A new approach to LSA certification

“It’s always been done this way” begins a familiar statement for someone defending a long-standing practice. The reference here is to the nearly 10-year-old category of Light-Sport Aircraft and how these airplanes are permitted to fly across the USA. It is no longer being done the old way and the results are good.

The Sport Pilot/Light-Sport Aircraft (SP/LSA) rule will celebrate its 10th anniversary next year in 2014. After more than a decade of deliberation, the FAA issued the SP/LSA rule at AirVenture Oshkosh in 2004.

The first fully manufactured LSA — called a Special LSA — came on the market in April 2005. Since then, an amazing 132 models have been offered to customers.

While not all these models have found market success, many have established themselves as airworthy, capable, affordable airplanes (at least when compared to other brand new aircraft pilots may consider for purchase).

To say the LSA market has arrived in the world is a gross understatement. The truth is that the new category has so changed the aviation firmament that conventionally certified aircraft may eventually meet similar standards.

So, how is it these aircraft become “certified?”

Welcome to F37

In 2012, ASTM’s F37 committee — the group that wrote and maintains the standards used to gain acceptance for Light-Sport Aircraft — celebrated its 10th anniversary. This worldwide group of mostly volunteers produced — from scratch — specifications for the design, performance, quality acceptance tests, and safety monitoring for LSA. ASTM standards guide the preparation of Pilot Operating Handbooks, maintenance manuals, and a system of Continued Operational Safety Monitoring to advise consumers of maintenance needed to keep their aircraft in good operating condition.

How can a bunch of unpaid people do what FAA is challenged to do with multibillion-dollar budget? Think Wikipedia, the online encyclopedia, and you’ll get the idea. A collaboration of hundreds of laypeople can often accomplish what a committee of experts cannot. They can move quickly and at far lower cost. The committee keeps standards up-to-date much more swiftly, sometimes effecting an important change in as little as 30 days.

One part of the F37 committee — a “task group” working on standards for rocket-deployed whole-airplane parachutes — received an award for creating an approved standard in only six months. In contrast, winning FAA approval for a parachute to be fitted to the government-certified Cessna 150 (an aircraft very similar to LSA of today) took 10 years and cost BRS Parachute more than $2 million. The F37 subgroup did it in six months…with volunteers.

Industry Consensus Standards Work

Under FAA rules for LSA producers, a manufacturer fills out the appropriate application forms and then simply declares that the aircraft meets ASTM standards. When an LSA is ready for delivery, a Designated Airworthiness Representative (DAR) examines the aircraft in an inspection that obviates the need for the factory to qualify for an FAA Production Certificate (another task that can cost millions of dollars).

Nonetheless, even with the good work of a legion of DARs, how does a consumer know a given aircraft truly meets the ASTM standards? Manufacturers are required to conduct annual internal audits under ASTM standards. To reinforce that requirement, the FAA has also been making factory visits to perform highly-detailed audits of standards compliance, manufacturing quality processes, and adherence to applicable regulations.

Today, most companies take steps to assure full compliance when — and if — the FAA should announce its intention to visit. Companies use internal procedures and help from industry organizations like the Light Aircraft Manufacturers Association (LAMA) to work through the ASTM standards set line-by-line. Consultants versed in the 10-year-old process are now available to assist companies in meeting the standards and keeping the right actions in place to maintain the airworthiness of their aircraft.

What is the proof of their success? The FAA considers the safety of LSA to be “acceptable,” to quote the word often used by agency personnel. Indeed, while some accidents are inevitable due to factors beyond the control of the manufacturer (pilot error and weather, among other reasons), LSA have demonstrated a positive track record.

Here is a key statement: The FAA would not be working with the giants of the aviation industry to create similar standards for Type Certified aircraft if the administration could not point to success among LSA.

Worldwide Phenomenon

Individuals from many countries work on and understand these standards. Why? Isn’t this just a U.S. regulation? LSA sold in America are often imported, so those overseas companies need to meet the standards FAA accepts. More importantly, ASTM standards are increasingly accepted in other countries, meaning a company meeting them once can sell their aircraft in a growing list of other nations. This also saves millions.

F37 is presently composed of more than 200 members typically participating in two to three days of technical meetings twice per year. The committee meets both in America and abroad. Other meetings occur through electronic gatherings facilitated though the Internet. Those hard-working volunteers are guided by knowledgeable ASTM staff members experienced in writing standards. ASTM rules prevent any company or government agency from dominating the actions of the committee.

While maintaining several major standards and creating new ones, the F37 committee pushed ahead with a fresh innovation, building an all-new standard for electric-powered aircraft even before the FAA permits such propulsion. Work continues on a new standard for instrument flying.

The actions of this group of volunteers has inspired the FAA to continue with letting industry guide design requirements. Some might say this is the free market at work.

Comments

  1. says

    “When an LSA is ready for delivery, a Designated Airworthiness Representative (DAR) examines the aircraft in an inspection that obviates the need for the factory to qualify for an FAA Production Certificate (another task that can cost millions of dollars).” This is nearly the same as “production under a type certificate”, FAR 21 sub-part F 21.123. This regulation allows production under only a Type Certificate for up to six months with a conformity inspection of each article. After six months the production certificate is required, however as with most of the FAR’s there is an out to that as well as the phrase “unless otherwise authorized” is included in the regulation. The regulation itself allows production indefinitely under only a T.C. the bureaucrat at the FSDO or ACO office may not, through local policy. It is much like a “field approval” still acceptable but nearly impossible to get from the local office depending on there personnel.

  2. says

    The comment I offer may concern potential owners of LSA’s. The S-LSA performance is tailored differently than that the E-LSA aircraft. The FAA has found that any number of the manufacturers have failed to adequately test to the ASTM standards they certify to. You need to look at the accident reports. Cessna even found it was difficult to get the performance and safety they were looking for in the area of safety. During design those manufacturers need to do more during development; i.e., spins and unusual attitudes must be investigated, not just “want this to be an end result.” Placards prohibiting such maneuvers doesn’t stop them from occurring. For every regulation written there was a body count.
    In regards to the job of the FAA-DAR. That person doesn’t or shouldn’t inspect quality into the manufactured product. That task if the ‘responsibility’ of the manufacturer’s quality and shop disciplines during the assembly process. To meet the ASTM the manufacturer must certify via FAA 8130-15 statement of compliance and their records, that they manufactured and inspected the end product before calling for the FAA’s issuance of the CofA.

  3. Richard says

    Meanwhile the FAA sits on it’s hands while the EAA and AOPA file for an exemption to allow similar medical requirements for similar aircraft that are only slightly heavier than the ARBITRARY 1320 pound limit they put in the LSA design.

    Not totally arbitrary, they just grabbed that number because it is close to the 600KG limit used in Europe.

    Hopefully soon, the EAA /AOPA exemption will be allowed unless the FAA is holding the outcome of the lawsuit to recover the nearly 500 million dollars they exhorted from the EAA, hostage.

  4. Joe says

    I’m with Richard!! General Aviation will benefit more from the AOPA/EAA initiative to make Sport Pilot standards include Recreation Pilot standards to get the fleet of currently “grounded” aircraft back in the air. Just think of the money us old folks will spend on our 180 hp and under planes if we could fly without a medical. General aviation as a whole will benefit and folks will still buy/fly the current LSA planes because it is an easy way to get into the air. FAA….. Please act to help aviation!!

  5. Richard says

    Now, if the FAA would get off of their duffs and change the gross weight and speed limitations for LSA to something a little more reasonable, things would be looking even brighter.

    • W lowen says

      Speed limitation of 120 knots is silly. WHY 120 knots ? To meet European standards. If the aircraft meets landing and stall criteria why burden us with any speed limitation ?
      The same for gross weight of 600 kilos
      (1320lbs). Not much of a thought process to just copy a standard that has no relavance to flying equipment in the USA.

      • Phil G says

        The LSA standards where designed to stimulate new manufacturers entering the market, if the C152 was allowed to be LSA no one would buy new planes…

        • Greg says

          No one is buying new planes because most of the population can’t afford to drop 100k on what, for most people, is a luxury toy.

          You want to save GA? Do two things. . .

          Make it Cheaper (So that those of us living in the Median Income Range in the US at about $51,000, can still afford a house and to fly more than one hour/month)

          Make it more accessible (i.e. eliminate the class 3 medical and go with the Drivers License standard for all non-commercial flying).

          You do those two things, and you will see a resurgence in GA. People will start renting planes more often, those that rent planes will buy new planes more often. . . New Pilots will seek more and better certification levels. . . so on and so forth.

          • Phil G says

            You get that with LSA, just have to accept a tube and fabric future with tube and fabric budget. Plenty of E-LSA planes out there

  6. Jim Hausch says

    An excellent summary and recap. Thank you.

    I am marginally exposed to the output of ASTM committees in the machine safety world. These committees are often made up of engineers from competing companies.

    One great thing they do is NOT say, “this is how you must to this”; but, rather, “we want this to be the end result”. The effect is that people are free to innovate to solve a problem.

    I sometimes imagine an engineer at a company with a unique solution working to get the end-result of their solution written into the standard. This, in effect, throws down the rhetorical gauntlet to the others by saying, “we aren’t going to tell you HOW we did this, but if you can think of another way to accomplish this same end result, go for it!”

  7. Mike Marthaller says

    A glimmer of light on a dark aviation horizon.

    Possibly an example for all industries being crushed by over regulation.

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