Thread: A License To Learn

Near the first anniversary of my graduation from LSR-M school I put together the following thoughts about the safety consequences of the new rating. Please, what do I have wrong?

When students at the course would ask questions that were beyond the curriculum of the 120-hour course at the Light Sport Mechanic school the instructors (21st century pioneers of aircraft maintenance training) quickly and often said the course would only get the students a "license to learn". A year later, I understand what that means: 120-hour school graduates are not ready to be Aircraft Repairmen. But they get the rating anyway and at any level of competency.

There was no criticism in class for the brevity of training because the students were paying a premium to qualify for the FAA's new maintenance rating for Light Sport Aircraft Mechanics. They would within weeks be able to sign off annuals and 100-hour inspections and make repairs for compensation.

The future mechanics don't say anything about the training conditions or the curriculum because they don't know any better, and because they are getting a repairman certificate for a price with minimum time on task with the weakest possible academic accountability (as in teaching the test). Does it sound to good to be true. Well, it is true … and dangerous.

Over the years, even before the LSA romance struck me, I have been consistently discouraged by the quality of work and suspicious appraisals that led to increased charges of A&Ps and IAs, all from the FAA maintenance establishment. I attended a 120-hour course so I could do my own work and I was dismayed as I grew to understand the gap between old general aviation maintenance and new Light Sport aviation maintenance. Traditional A&P's are ill prepared for light sport maintenance but how prepared are 120-hour course graduate LSR-M mechanics?

Most mechanics, A&P and Light Sport, are honest, hard-working, and competent individuals in organizations that are responsible, competitive, and fair. I am not suggesting foul play by anyone. I am addressing a safety gap though, one that is growing as more and more FAA licensed LSA mechanics enter the aviation maintenance work force. Sound scary?

According to the FAA (the actual licensing authority), LSR-M mechanics can do virtually any maintenance for Light Sport aircraft (see CFR 14, Part 43). However, when authority of manufacturer's consensus and ASTM materials and procedures enter the hanger, maintenance becomes very different than what traditional A&P's know about. Here are a few differences and questions that arise about safety.

Actual time on task training. A&P training historically required thousands of hours of training and left students as virtual apprentices, not journeyman airplane mechanics. No newly minted A&P expected to open shop to work on airplanes, they expected to work in a shop along side mechanics who had done the work who could show the newbies how to do it. 120-hour graduates are licensed and can legally work on Light Sport aircraft with no further support for their naivety. What a mechanic does not know and what he has not seen yet creates a safety gap. As time goes on and the ranks of LSA mechanics are filled with poorly trained or inexperienced individuals, the safety gap could grow to a chasm.

Qualification testing. At the course I attended, to be blunt, they taught the test, there own test. There is an argument among professional educators about "teaching to the test", but this is not the place for that argument. The instructors gave pre-tests and went over the answers frequently and throughly. As you might guess, there were no surprises, everybody passed. There were few, if any, hands-on tests for which failure would disqualify the student. The school's response, again, "There is only so much time teaching and learning. You have to learn the other stuff on your own, later." Yeah. Maybe much later, or never. We did have performance goals and our work was evaluated. However, there was little serious accountability. No one was dis-enrolled for shoddy workmanship. Although, they offered one anecdote for a tuition refund to an inept student.

Who can do the work? Holders of A&P, IA, LSR-M and Owners and Pilots. Furthermore, there are factory trained engine mechanics authorized by the engine manufacturer to perform maintenance. And the last qualification for performing maintenance is the manufacturers requirement for task specific training or experience of a "responsible individual". Almost all maintenance tasks in those LSA maintenance manuals have task specific training requirements. Where to get the training can be a mystery. Some task maintenance approval can be gained with a telephone call, or email, or by viewing videos, or attendance at on site training, or personal study, or a 120-hour course, or a demonstration? Task specific training and experience seems arbitrary at times and certainly driven by manufacturer's liability. Manufacturers can and do control mechanic qualification by simply withholding repair materials or instructions from otherwise qualified mechanics. The industry secret is: if the 120-hour course produced mechanics acceptable to the manufacturers, the manufacturers would not require additional task specific training for so many tasks.

Unexpected complexity of modern light sport aircraft. Light Sport aircraft appear to be basic and simple. But are they? When compared to the general aviation fleet, except for very recent and very expensive composite aircraft, LSA aircraft can only be described as exotic. Almost all LSA have, or ominously could have, systems that were unheard of only a few years ago (and at unheard of prices). Complex avionics, communications and navigation systems, autopilots coupled to sophisticated satellite navigation systems, electronic ignition systems, and carbon composite airframes challenge the cadre of A&P's, let alone the 120-hour LSR-M. LSA repairmen are licensed to install sophisticated autopilot equipment, coupled GPS systems (hands off accurate to meters) and synthetic vision systems that traditional aviation aircraft will never have. There is nothing simple about LSA aircraft, just the opposite.

Type certification vs: ASTM Compliance. There is a new sheriff in town and it's not the FAA. When they created the LSA category the FAA handed off responsibility for policing the maintenance requirements of LSA, but oddly kept the right to approve maintenance schools and mechanics. In the next breath the FAA gave back a portion of maintenance approval authority to manufacturers. So what are the new rules? As far as Light Sport there are no more AD's, TSO's, STC's, or 337's, but there are unlimited letters of authorization and secret service instructions from airframe manufacturers and engine manufacturers. The "rebate" as mechanic qualification control is an interesting concept, as well, and deserves its own treatment. So, who's in charge? Is there any consistency?

Warranty, Insurance, and liability? Pilot for pilot and plane for plane it costs more to insure a light sport aircraft than to insure a similar GA aircraft. When hungry lawyers smell the liability of ill-prepared mechanics they will certainly devour the mechanics available assets. Insurance companies have the deepest pockets. As a result your rates may increase. There are few statistics for LSA because it is so new. Insurance companies have scrambled with high loss numbers to set rates we will pay. If LSR-M rated mechanics are poorly prepared and their work leads to LSA failures, the number of failures will increase with the number of mechanics and the numbers of aircraft available for them to work on. OK, it is a prediction, but one that can be watched and for which we can be prepared. Will Rotax or the airframe manufacturer honor the warranty if you do not hold the proper certificate. Are you subject to FAA enforcement action? Will your insurance company pay if your mechanic can be shown to be poorly trained? Remember, the owner is responsible. I do not recall the 120-hour school discussing mechanic liability insurance.

Engines. Perhaps 90% of light sport aircraft use a Rotax engine. The GA A&P is so ill prepared to service Rotax engines that the engine manufacturer requires engine specific, manufacturer approved training, just to change the oil, let alone more advanced maintenance called for at 100 hours and at annual. It is a wonder, but the 120-hour graduate is authorized by the manufacturer of Rotax engines to change the oil and perform other service level maintenance, forget repairing or even changing engine components that takes more factory approved training. You might say, "But the FAA and ASTM guided manufacturers say the owner/pilot can change the oil." True enough, you can find that in the regs and manuals. However, read the maintenance manual carefully, somewhere in there you will be directed (as in mandatory) to comply with the engine manufacturers requirements and you are back to factory authorized engine training for even the simplest maintenance. That is not a bad thing. But, did your mechanic get adequate training at the 120-hour school?

Parts. The light sport aircraft parts business model includes high expectations of profit. After all, they have you, they wrote the rules (ASTM and consensus, remember?) The economics of scarcity and production control allow seemingly unlimited price gouging. Check out some of those airframe component costs or see how much those authorized engine parts cost. See the insurance comments again. It will be easier and easier to "total" an LSA than to replace damaged components. That drives up your insurance, regardless of how well you fly or for how long you fly. Are you going to let your LSR-M mechanic repair your airframe? Will the manufacture let him do it?

Recurrent training. To maintain an IA rating the mechanic must receive periodic recurrent training. That is how the FAA insures that the skills and knowledge of the inspectors are up-to-date. LSR-M rated mechanics have no such requirement from the FAA. They get their license and they are good-to-go for life. As an aside, The Rotax engine manufacturer has implemented a two-year limit on the engine maintenance license that they issue. Now, do you want an annual inspection of your airframe from someone who may have only attended a weak 120-hour course and has no requirement to update his skills or knowledge? If the FAA thinks that it is good enough for the inspector for a Cessna 150 to get recurrent training, why do they think that it is not necessary for the mechanic who maintains a much more sophisticated airplane?

The category is still new with only its first rules revision in five years, very few in maintenance. Keep good records of your SB compliance work. In another five years the statistical information relating to maintenance by A&Ps, IA's, and LSR-M's will be more informative. If airplanes fall from the sky because of weak, incomplete or inadequate training, we'll know about it. Won't we?

Responsibility. Owners and pilots are responsible for the airworthiness of their aircraft (it says so in the rules) and are responsible for finding and using competent service and repair mechanics. We can improve light sport safety by improving light sport maintenance and improving light sport maintenance training. It is possible to head-off the looming actuarial crash with some improvements in training. My recommendation? More schooling, longer courses, independent qualifications testing, both hands on and written, and required engine and airframe recurrent training of prospective LSA maintenance license applicants and holders. The DAR system works for airworthiness. Maybe it could work for LSR-M qualification, as well. Somewhere along the way someone with independent experience and authority has to qualify our 120-hour school LSR-M work force.

Is something ticking? The aging air fleet has been touted as a safety warning for decades and very old aircraft are still maintained by A&Ps who have thousands of hours of training and experience. Light Sport Aircraft are comparatively new and few. Newer LSA maintained by LSR-M are easy to keep going, when they are new. There's little to fix or adjust on new airplanes, compared to older planes. But what happens as LSA aircraft age and more and more low time mechanics join the LSA maintenance work force?

Improving the system. A waypoint on the return course from this misguided 120-hour adventure is found in paragraph (a)(3)(ii) of 14 C.F.R. Title 14, Part 65, Subpart E—Repairmen "where the repairman has completed formal training that is acceptable to the Administrator and is specifically designed to qualify the applicant for the job on which the applicant is to be employed". The "Administrator" in this case was a bureaucrat with little vision of where his decision could lead. It is not too late to correct this course and the "Administrator" has the authority to do it.

For Light Sport Repairman, Maintenance Rated I have used LSR-M although CFR 14 43.7 (g) suggests RLSM-A. It has little to do with my argument, but can be confusing.

What do I have wrong?

Terry Lytle

“…what do I have wrong?”

Most bluntly, Terry, what you have wrong is your concept of the role of the federal government. The federal government should not be trying to protect us from ourselves.

The reason the FAA chose to allow a lower level of regulation for Light Sport Aircraft is not because they thought the planes are simpler but because with our lower speeds and lighter weights we are much less likely to cause injury to members of the public other the participants, the pilot and his one passenger. Has anyone on the ground ever been hurt by a LSA? I think not.

The government recognized their lower duty of protection toward individuals who choose to participate it what is obviously a dangerous sport.

If you think that flying general aviation aircraft that have been certified by the Feds and maintained by certified repair stations is safe, you are delusional. In my forty years of flying I have had more close friends die in flying accidents than I have bones in my body. However, it seems to me that our light sport accident rate is been better than that of certified light aircraft. And in contradiction to your claim of high insurance rates, mine seem low. In fact, I pay less for my CT insurance than I pay for my sailplane with a similar hull value.

If we don’t have a problem, for god’s sake let’s not ask the government to fix it.

I do not need, or want, the federal government to tell me how often or by whom I should have my airplane serviced or repaired. That’s my business.

And no, I don’t just take my plane to just anyone who has a LSR-M. In fact, I don’t even know if my mechanic has an LSR-M or not. I chose him because I talked to him long enough to be convinced that he knows what he is doing. I couldn’t care less what certifications he has or how well he did in whatever training class he may or may not have taken.

The simple statement that the mechanic should have “task specific training or experience” strikes me as the most profoundly logical regulation I can possibly imagine. Yet you rile against it.

Your comment about our “planes falling out of the sky” was enlightening. Our planes don’t fall out of the sky on their own. If there is structural or control failure, we pull the chute, float to the ground and walk away. If the engine quits we glide to a landing - a landing which is very likely to be successful (defined as being able to walk away) at our low stall speed. Especially where you live in the Great Basin (I’ve landed my sailplane thereabouts at least a hundred times without damage despite its higher stall speed, much longer wing and lower wing tips).

The only way our planes are going to fall out of the sky is by pilot error – not by the mechanic missing a question on his training class quiz. And by the way, though GA pilots are much more prone to stall spin accidents, even the highly trained and certified “pilots” Colgan put in the front seats of flight 3407 still found a way. So don’t think of government certification as some form of inoculation.

As for recurrent training, do you really think your going to forget how to balance the carbs? I’m not an LSR-M but even from the little training I have taken I don’t think I’ll ever forget that. But even if I do, I have my class notes to look back on, and of course, I’ll be working to the latest written procedure anyway. So why should I repeat that training?

As for liability, let me assure you that in the U.S. you will be held legally responsible for any accident that results from work you do, or don’t do, on an aircraft. If you don’t feel comfortable with what you are doing, I wouldn’t do it. Unfortunately, you may also be held responsible for accidents that have absolutely nothing to do with you (as evidenced by the latest findings against Piper (http://www.aopa.org/aircraft/article...WT.mc_sect=tts). If you have deep pockets, I would recommend against a career in aircraft repair.

What’s most amazing to me is where this is coming from. The last time I landed in Eureka there was a high school rodeo between the airport and town. Young men were jumping off galloping horses on to the backs of charging calves, wrestling them to the ground, flipping them over and lashing their feet together. It looked to me like a very dangerous sport. But I don’t think there was any federal agency certifying those horses, or the training they received. And I may be wrong here, but it was my distinct impression from talking to ranchers in the stands that these folks would not have put up with any federal interference. They seemed to epitomize the fierce independence that has always characterized rural areas of the American West.

Mike Koerner