Mosaic impacts for maintenance

bflynn

bflynn

Final Approach
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Display name:
Brian Flynn
First question - am I reading Mosaic right?

We know the range of aircraft eligible for sport pilots is changing and the FAA is doing away with the LSA definition in 1.1. This morning I was up early and started reading through MOSAIC to see what that meant for LSA Repairmen and LSA IAs, but I was finding it a little dense (or it's just me being dense at times). In doing away with the LSA definition, they're changing the range of aircraft that repairmen and IAs can work on. The training requirements are going to change, but it won't be a full 2 year part 147 course? It sounds like it will be the 120 hours the repairman already has to do plus additional training specific to the category of aircraft to work on. You won't need a full A&P? But what if the same aircraft is flown by non-sport pilots for non-sport activities?

Am I reading this right?
 
They're not doing away work the LSA definition; they're expanding it. A light-sport repairman (the 120 hour course) can work on any aircraft certificated as SLSA, but not legacy certified aircraft that meet the LSA definition (e.g. J-3 and maybe C-172 if the changes for through).
 
Rainbow Aviation (Brian & Carol Carpenter) has posted some videos in the last couple of days, I think they have 1 more left to post on the topic.

LSRM and the new MOSAIC NPRM​

- In this video were going to take a look at the ramifications for the new MOSAIC rule as laid out in the current NPRM. Carol and Brian Carpenter discuss their concerns and proposals to remedy the shortcomings of the NPRM as it relates to the light sport maintenance training proposals.

Proposal- The Repairman Inspection Course for Amateur Built aircraft owners​

- In this video were going to talk about our proposal to allow owners of Experimental Amateur built aircraft to conduct their own annual condition inspections. Carol and Brian Carpenter discuss their concerns and proposals to remedy the shortcomings of the NPRM as it relates to the Experimental Amateur built aircraft condition inspections.
 
yabut, did you see the blurb where the FAA supposedly came to them 4 years ago musing about making it mandatory for EAB owners to have to take LSRM (equivalent)? EAB non-builders pay attention, I told y'all what the FAA really wants. I know EABers have had a certain swagger about their regulatory largesse for years, but nothing is permanent. Careful who you let in the tent, this LSAer expansion may not be the koombaya moment everybody keeps touting it as.

As to Rainbow Aviation, they're doing optics control. They'd make money hand over fist as first-past-the-post providers of said training, short lived as their monopoly would be if that requirement were to be made into law. Of course they don't want to turn off the audience by admitting on camera they were giddy at the insinuation the FAA wanted to proceed with the intent to make LSRM-equivalent training mandatory for EAB.

"but the EAA won't let us". wut? That was also eye-opening hearsay. She really wants me to believe this is the interaction an FAA office presented when asking themselves if they should make something mandatory? Lulz.

I also find their commentary against non-builder EAB owners pretty condescending. It's also contradictory, given it is APs who are currently providing signatures to these non-builder EABers. E-LSA are also allowed to modify their airplanes "away from AP eyes", yet that is not a problem for them. Gee, wonder why? (hint who provides LSRI training for E-LSAers.....). You can't have the cake and eat it too.

Moot point for me, as I reject the premise EAB airplanes are falling out of the sky as a function of who is doing the condition inspection and what paperwork they have or don't have from the alphabet soups, vis a vis LSA or even normal AW fAc-bUilT. These folks are speaking out both sides of their mouth.
 
This move could also be the initial ground work toward an owner maintenance type program. Including the 120 hr repairmen requirement for EAB and expanding the LSA aircraft list to include more TC aircraft narrows a huge gap that couldnt be spanned with the commercial non-primary cat in the past. If this change generates similar interest in other ICAO members then it just might jump the final hurdle that the TCCA owner program couldn't. Or at least provide a solid separation between A&P maintained aircraft and LSARM maintained aircraft. For anybody interested I would definitely recommend get as many comments posted.
 
hindsight2020 said:
yabut, did you see the blurb where the FAA supposedly came to them 4 years ago musing about making it mandatory for EAB owners to have to take LSRM (equivalent)? EAB non-builders pay attention, I told y'all what the FAA really wants. I know EABers have had a certain swagger about their regulatory largesse for years, but nothing is permanent. Careful who you let in the tent, this LSAer expansion may not be the koombaya moment everybody keeps touting it as.

As to Rainbow Aviation, they're doing optics control. They'd make money hand over fist as first-past-the-post providers of said training, short lived as their monopoly would be if that requirement were to be made into law. Of course they don't want to turn off the audience by admitting on camera they were giddy at the insinuation the FAA wanted to proceed with the intent to make LSRM-equivalent training mandatory for EAB.

"but the EAA won't let us". wut? That was also eye-opening hearsay. She really wants me to believe this is the interaction an FAA office presented when asking themselves if they should make something mandatory? Lulz.

I also find their commentary against non-builder EAB owners pretty condescending. It's also contradictory, given it is APs who are currently providing signatures to these non-builder EABers. E-LSA are also allowed to modify their airplanes "away from AP eyes", yet that is not a problem for them. Gee, wonder why? (hint who provides LSRI training for E-LSAers.....). You can't have the cake and eat it too.

Moot point for me, as I reject the premise EAB airplanes are falling out of the sky as a function of who is doing the condition inspection and what paperwork they have or don't have from the alphabet soups, vis a vis LSA or even normal AW fAc-bUilT. These folks are speaking out both sides of their mouth.
Click to expand...

You have a fundamental misunderstanding of their position and motivation. They are advocating that owners of an EAB aircraft that they didn't build be allowed to take a course and after completion of that course be allowed to perform the annual condition inspection of said EAB aircraft. As you noted, this is the way it works currently for E-LSA owners. How is advocating for expansion of that to EAB a bad thing?

As to making money "hand over fist", only they know what their plans are, but based on what I have seen, they are more or less maxed out in their operational capacity and I doubt they are eagerly contemplating a great expansion of their programs.

My take on their first video is that they are concerned that if this goes the wrong way we will see an "A&P Light" out of this requiring a lot more training and complexity than a 120 hour class. They're not going to provide that training and I doubt there would be much demand for it; It's hard enough to set aside 3 weeks and travel to rual Missourri as it is, no one is going to do that for a 6-12 month course. It would also destroy any advantage to owning a LSA. This is where you should focus your doom and gloom outlook as this is the way to destroy any positive benefits of the MOSAIC NPRM...
 
Dana said:
They're not doing away work the LSA definition; they're expanding it. A light-sport repairman (the 120 hour course) can work on any aircraft certificated as SLSA, but not legacy certified aircraft that meet the LSA definition (e.g. J-3 and maybe C-172 if the changes for through).
Click to expand...
I see what I didn't yesterday - while the LSA definition is expanding, there is a difference between aircraft certified under lsa rules and aircraft which sport pilots can fly. LSRM can work on certified lsa aircraft but not on every airplane sport pilots can fly.

I think a A&P light which is restricted to smaller ga airplane is a good idea.
 
idahoflier said:
They are advocating that owners of an EAB aircraft that they didn't build be allowed to take a course and after completion of that course be allowed to perform the annual condition inspection of said EAB aircraft. As you noted, this is the way it works currently for E-LSA owners. How is advocating for expansion of that to EAB a bad thing?
Click to expand...
I am not saying it’s a bad thing.

But every S-LSA converted to E-LSA, like my Sky Arrow, had to pass an inspection verifying it was in the same state at the moment of conversion as when it rolled out of the factory. As such, though now open to modification, the owner has an established base model to start with.

With an E-AB, it’s a different situation. The builder may have deviated from plans, if there were any, in pretty much any manner. Yes, the new owner should have builder’s logs to refer to, but may have to deal with all sorts of shortcuts and non-standard methods and materials when inspecting said aircraft.

Again, not arguing against the expansion, just that new owners inspecting aircraft someone else built may need to be a bit more conscientious than with an E-LSA conversion.
 
FastEddieB said:
I am not saying it’s a bad thing.

But every S-LSA converted to E-LSA, like my Sky Arrow, had to pass an inspection verifying it was in the same state at the moment of conversion as when it rolled out of the factory. As such, though now open to modification, the owner has an established base model to start with.

With an E-AB, it’s a different situation. The builder may have deviated from plans, if there were any, in pretty much any manner. Yes, the new owner should have builder’s logs to refer to, but may have to deal with all sorts of shortcuts and non-standard methods and materials when inspecting said aircraft.

Again, not arguing against the expansion, just that new owners inspecting aircraft someone else built may need to be a bit more conscientious than with an E-LSA conversion.
Click to expand...

I completely agree with you and because of the point you brought up is probably why the FAA isn't looking to expand who can perform a condition inspection on an EAB aircraft.
 
hindsight2020 said:
yabut, did you see the blurb where the FAA supposedly came to them 4 years ago musing about making it mandatory for EAB owners to have to take LSRM (equivalent)? EAB non-builders pay attention, I told y'all what the FAA really wants. I know EABers have had a certain swagger about their regulatory largesse for years, but nothing is permanent. Careful who you let in the tent, this LSAer expansion may not be the koombaya moment everybody keeps touting it as.

As to Rainbow Aviation, they're doing optics control. They'd make money hand over fist as first-past-the-post providers of said training, short lived as their monopoly would be if that requirement were to be made into law. Of course they don't want to turn off the audience by admitting on camera they were giddy at the insinuation the FAA wanted to proceed with the intent to make LSRM-equivalent training mandatory for EAB.

"but the EAA won't let us". wut? That was also eye-opening hearsay. She really wants me to believe this is the interaction an FAA office presented when asking themselves if they should make something mandatory? Lulz.

I also find their commentary against non-builder EAB owners pretty condescending. It's also contradictory, given it is APs who are currently providing signatures to these non-builder EABers. E-LSA are also allowed to modify their airplanes "away from AP eyes", yet that is not a problem for them. Gee, wonder why? (hint who provides LSRI training for E-LSAers.....). You can't have the cake and eat it too.

Moot point for me, as I reject the premise EAB airplanes are falling out of the sky as a function of who is doing the condition inspection and what paperwork they have or don't have from the alphabet soups, vis a vis LSA or even normal AW fAc-bUilT. These folks are speaking out both sides of their mouth.
Click to expand...
Or they know that their market of 15 and 2-day folks won't do a 6-12 month course and their business model will become nonexistent.
 
Somehow someone is missing the point...:confused2:
Maintaining any and ALL aircraft require the same thing. The 2000 or 120 hour course is to inform everyone doing maintenance what the regulations say:

The Owner/Operator is responsible for the aircraft's Airworthy Condition:
91.403 GENERAL

"No one" (Mechanic, Owner/Operator or guy on the street) may do any work on any aircraft, engine or accessory without the appropriate maintenance publications.
43.13

The Maintenance rules training should go to "ALL" Owner/Operators.

The FAA delegates using FARs on how to fly safe through best practices.

The Owner/Operator delegates maintenance to people who choose to study and perform the procedures and/or inspections. Those people who choose to perform maintenance will seek the necessary requirements to do the work. Whatever alphabet name the mechanic calls themselves, just be sure they follow the manufacturer's and/or engineer's instructions. It really is that simple. Certificates and license are documents confirming you where tested on the minimum required regulations and agree to follow them.

Don't loose sight of what makes Safe Flying possible. Creating or interpreting rules that are counter to best practices is kinda backwards and stifling. We all just need to stay focused on Flying Safely.
 
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