Major Repair/Alteration Authorization
We know that you have all diligently read your aircraft’s Pilot Operating Handbook but we are certain that you will not object to being reminded that the introduction states that, “The airplane must be maintained in accordance with consensus standard ASTM F 2295 Standard Practice for Continued Operational Safety Monitoring of a Light Sport Aircraft. Please note that this standard describes the responsibilities of the Owner/Operator.”
We thought that it would be useful for you if we distilled what this means in practice. By the way, the standard can be purchased from ASTM:
http://www.astm.org/Standards/F2295.htm.
Operation of an S-LSA aircraft is different from a normal general aviation aircraft (what we would call a Part 23 airplane). In the S-LSA world, Cub Crafters, is obliged to control the design and ensure that it meets the requirement of the ASTM design standard (ASTM F2245). There are important differences when it comes to making major repairs or alterations to S-LSA aircraft. In the Part 23 world, a major alteration or repair is approved with a form 337 or an STC. Mechanics are trained to follow these procedures and there are guidelines that tell the mechanic how to distinguish between major and minor alterations and repairs. The procedures in the S-LSA world are different. The airplane’s maintenance manual describes the repairs and alterations that may be done on the field and gives the qualifications of the mechanics who are authorized to perform them. For any other work, the owner must obtain a “Major Repair/Alteration Authorization” (MRA) from Cub Crafters. For that there is an MRA form that resembles a 337.
To put the previous paragraph more simply, a major repair or alteration can be done on an S-LSA if it is described in the maintenance manual. Otherwise, you must obtain an MRA from Cub Crafters.
For Cub Crafters to support major repairs and alterations involves having appropriate infrastructure. As you will appreciate, this implies significant resources and expenses. Therefore, we have had to develop policies and procedures to ensure a timely flow of work and in certain instances, recovery of costs.
Any kit shipped that is part of a service bulletin or service instruction will be shipped with an MRA. The cost of the MRA will be included in the price of the kit. If an MRA is needed to support warranty, an MRA will be issued at no cost. In all other cases, there will be a
charge at a rate of $95.00 per hour. We will do our best to estimate the time required to complete an MRA, but given the variety and complexity of these jobs, we must charge actual time.
The MRA is specific to the aircraft being modified. A sample is posted on our website. Once the work has been completed the original must be returned to Cub Crafters.
You will notice that these instructions are specific to S-LSA aircraft. Owners of E-LSA aircraft are legally responsible for ensuring the continued airworthiness of their aircraft, Cub Crafters has no legal responsibility for E-LSA aircraft though our normal warranty applies and we will certainly provide guidance with unmodified aircraft in the normal manner.
Continued Operational Safety of S-LSA aircraft-Major Repair/Alteration Authorization
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