I was told that this is an exemplar of the desired language: "No person may operate the aircraft unless within the preceding 12 calendar months it has had a condition inspection performed in accordance with the scope and detail of 14 CFR Part 43, Appendix D, or other FAA-approved programs, and was found to be in a condition for safe operation. This inspection must be performed by an appropriately rated mechanic, the original builder who holds a repairman certificate for that aircraft, or a certificated repairman (light-sport) with a maintenance or inspection rating for that category and class of aircraft." And that per FAA Order 8130.2, Chapter 15, which covers the "Issuance of Replacement or Amended Airworthiness Certificates," it is an "administrative" amendment to correct or update limitations without requiring re-certification of the hardware.
It's not FSDO-specific language. Like most of the paperwork end of the process, it's standardized. See FAA Order 8130.2L (1/30/2026). This is from my slide comparing the old and the new.
Question, are you dealing with an E-AB that is still in the certification process, or one that that was already fully certified pre-MOSAIC?
Including a chart is an option if the test area is complicated with to avoid, but most often it just says "25 mile radius from XXX airport."
Mine was originally eab certified in 1996.
Perhaps so, or perhaps it's changed with the new op lims? The rep I worked with at the Nashville FSDO wanted a digital sectional with a circle on it.
I am considering purchasing an existing aircraft certificated pre-MOSAIC.
(1) never argue with an 800-pound gorilla, but (2) how can a digital sectional be required if there is no requirement to use digital? (Just my thinking out loud.)
I'm sure there have been lots of changes since then! It raises an really interesting question. Does the amendment to allow condition inspections by an LSRM stand alone or does it trigger a review and potential update of all the Operating Limitations, some of which might be more burdensome or require different data?
The old op lims are discarded. The new op lims, which includes a phase one area and airworthiness certificate, supercedes the old ones.
To be clear, he didn't state it had to be digital. He required it fit on a standard 9x11 page of paper and be legible. I found if I tried taking a picture of a sectional with a 50 nm radius then shrinking it for printing, it wasn't legible and he refused to accept it. The only way I found that worked was to have a digital copy.
I was able to confirm with my FAA contact that the result is a complete new set of limitations. But they say that it should not require new or additional burdens. So, we may be back to how particular FSDOs are handling it.
All three times I've gotten new oplims (including the most recent still in process), it's been a verbal description, no chart required. I guess it's down to the FSDO.
In that I don't think the FSDO has discretion; they have to build a new set of oplims from the latest 8130.2. Sometimes the changes benefit the owner, sometimes they don't.
You are correct. The 8130.2 actually says so.
To be clear, they asked if I wanted to update the phase one area. Of course I did as the plane was new to me. The new op lims last page has the sectional map with circle I created at his request.
AFAIK, nothing. I haven’t looked back that far but my contact explains the changes have historically liberalized requirements and added more detail to what were general statements.
The opportunity is only valid provided the market takes advantage of it and physically buys into. Unfortunately, the Part 91 private recreational market doesn't have good track record with buying in.
I’ve had a few customers try and get their operating limits modified so I could do their condition inspection. The North Texas FSDO has been a problem area for people trying to get it done but San Antonio has been doing them no problem.
I was hoping for some specific examples as the only issues I've heard were concerning the revision of old type OpsLimits where some owners only wanted a line-item type revision. Unfortunately, that is not an option as noted above. So, are you stating that those ASIs are out-right refusing to revise the OpsLimits?
You'll find ASIs in the same FSDO will operate independently. No different than how mechanics come up conflicting determinations even though we all have the same certificate and follow the same rules. While I think a certain level of subjectiveness is important at these levels, if an ASI or A&P opinion cannot be supported by the existing rules, that is something different and should be dealt with accordingly.
I agree, even when using the same guidelines
first off, my poi at the tampa FSDO is great to work with. as to the line item, yes the new system does not let them just update your op-limits. they have to have you input a new request with the whole package. i just went through this with the harvard as they put a limit on it that was not required by the order that I didn't want on there. he agreed that he put it on in error and would have no problem removing it, but said, sorry you will have to submit a new package for me to do it, i just can't remove it with the new system.
