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S-LSA downsides

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Victor Bravo

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With the possible exception of the SR-71 ( with its Titanium rivets and all that), There is no reason for any manufacturer to make it nearly impossible to perform a repair on their airplane. Who would it benefit?
 
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Dana

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With the possibleexception of the SR-71 ( with its Titanium rivets and all that), There is no reason for any manufacturer to make it nearly impossible to perform a repair on their airplane. Who would it benefit?
The manufacturer?
 

Hot Wings

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The manufacturer?
But only in a market with limited options for the consumer relative to demand......or if you are depending on the "brand" to do the marketing for you. There are lots of examples in the marketing world where inferior products demand a higher price because they are of the right "brand". This same concept also applies to products of equal real value and quality.
 

PTAirco

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I know a small, privately owned repair shop that gets all the insurance work that it wants. They do outstanding fabric and paint work, wood work, etc. There was an article in Sport Aviation a few years back, about his M14 powered UPF 7.

The shop is the cleanest, most organized aircraft workshop that I have seen.


BJC

I got into this because I was once called by the insurance adjuster after a friend of mine crashed his aircraft. A substantially rebuilt and recovered the aircraft prior to this. The crash had nothing to do with anything we did, but he wanted to know if we were willing to work on tube and fabric aircraft, since nobody seems to want to touch them. People simply said no, or quoted astronomical figures. A Husky we eventually took on was finished in three months, good as new.
very often insurance companies do not have a choice in writing it off, since nobody wants to repair it.

Our shop, by the way, it's not the cleanest and most well-organized shop! But stuff gets done here... And I'm working on it.
 
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Daleandee

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Hmmm... I'm thinking that if an owner converts to ELSA, then the manufacturer's liability could be substantially reduced, no? Maybe that's their intention.
Perhaps that is their intention. Let me be Captain Obvious and throw the reminder out that once converted from SLSA to ELSA the ability to rent the aircraft or use it for flight instruction goes out the window. What they are doing is very effective in driving instructors away from their aircraft for training purposes.

The training environment is an excellent place to find an airplane needing repairs from time to time. So ... if their planes are not being used for instruction it seems that the manufacturer's liability would be reduced even further and if it stays SLSA and needs repairs they make a lot of loot to put it back in service.

Dale
N319WF
 

davidb

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For the record:. It's American Legend.
..............

And they are not even that badly damaged; one of them I could have ferried back with a new strut.
That these aircraft are also offered as kits should come into play meaning there must be a builder’s manual. That manual must specify how to attach a strut as well as how to put everything else together. S-LSA maintenance and condition inspections can be done by an A and P mechanic. Therefore, your mechanic can inspect it and determine the strut needs replacement. If he follows the “approved method” per the builder’s manual, how can the lawyers not allow this?

The build manual is the factory approved method. You are not seeking to modify the aircraft so no manufacturer letter of authorization should be required.

If you can prove the strut is manufactured or supplied from Univair, it should be legal to get it directly from them if it isn’t modified by Legend.
 
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gtae07

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There is no reason for any manufacturer to make it nearly impossible to perform a repair on their airplane. Who would it benefit?
I wouldn't argue they're trying to make it impossible to repair the airplane. Rather, given the way the LSA rules are set up, it presents a very tempting opportunity to run things such that repairing the airplane requires paying them through the nose.

This is not an unusual thing at all, in the broader sense. Look at the (anecdotal?) attempts by car manufacturers to try and deny warranty service if work was performed somewhere other than the dealership, or if any scheduled maintenance was not performed. Look at attempts by electronics manufacturers to use proprietary hardware and encrypted software (and attempts to use DMCA as legal deterrent) to prevent modification or repair of items outside authorized service centers. These are all attempts to limit the supply of repairs/parts and thus increase prices.

I think the FAA naively set up repairs as requiring manufacturer authorization thinking that manufacturers could release maintenance and repair manuals without having to go through the approval process, and so they could permit a broader scope of repairs. In reality (because nobody reacts to FAA regulations the way the FAA expects and intends them to), some manufacturers have chosen to go the opposite way and withhold repair data and parts as much as possible, such that owners have to pay significant sums of money for replacement parts, repair drawings, or repair work done by the manufacturer.

The FAA really needs a "red team" when they sit down and do their regulation-writing...
 

PTAirco

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That these aircraft are also offered as kits should come into play meaning there must be a builder’s manual. That manual must specify how to attach a strut as well as how to put everything else together. S-LSA maintenance and condition inspections can be done by an A and P mechanic. Therefore, your mechanic can inspect it and determine the strut needs replacement. If he follows the “approved method” per the builder’s manual, how can the lawyers not allow this?

The build manual is the factory approved method. You are not seeking to modify the aircraft so no manufacturer letter of authorization should be required.

If you can prove the strut is manufactured or supplied from Univair, it should be legal to get it directly from them if it isn’t modified by Legend.

I asked for drawings and parts catalogs. They refused to provide them:
Quote:
"Legend aircraft engineering, manufacturing processes and certification documentation is all proprietary. Please refer to our maintenance manual, page 68. “No structural repairs are approved” The FAA and ASTM requires all SLSA aircraft repairs and alterations to be approved by the manufacture. Legend Aircraft values the quality and strength of our aircraft. We also must protect ourselves with any liabilities from any potential lawsuits. If you want to maintain SLSA certification and airworthiness, you must repair the aircraft with approved parts from American Legend Aircraft."

It's a Cub clone, for goodness sake!
 

davidb

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I asked for drawings and parts catalogs. They refused to provide them:
Quote:
"Legend aircraft engineering, manufacturing processes and certification documentation is all proprietary. Please refer to our maintenance manual, page 68. “No structural repairs are approved” The FAA and ASTM requires all SLSA aircraft repairs and alterations to be approved by the manufacture. Legend Aircraft values the quality and strength of our aircraft. We also must protect ourselves with any liabilities from any potential lawsuits. If you want to maintain SLSA certification and airworthiness, you must repair the aircraft with approved parts from American Legend Aircraft."

It's a Cub clone, for goodness sake!
Without the help and approval of ALA, I believe you could still maintain SLSA but will require some investigation and documentation on your part. You would need the assistance of other builders and owners of the same AL model as well as help from Univair.

Once you have documented proof that the strut from Univair is the same, remove and replace.

ALA is trying to limit their liability. That’s fine but taking their position to the extreme doesn’t hold up. If ALA were to go out of business tomorrow, are all of their existing SLSA cubs no longer certified? Would the FAA require you to convert it to ELSA if it needed a tire replacement?
 

BBerson

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It may not be possible to exchange the S-LSA airworthiness certificate for the E-LSA certificate if the aircraft is unairworthy or modified. (just a guess, based on how things usually are)
 
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Hot Wings

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ASTM standards are copyrighted but I believe the following falls under the fair use doctrine:

From F2295


8. Discontinued Airworthiness Support

8.1 Should a manufacturer no longer be able to support the
LSA produced, manufacturer should make a timely and diligent
effort to contractually transfer any design data needed for
continued airworthiness support to a viable entity, such as
another manufacturer, type club, user group, or other interested
party.
==============
9. Major Repairs and Alterations

9.1 All major repairs or alterations made to aircraft subsequent
to its initial design and production acceptance testing to
applicable ASTM standards and sale to a consumer must be
evaluated relative to the requirements of the applicable ASTM
design and production acceptance specification(s).

9.2 The manufacturer or other entity that performs the
evaluation of an alteration or repair shall provide a written
affidavit that the aircraft being altered will still meet the
requirements of the applicable ASTM design and performance
specification subsequent to the alteration
.
 

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BBerson

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Does S-LSA have Operating Limitations for maintenance rules? Maintenance manual mandatory linked by Operating Limitations?
 

Hot Wings

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Does S-LSA have Operating Limitations for maintenance rules? Maintenance manual mandatory linked by Operating Limitations?
It is pretty much up to the manufacturer to craft whatever maintenance rules they choose.

3. Terminology
3.1 Definitions:

3.1.9 maintenance manual(s)—manual provided by an LSA
manufacturer or supplier that specifies all maintenance, repairs,
and alterations authorized by the manufacturer.

If this section is left blank then there are no authorized repairs other than what the manufacturer may authorize on a case by case basis. This would make ALL repairs major repairs per the following:

3.1.10 major repair, alteration, or maintenance—any repair,
alteration, or maintenance for which instructions to
complete the task excluded from the maintenance manual(s)
supplied to the consumer are considered major.

It does appear to me that per section 9 that others beside the manufacturer can develop repair procedures and methods, independent of the manufacturer, as long as they can document per the ASTM standards the the resulting repaired plane still meets the standard under which it was "certified". This could be simple or rather complex.

We left a lot of holes in the ASTM standards. Some intentional - some not.
 

davidb

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Wow, buyer beware. FTR, I own an SLSA and my manufacturer is quite the opposite of ALA wrt maintenance and repairs.
 

PTAirco

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My partner in this is flying out there at the end of January to talk to them in person. I feel it's a waste of time but it will be interesting to see what comes out of it.
 

PTAirco

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It may not be possible to exchange the S-LSA airworthiness certificate for the E-LSA certificate if the aircraft is unairworthy of modified. (just a guess, based on how things usually are)
Yes, one would presume an airworthy aircraft. The DAR inspection takes place with an aircraft ready to fly and not modified in any way from standard.
 

Victor Bravo

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Well, the big question is still whether ALA wants to be seen as a manufacturer worth doing business with. If they want to be reasonable and they want to have a good reputation, then they will work with PTAirco to find an acceptable repair method. All other aircraft manufacturers have the same liability concerns and they still allow their aircraft to be repaired using standard processes.

If for some reason they don't care about their reputation, then E-LSA is the easiest work-around.

HOWEVER, I also believe that if PTAirco and other S-LSA owners go to the FAA, and ask whether the FAA really wants structural repairs to be so difficult and problematic, the FAA may get involved and "request" that ALA provides some repair approval in good faith.
 
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