I oppose the weight exemption for the icon aircraft on several grounds:

First, safety, pilots who are used to the handling of an aircraft equipped with “fixed devices” to help 

prevent the onset of stalls but are not familiar with these characteristics at an increased max weight will 

suffer at a higher accident rate at low altitude based to final accidents. Being able to recover from a stall 

is a fundamental of flying and should not be ignored. 

Secondly, manipulation of the system, I believe that many of the supporters of this weight increased 

exemption have ulterior motives. Some of them are equipment suppliers and standard gain financially. 

Others are hoping that this will set a precedent allowing themselves to produce heavier aircraft than the 

LSA rule intended under the guise of safety. This is an example of the all mighty dollar at work, where 

profits precede safety. We should not allow the sacrifice lives of pilots to set a precedent, there are 

mechanisms in place to have the rule changed if that is your desired intention but not by attempting to 

manipulate the FAA. 

Thirdly, potential FTC Anti-Trust Violations, if this exemption is granted it gives Icon Aircraft a 

competitive advantage over every other LSA manufacturer in the industry. In the interest of taxpayers, I 

do not want to see the time, money, and resources wasted debating this issue between these two 

federal institutions. The FAA spent considerable amount of time and taxpayers dollars putting together 

the LSA rules and to disregard them because one company presold or at least took deposits for 700 

aircraft that does not fit into the category in which it was promised is absurd.

Fourthly, the audacity of icon aircraft to ask for 250 pounds for wing cuffs and airfoil shift and presenting 

it to the public and FAA as a new technology that they invented is preposterous. The “Spin Resistance 

Technology”, as they refer to it, has been known for over half a century. Proper design of the aircraft 

would allow them to incorporate their “SRT” within the allowable limit of the existing LSA rule. If you 

refer to the attached “ICON A5TMAircraft Delivery Position Agreement” you will see their standard and 

optional equipment list as follows:

ICON A5 – Amphibious Light Sport Aircraft (S-LSA)

Performance Specifications:

ASTM Standards: Aircraft will meet or exceed the requirements as established by the ASTM F2245 

standard: “Standard for Specifications for Design and Performance of a Light Sport Airplane.”

Seats: 2

Maximum Takeoff Weight: 1430 lbs

Useful Load: 430 - 530 lbs (option dependent)

Baggage: 60 lbs (maximum)

Fuel (Auto Gas or Av Gas): 20 gal

Maximum Speed (Vh): 105 kts (120 mph)

Range: 300 nm

Takeoff & Landing Distance: 750 ft

Engine (Rotax 912 ULS): 100 hp

Standard Equipment:

Retractable landing gear

Manual wingfold

GPS moving map
Analog flight instrumentation (per ASTM LSA standards)

Intercom system

VHF Communication Radio

Mode C Transponder

Standard Documentation:

Pilot Operating Handbook (POH)

Airworthiness Certificate

Weight and balance data

Optional Equipment: (Pricing and Availability to be provided at Production Notice)

ICON Complete Airplane Parachute

Automatic Wingfold

Night Lighting Package

Seaplane Configuration (no landing gear)

Attitude Indicator

Custom A5 Towing Trailer

Glass (LCD) multifunction display

In their petition for weight exemption they make no mention of any of these non-essential and extremely 

heavy features. If they were to remove the non-essential equipment illustrated in ASTM F2245 they 

would be under the allowable existing limit and no exemption for weight would be necessary. Either 

reduce the weight by elimination of unnecessary features or adhere to Part 23 Type Certification.