AOPA Pilot Magazine - August 2023 - 96

RUDDER & WRENCH
Pennsylvania. Although these consensus
standards have been accepted by the FAA,
they are not FAA-approved. They don't fit
into the FAA's regulations regarding airworthiness,
certification, or maintenance,
which has made them a regulatory hot
potato that the FAA rulemaking folks have
been reluctant to touch.
Under pres s u r e
SLSA owners at the manufacturer's mercy
in a fashion that owners of certified airplanes
aren't.
The vast majority of SLSAs are powfrom
t he
96
Experimental Aircraft Association, the
FAA adopted the light sport aircraft rule
in July 2004. With respect to maintenance
requirements, the FAA basically opts out.
The rule, specifically 91.327, requires
SLSAs to be maintained and inspected in
accordance with manufacturer-developed
procedures, to comply with all manufacturer-issued
safety directives (like
ADs except that they don't come from
the FAA), and not to be altered except
as approved by the manufacturer. This
gives the manufacturers of SLSAs absolute
control over maintenance requirements,
including unfettered ability to change the
rules in the middle of the game. This puts
ered by Rotax 900-series engines. Rotax
specifies a calendar-time TBO of 12 years
for these engines. So, as the 12-year anniversary
of the SLSA rule approached, many
SLSA owners started asking " Do I really
have to overhaul my engine? " A couple of
them requested a legal interpretation.
Then something odd happened. In
August 2013, AGC-200 issued a legal
interpretation ( " Willette " ) stating: " The
intervals specified in maintenance manuals
for S-LSA, therefore, are not per se
mandatory. Consequently, a maintenance
provider may develop an alternative that
is acceptable to the FAA... " Two years later,
in July 2015, AGC-200 issued another legal
interpretation ( " Keller " ): " The aircraft
would not be airworthy if operated beyond
TBO... " Two legal interpretations written
by two different FAA attorneys two years
apart arriving at opposite answers.
In May 2016, I sent a lengthy letter to
AGC-200 pointing out this contradiction.
" Clearly Willette and Keller cannot both
be correct, " I wrote. " I am requesting a
definitive interpretation of which of these
two interpretations the owner or operator
of an SLSA may rely upon. "
More than a year later, I spoke with
the rulemaking attorney to whom my
request had been assigned. He apologetically
told me that the interpretation
I requested would not be forthcoming.
" The folks in the Maintenance Division
don't want to touch this, " he said. The
issue remains unresolved. If you're an
SLSA owner, you have two contradictory
legal interpretations. Take your pick.
A&P experience requirement
The FAA doesn't make it easy to qualify
as an A&P. To become eligible to take the
three mechanic knowledge tests (general,
airframe, powerplant) and the practical
test (an all-day affair conducted by a designated
mechanic examiner), you must
http://www.diamondaircraft.com
AOPA Pilot Magazine - August 2023

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