07/18/2012 11:03 9254260771 

July 19, 2012 

DEPARTMENT OF TRANsPoRTATION 

Frank P. Paskie'Wicz, 

Deputy Director, Aircraft Certification Service 

Richard Posey 

Federal Aviation Administration 

Regarding: Docket No. F AA-2012-0408 

Docket Operations, M-30 

U.S. Department of Transportation 

LBURKELAMA 

1200 New Jersey Avenue SE., West Building Ground Floor, Room W12~140 

Washingto~ De 20590-0001. 

Dear Sirs: 

PAGE 01 

cc 

The Ught Aircraft Man:ufa.ctu:rers Association (LAMA) is pleased to attach our comments on 

the above-referenced document. 

These comments were prepared by our Chairman Emeritus Larry Burke and his comments 

have been reviewed and approved by myself as President and Chairman of the Board. 

I add my commendation to the FAA for a well-considered policy and urge you to further 

consider the comments Mr. Burke makes on behalf of the Light·Sport Aircraft producer 

community. 

Thank you and best regards, 

Dan Johnson 

LAMA president and chairman of the board 

W'W'W.LAMA.bz & www.LAMAeurope.com 
07/18/2012 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.