07/18/2012 11:03 9254260771



### July 19, 2012
DEPARTMENTOFTRANsPoRTATION 

### FrankP. Paskie'Wicz, Deputy Director, AircraftCertificationService Richard Posey Federal AviationAdministration Regarding: DocketNo. FAA-2012-0408 DocketOperations,M-30 U.S. Department

### ofTransportation LBURKELAMA



### 1200 NewJersey AvenueSE., WestBuildingGround Floor, Room**W12~140**

### Washingto~ 

## De 20590-0001.
DearSirs: PAGE 01



### cc



### TheUghtAircraftMan:ufa.ctu:rers Association (LAMA) ispleased to attachourcomments on the above-referenced document.
Thesecommentswere prepared

### by ourChairmanEmeritus

### Larry Burke andhiscomments have beenreviewedand approved

### by

### myselfas PresidentandChairmanofthe Board.
I addmycommendationtotheFAAfor a well-considered policy and urge you tofurther 

### consider thecomments Mr. Burkemakes onbehalfoftheLight·SportAircraft

### producer community.


### Thankyou

### andbestregards,

DanJohnson LAMApresidentandchairmanoftheboard W'W'W.LAMA.bz & 

### www.LAMAeurope.com07/18/2012 11:03 9254250771 

### LBURKELAMA

FAX TRANSMITTAL 202-493-2?.51

DEPARTMENT OF TRANSPORTATION Frank P. Paskiewicf., Deputy Director, Aircraft Certification Service Federai**A~~ation** Administration Richard Posey Federal Aviation Administration Washington, DC Regarding: Docket No. 

### FAA-2012-0408
Docket Operations, M-30 U.S. Department of Transportation 1200 New Jersey Avenue SE., West Building Ground Floor, Room W12-140 Wa.shington, DC 20590-0001.**~SSUANCE** 

### OF SPECIAL AIRWORTHINESS CERTIFICATES FOR LIGHT-SPORT CATEGORY AIRCRAFT:**DE~ar** Sj.rs: i The Light Aircraft Manufacturers Association (LAMA) commends FAA on their field assessments and reporting same to the Light-Sport Aircraft (LSA) Community.
We also commend 

### FAA ori Docket No. FAA-2012-0408 as a thorough definition 

### PAGE 02

1 about what it requires to qualify as a manufacturer of light sport aircraft,

and to demonstrate the necessary compliance and controls required to meet the ASTM LSA**standard~.** LAMA is proud to note 

### that those manufacturers that 

### we have assisted w:lth our ASTM standards compliance check lists, and quality assurance guidance have usually fared weJ.J. during the FAA field assessments. It has concerned us that 

### we could not reach more of the LSA community, and unfortunately those that we have been unable ·to reach, have cal.lsed the· FAA to note that several of t.he JJSA manufacturing community that were assessed by the FAA were not in compliance with 8130-15. -However, 3ome**thing~** are not cl¢or- to r..AMA**a~** to the meaning o£ oe:r.tain phrases, and considering that the 

### FAA has but assessed about 

### 16% of the LSA manufacturing community, we and the cornmunity do not think the FAA comments using phrases J..ike "the majority" of the community not in compliance are representative of actual facts although 

### we acknowledge "the majority" 

### is followed later by "of the manufacturing facilities· evaluated," which to some extent mitigates the statement. In addition, we suggest that the :E"AA emphasize that several of those manufacturers upon the first field visj.t that did not have all the required documentation were late.r. able to demonstrate full compliance with 81.30-15. We suggest these changes because correct or not', the media has trumpeted the LSA community as faulty, and unfortunately, some of the 

### FAA field offices are picking up on the "majority

...not in compliance" phrase, and refusing to grant airworth1.ness certificates to manufacturers whose complia.nce 

### has not been eva.J.uated.07/18/2012 11:03 9254250771 LBURKELAMA PAGE 03

As an example of this latter issue, we call your attention to Pipistrel Aircraft, which presently is denied EJ**sr~sA** airworthiness certificate by more than one 

### FAA f:l.eld office because of the 

### FAA posit:i.on on "non-compliance."


### We .strongly support the emphasis upon continuing airworthiness, and the need for vigorous a.nd. ever watchful and expeditious correction of field findings. We share with the 

### FAA that continuing airworthiness is one of the key elements to**~afe ope:rt1t~.on**  of the l·SA fleet. However, we do not understand what the FAA means by "provided all other requirements are met," regard1:ng the statement about "those aircraft issued airworthiness certificates prior to the ef.feotive date of FAA-2022-0408 will not be affected by this policy."
We ask that thi.s "requirements" statement be clarified, for it presently is subject to wide interpretation that may not be what was meant by 

## FAA.

It is particula:r.ly troublesomoa, for it conflicts with our next suggest.ion regarding retention of airworthiness ce:r.:tif:i.cates by the p:resent J.,SA fleet.
We object to the suggested limitations regarding eligibility for SLSA aircraft to retain their SLSA airworthiness certificates.
We propose to make it less restrictive, but still maintaining the expected level of field safety of operations.
Here is what we propose: That any entity, be j.t a manufacturer, distributer, or retail sales,· training facility, FBO or o·ther recognized aircraft rela·ted entity that has in place an aggressive and watchful continuing airworthiness activity per**t~e** appropriate ASTM Standard, and that has th.e abj_lity to provide expeditious and good engineering corrective action of field safety items, and upon inspection by the FAA and to the satisfaction of the FAA shaw that this activity can be SIJstaJ.ned, then these LSA be allowed to retain their SLSA airworthiness certificates. Not all other requirements will have to be met; 

### only continuing airworthiness will be requi.red for those aircraft already i.ssued their SLSA airworthiness certificate. LAMA ba.ses this**sugg~stion** upon the present acceptable safety record of the current LSA fleet, and the fact that the SLSA aircraft have generally been operated with reliability and safe flight. Having inspected several overseas and domestic LSA manufacturers, and carefully reviewed their documentation for compliance, and reviewed the documentation that is required to be with the aircra.ft, us;f.ng the LAMA QA and compliance check lists, LAMA sees no increased**ri~k** of. continuing to allow to ope**.~e** an to retain their SLSA airworthiness certificate those LSA .aft he flee a proper backing of continuing airworthiness.