual supplied with the LSA. The purpose of this inspection is to look for any wear, corrosion, or damage that would cause the LSA not to be in condition for safe operation.
- Heavy maintenance—any maintenance, inspection, repair, or alteration a manufacturer has designated that requires specialized training, equipment, or facilities.
- Line maintenance—any repair, maintenance, scheduled checks, servicing, inspections, or alterations not considered heavy maintenance that are approved by the manufacturer and is specified in the manufacturer’s maintenance manual.
- LSA repairman–inspection—a U.S. FAA-certified LSA repairman with an inspection rating per 14 CFR part 65. This person is authorized to perform the 100hour/annual inspection of the aircraft that he or she owns.
- LSA repairman–maintenance—a U.S. FAA-certified LSA repairman with a maintenance rating per 14 CFR part 65. This person is allowed to perform the required maintenance and can also accomplish the 100-hour/ annual inspection.
- Major repair, alteration, or maintenance—any repair, alteration, or maintenance where instructions to complete the task are excluded from the maintenance manual.
- Minor repair, alteration, or maintenance—any repair, alteration, or maintenance where instructions to complete the task are included in the maintenance manual.
The 100-hour inspection is the same as the annual inspection, except for the interval of time. The requirements for whether or not the 100-hour inspection is applicable are exactly the same as the criteria for the standard 100-hour/annual required of non-LSA aircraft.
Aircraft Maintenance Manual (AMM)
Although these manuals do not require any FAA approval, the regulations do require that the manual be developed in accordance with industry standards. This ASTM sets that standard by requiring:
- General specifications to be listed, include capacities, servicing, lubrication, and ground handling
- An inspection checklist for the annual condition or 100-hour inspection
- A description of and the instructions for the maintenance, repair, and overhaul of the LSA engine
- A description of and the instructions for the maintenance, repair, and alteration of the aircraft’s primary structure
Other items that maintenance procedures must be provided for are:
- Fuel systems
- Utility system
- Instruments and avionics
- Electrical system
- Structural repair
- Painting and coatings
The Inspection, Repair, and Alterations section must specifically list any special tools and parts needed to complete the task, as well as the type of maintenance action (line, heavy, or overhaul) necessary to accomplish the activity. Directly associated with that information is the requirement to specify the level of certification needed to do the job (i.e., LSA repairman, A&P, or repair station). The manual may refer to existing FAA ACs.
Line Maintenance, Repairs, and Alterations
The minimum level of certification necessary to accomplish line maintenance is LSA inspection. Some typical tasks considered to be line maintenance are:
- 100-hour/annual condition inspection
- Servicing of fluids
- Removing and replacing components when instructions to do so are provided in the maintenance manual
- Fuel pump
- Spark plugs and wires
- Floats and skis
- Repair or alteration of components when specific instructions are provided in the maintenance manual
- Patching a hole in the fabric
- Installation of a strobe light kit
Heavy maintenance, repairs, and alterations must be accomplished by either a certified mechanic (A or P or A&P) or an LSA repairman—maintenance who has received additional “task specific” training. Some examples of this would be the removal and replacement of complete engine, cylinder, piston and valve assemblies; primary flight controls; and landing gear.
Heavy repair of components or structure can be accomplished when instructions are provided in the maintenance manual or other service directed instructions. A few examples of this activity are:
- Repainting of control surfaces
- Structural repairs
- Recovering of a dope and fabric
Heavy alterations of components can be accomplished when instructions are provided in the maintenance manual or other service directed instructions. Examples of this activity are initial installation of skis and installation of new additional pitot static instruments.
Overhaul of components can be performed only by the manufacturer (or someone authorized to perform) of the LSA or the component to be overhauled. An overhaul manual is required and must be a separate manual from the manufacturer’s maintenance manual. Items typically considered for overhaul are engines, carburetors, starters, generators, alternators, and instruments.
Major Repairs and Alterations
Another major difference between LSA maintenance and traditional aircraft maintenance is that FAA Form 337, Major Repair and Alteration, is not required to document major repairs and alterations. Instead, any major repair or alteration that is accomplished after the LSA has gone through production acceptance testing must be evaluated relative to the applicable ASTM requirements. After this evaluation has been accomplished (either by the manufacturer or an entity approved by them), a written affidavit must be provided attesting that the LSA still meets the requirements of the applicable ASTMs.
The manufacturer (or other approved entity) must provide written instructions defining the level of certification necessary to perform the maintenance and also include any ground test or flight testing necessary to verify that the LSA complies with the original LSA acceptance test standards, and is in condition for safe operation. Proper documentation of this maintenance activity is required to be entered in the LSA records and is also defined by the manufacturer.
Task specific training is not required to be FAA approved. This is solely the responsibility of the manufacturer. Some examples of this are an engine manufacturer’s overhaul school or the EAA Sport Air fabric covering school.
Safety directives are issued against an LSA or component and are not issued by the FAA, but rather by the original aircraft manufacturer. NOTE: If the LSA includes a product that is TC’d by the FAA, the manufacturer is required to issue a safety directive. Typical instructions within a safety directive include:
- List of tools required for the task
- List of parts needed
- Type of maintenance (line, heavy, overhaul)
- Level of certification needed
- Detailed instructions and diagrams
- Inspection and test methods
Safety directives are mandatory, except for experimental use LSAs.