# Light-Sport Aircraft Manufacturers Assessment (LSAMA) 

# F INAL 

# R EPORT

Production and Airworthiness Division, AIR–200

May 17, 2010Light-Sport Aircraft Manufacturers Assessment

― Final Report

5/17/2010 Page ii 

## DISCLAIMER
This document is disseminated under the sponsorshi p of the U.S. Department of Transportation in the interest of information exchange. The United States Government assumes no liability for the contents or use thereof. The United St ates Government does not endorse products or manufacturers.Light-Sport Aircraft Manufacturers Assessment

― Final Report

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### T ABLE OF 

### C ONTENTS
EXECUTIVE SUMMARY ............................................................................................................ IV
INTRODUCTION ..........................................................................................................................1 1.0 Back ground................................................................................................................ .......................1 1.1 Scope..................................................................................................................... ...........................1 1.2 Me thodol ogy ............................................................................................................... ......................2 1.3 Organization of Analysis in the Data Analysis/Discu ssion Section .................................................6
DATA ANALYSIS/DISCUSSION .................................................................................................8 2.0 Analysis

― General Overall............................................................................................................... 8 2.1 Continued Airw orthiness System............................................................................................ ........11 2.2 Product Conformi ty to Regulations......................................................................................... ........13 2.3 Manufacturer Extens ion/Distributor Assemb ly Procedures and Documentation System...............14 2.4 Compliance to ASTM Design Standards ....................................................................................... .16 2.5 Manufacturer’s Quality Systems............................................................................................ .........18 2.6 Maintenance Procedures and Documentat ion System ..................................................................19 2.7 Manufacturer’s Fa cility Ques tionnaire ..................................................................................... .......21 2.8 Other Data ................................................................................................................ ......................22
APPENDIX A. ACRONYM LIST..................................................................................................1
APPENDIX B. GLOSSARY.........................................................................................................1
APPENDIX C. PARTICIPATING OFFICES ................................................................................1
APPENDIX D. FIGURES .............................................................................................................1

### E XECUTIVE 

### S UMMARY

This report presents the result s of the Light-sport Aircraft Ma nufacturers Assessment (LSAMA), (herein referred to as assessment and team). This executive summary briefly discusses the assessment team’s analysis, conclusions, and re commendations based on data collected during the assessment.


### B ACKGROUND During the 2008 Experimental Aircraft Associ ation (EAA)/Federal Av iation Administration (FAA) Recreational Aviation Summit, the FAA Airc raft Certification Service, Production and Airworthiness Division (AIR–200) ag reed to assess the current stat e of the light-s port aircraft (LSA) industry. AIR–200 chartered and spons ored an assessment team, comprised of individuals from several offices with in FAA Aviation Safety (AVS).


### G OAL The assessment team’s goal was to review curr ent LSA manufacturing industry systems and processes through on-site evaluati on, analysis, and reporting. Th e team was also tasked to recommend enhancements to industry cons ensus standards for LSA design, manufacturing, continued airworthiness, and maintenance and FAA processes and procedures. The team’s methodology was to collect data from LSA manu facturers, including their extensions and distributors, located in the United States. Th e team collected data on LSA industry compliance with applicable regulations, sta ndards, and existing processes.


### M ETHODOLOGY The team developed survey questions and data ga thering tools, performed evaluations, analyzed collected data, and developed conclusions and recommendations. The team designed the questions to evaluate the LSA industry’s understanding and applica tion of applicable regulations, standards, processes and proce dures. The team developed co nclusions and recommendations based on the analysis of the collected data, team observations, and comments and suggestions of individuals the team intervie wed during the assessment.
The team evaluated 14 manufactur ers, including their extensions and 16 distributors. This sample of 30 LSA facilities established a 93 per cent confidence level that the results of this assessment represent the LSA industry as a w hole. The assessment surveys began in September 2008 and were completed in March 2009. The assessment survey participants were cooperative and provided unrestr icted access to their LSA faci lities. They exhibited a willingness and desire to build and promote safe LSA.

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### C ONCLUSIONS This report identifies four areas that need minor to significant improvement. Deficiencies vary from facility to facility, by degree, quantity, and type.
1. Compliance with FAA-accepted consensus standards

. The majority of LSA facilities surveyed could not fully demonstrate their ability to comply with certain consensus standards. The asse ssment indicates that manufacturers are making statements of compliance for aircraft that may not fully meet certain consensus standards. We have concluded that relying solely on the manufacturer’s statements of compliance, for the issuance of airworthiness certif icates, should be reconsidered.
2. Implementation of manufacturing systems

. Some manufacturers have failed to implement wi dely accepted internal quality control and production procedures that are necessary to assure minimal compliance to the ASTM consensus standards. Many manufacturers also lacked corrective action systems used to address systemic deficiencies. Further compoun ding this scenario is the fact that current consensus standards identify only minimum requi rements without a systems-based approach which only exacerbates procedural and record ke eping weaknesses. We conclude that these lack of controls may result in the producti on and distribution of such poorly documented aircraft that it may be very di fficult to verify conformity.
Distributors have not deve loped and implemented manufact uring and quality system procedures for many of the tasks they perf orm. When distributors perform assembly, inspections, and other functions, they seldom use the manufacturers’ procedures, records, or controls. The consensus standa rds do not require distribut ors to use process control procedures and as a result, di stributors have only partial ma nufacturing and quality system procedures and associated records. We concl ude that the consensus standards need revision to require documented controls and processe s for assembly and other production functions that distributors perform pr ior to airworthiness inspections and flight.
3. Understanding FAA regulatory requiremen ts, policy and guidance, and industry consensus standards

. We conclude that industry and FAA desi gnees have inadequate knowledge of FAA regulatory requirements and policies and ASTM/industry consensus standards. The evidentiary factors for this conclusion include : (1) inadequate applic ation of manufacturing process procedures necessary to establish eligibility, (2) misinter pretations of the intent of FAA regulatory requirements, policy and guida nce, and industry consensus standards, (3) misinterpretations of overall roles and res ponsibilities of the va rious industry entities (manufacturers, their extensions and dist ributors), (4) non-standardized methods and sequencing of airworthiness cer tification, and (5) un certainty of appropriate contacts for needed guidance.

5/17/2010 Page v5/17/2010 Page vi 4. Industry’s system for managing, assessing, and maintaining the effectiveness of the consensus standards

. The industry does not have a means to comm unicate with manufacturers on how to comply with the requirements of the consensus sta ndards. We conclude that the process for evaluating compliance with the standards a nd taking corrective action needs significant improvement. Additionally, the process for maintaining and updating consensus standards needs improvement.


### R ECOMMENDATIONS The team developed its recommendations base d on data analysis, conclusions, trending indicators, and industry responses to a questionnaire. Specific recommendati ons are located in section 2.1 through 2.8 of this report, and the fo llowing summarizes those recommendations:
Industry

 Take immediate steps to fully comply w ith FAA regulatory and consensus standard requirements.

 Standardize the continuous airworthiness notification pr ocess for all LSA types.

 Develop training to ensure industry fu lly understands FAA regulatory and policy requirements, and the methods and means to comply with those requirements.

 Establish periodic meetings between FAA and industry to work toward full compliance to FAA regulatory and consensus standard requirements.

 Conduct an initial conformity inspection of all first-time-manufactured LSA models.

 Continue assessments of manufacturer s, extensions, and distributors.

 Review current accepted consensus standards for adequacy and revise existing standards or create new standards where necessary.

FAA

 Update existing policy (Advisory Circulars and Orders) pertaining to airworthiness certification requirements, registratio n marking, and designee management.

 Update Designated Airworthiness Repres entative(s) (DAR) and advisor training.

 Establish a process to receive safety alerts , directives, and other pertinent information.

 Continue oversight of th e LSA manufacturers to a ssure compliance with FAA requirements and ASTM consensus standards.

### I NTRODUCTION 

### 1.0 B ACKGROUND 1.0.1 Light-sport Aircraft Manufacturers Assessment On July 16, 2004, the Federal Aviation Administ ration (FAA) issued a new rule for the manufacture, certification, operation, and maintenance of light-sport aircraft (LSA), which became effective September 1, 2004. LSA have a maximum takeoff weight of not more than 1,320 pounds (1,430 pounds for aircraft intended fo r operation on water) and are heavier and faster than ultralight vehicles. LSA include ai rplanes, gliders, balloons, powered parachutes, and weight-shift-control aircraft. Adoption of the ru le was necessary to address advances in sport and recreational aviation technology, lack of appropriate regulations for existing aircraft, several petitions for rulemaking, and petitions for exemptions from existing regulations. The FAA adopted the rule to provide for the manu facture of safe and economical aircraft that exceeded the limits previously allowed by ultralight aircraft regulations. The rule also allows certificated pilots to operate these aircraft for sport and recreation, carry a passenger, and conduct flight training and towing in a safe manner. In January 2008, the FAA established the LSA Ma nufacturers Assessment to evaluate the health, state of systems implementation, and compliance of the LSA industry as a whole. Specifically, the goal of the assessment was to assess current LSA industry manufacturing systems and processes through on-site evalua tion, analysis, and reporting under a continuous improvement process, and to provide recommenda tions to enhance aviation safety.

1.0.2 Assessment Team AIR-200 chartered and sponsored an assessment t eam. The team comprised individuals from AIR-200, the Aircraft Engineeri ng Division (AIR-100), the Intern ational Policy Office (AIR-40), Flight Standards Service, Aircraft Mainte nance Division (AFS-300), and the Aircraft Certification Service Small Airplane Directorat e (ACE-114). A listing of these participating offices is provided in appendix C to this repor t. The team was res ponsible for developing assessment questions and data gathering tools, performing evaluations, analyzing data, and developing conclusions and recomme ndations. All items were deve loped with team consensus. The team also developed a team operating agreemen t, which outlined steps to take if a significant safety issue requiring immediate acti on was discovered during an evaluation.


### 1.1 S COPE The team collected data from LSA manufacturers, their extensions, and distributors, which are individually and collectively referred to as “LSA facilities” in this report (see appendix B, Glossary). The assessment collected relevant data on LSA industry compliance with regulations, standards, and processes. The team used the data collected to evaluate and report on the

5/17/2010 Page 1LSA industry as a part of FAA safety oversig ht. The FAA di d not use the assessment and evaluation of collected data for individual li ght-sport manufacturer compliance audits.


### 1.2 M ETHODOLOGY 1.2.1 Determination of Sample Size and Selection of LSA Facilities A representative sample size of LSA facilities and of associated confidence levels were calculated as part of th is assessment. Calculations were based on the total population of LSA facilities within the United States as of June 8, 2008 (52). This information was obtained from the EAA Web site. A graphical breakdown of faci lity types is presente d in figures 1 and 2.

Airplane / Glider, 42, 80% Weight-shift, 5, 10% Powered parachute, 5, 10%

Figure 1 – Facility by Aircraft Type

US, 17, 33%

Foreign, 35, 67%

Figure 2 – U.S. vs. Foreign Facilities

5/17/2010 Page 25/17/2010 Page 3 Population = 52 The sam ple size was determined by performing cal culations based on various confidence levels, assuming a standard distribution. No differentiation was made for facility t ype or aircraft type. The calculations consider confidence level, degree of variability, and sample precision. Table 1 presents the confidence levels and associated sa mple sizes. Calculations were based on choosing a degree of variability of 30 percent and sample pr ecision of 10 percent. An initial confidence level of 92 percent was chosen for the assessment; this corresponded to evaluating 29 LSA facilities. However, the team evaluated an additional facility, providing an overall confidence level of 93 percent based on the LSA facility populatio n as of June 8, 2008. This confidence level corresponds to a 93 percent confidence that the resu lts of this assessment represent the LSA industry as a whole. To minimize travel, the team chose survey locations in specific geographic areas. The team evaluated LSA facilities in Florida (nine), Ge orgia (three), North Carolina (four), California (three), Wisconsin (three), Michigan (four), Texas (two), Virginia (one), and Connecticut (one), including 14 manufacturers and manufacturer extensions, and 16 distributors. Each evaluation was a 1-day event. Two- to four-person teams composed of members from the team conducted the evaluations. Confidence Level Sample Size 98% 36 95% 32 93% 30 92% 29 90% 27 75% 18 50% 8 25% 2 10% 1 Table 1. Sample Size Determination

1.2.2 Assessment Questions The team developed 156 questions to evaluate how the LSA industry understands and applies applicable regulations, standards, and processes. The majority of questions were based on the FAA-accepted ASTM international consensus sta ndard requirements (formerly the American Society for Testing and Materials) (referred to in this report as ASTM consensus standards). Some questions were designed to evaluate the application of curre nt best practices used in the aviation industry. 1.2.3 Assessment Question Grouping The team grouped the questions into six major sections for data collection and analysis:

 Continued Airworthiness System

 Product Conformity to Regulations

 Manufacturer Extension/Distri butor Assembly Procedures and Documentation System

 Compliance to ASTM Design Standards

 Manufacturer’s Quality Systems Maintenance Procedures and Docum entation System The team further identified subtier categories of questions within each major section.

1.2.4 Data Collectio n and Analysis Process The team used both formal and informal data collection methods during this assessment. The methods included auditing techniques, intervie wing, and soliciting comments and suggestions. Most answers to questions were scored on a 0 to 5 scale. Scores were totaled and averaged. Because the team derived questions for specific LSA subjects, each question did not necessarily apply to every facility. Questions the team determined were not a pplicable (N/A) to a facility or not evaluated were not scored with a numerical value and were not included for determining averages. An example question worksh eet is provided below (figure 3).

5/17/2010 Page 4Figure 3. Sample Question WorksheetPage 51.2.5 M anufacturer’s Facility Questionnaire In addition to gathering data based on specifi c questions, the team ga ve the assessed LSA facilities an opportunity to cont ribute information they considered important. During each assessment, the team gave a representative of th e facility a Manufacturer’s Facility Questionnaire and return envelope addressed to AIR-200. Befo re the start and during the out brief of each assessment, the team requested that the repr esentative of the LSA facility complete the questionnaire and return it to the FAA as soon as possible. The team also asked the LSA facility representative to comment on the questionnaire regarding any aspe ct of the assessment and about LSA in general. The results of the qu estionnaire are disc ussed in section 2.7.

1.2.6 Data Limitations This report presents data collected during the assessment and selected discussion. The following must be considered when reviewing the data: The team was tasked with assessing LSA ma nufacturers. However, in conducting the assessment, the team discovered that over half of the participants we re distributors.
The assessments were limited to LSA facilit ies located in the United States, but many LSA aircraft involved in the asse ssment were designed and/or built in foreign countries for sale in the United States (that is, over half of the participants were distributors of foreign designed/built aircraft). The assessment included 156 total questions; howev er, the number of que stions answered by individual participants ranged from a low of 10 to a high of 130 (the average number of responses was a fraction over 87). Examples of the reasons for this follow:

 Distributors frequently coul d not respond to design or manu facturing-specif ic questions, especially if the design or manufacturing activities took place in a foreign country,

 Some questions were tailored to very speci fic activities (for example, assembly by distributors) which were not co mmon to all participants, and

 Some questions asked about specif ic types of aircraft (for ex ample, airplanes) that could not be answered by manufacturers/distributors of other aircraft types (for example, powered parachutes). Assessment results related to types of aircraft must be viewed rela tive to the number of respective participants. For example, the a ssessment included 22 airplane manufacturers/ distributors and two glider ma nufacturer/distributors.


### 1.3 O RGANIZATION OF THE 

### D ATA 

### A NALYSIS 

### /D ISCUSSION 

### S ECTION Each of the paragraphs in the Data Analysis /Discussion section is presented using the same format: data presentation, data analysis , conclusion(s) based on the analysis, and recommendation(s) based on the conclusion(s).

5/17/2010 Page 6The Data Analysis/Discussion section is organized using a tiered approach. An outline is provided below: Analysis

― General Overall, Section 2.0

 Continued Airworthiness System (CA), Section 2.1
o General Discussion – CA

 Product Conformity to Regulations (PCR), Section 2.2
o General Discussion – PCR

 Manufacturer Extension/Distri butor Assembly Procedures and Documentation System (MEDAPD), Section 2.3
o General Discussion – MEDAPD

 Compliance to ASTM Design Standards (CDS), Section 2.4
o General Discussion – CDS

 Manufacturer’s Quality Systems (QS), Section 2.5
o General Discussion – QS

 Maintenance Procedures and Documentation System (MPD), Section 2.6
o General Discussion – MPD

 Manufacturer’s Facility Questionnaire, Section 2.7
o General Discussion – Manufacturer ’s Facility Questionnaire
o Manufacturer’s Facility Questionna ire Results – Analysis Summary

 Other Data, Section 2.8
o General Discussion – Other Data
o Specific Analysis – Other Data The Data Analysis/Discussion section first presents a general overview. The narrative presents analysis, conclusions, and recommendations that apply to all of the major groups together. The next level of discussion applies to each majo r group. It begins with a general narrative that summarizes a major group, followed by overall conc lusions and recommendations that apply to the major group.

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### D ATA 

### A NALYSIS 

### /D ISCUSSION 

### 2.0 A NALYSIS 

### ― G ENERAL 

### O VERVIEW The FAA conducted this assessment at 30 manufact urers, extensions, and distributors. All provided unrestricted access to th eir LSA facilities. During the interviews the participants were cooperative and willing to answer questions to the best of th eir ability. The LSA facilities involved significantly contribu ted to the successful comple tion of this assessment. This report recommends corre cting and improving several di fferent areas of the LSA manufacturing industry and FAA po licy and guidance. Many of the companies surveyed during this assessment exhibited exubera nce and confidence in their cont ribution to the LSA industry. There is a willingness and desire, regardless of experience level, to build and promote safe LSA.
The recommendations below reflect a summary of the individual and section recommendations presented later in this report. Furthermore, the conclusions co me from a consideration of how the individual sections support each other. Graphical data is presented in Appendix D of this report. NOTE: There was not a significant difference in the overall average scores between distributors, manufacturers and extensions, and all LSA facilities. 2.0.1 Compliance A review of the overall results indicates that a majority of LSA manufacturers could not fully demonstrate their ability to comply with FAA regulatory and policy requirements. The section summaries indicate that the manufac turer’s ability to demonstrate co mpliance varied a great deal.
Conclusion : LSA manufacturers could not fu lly demonstrate compliance to FAA regulatory and policy requirements.
Recommendation : LSA industry should take immediate steps to fully comply with FAA regulatory and policy requirements.
Recommendation : Industry should es tablish periodic meetings to work towards full compliance with FAA regulatory and policy requirements. 2.0.2 Initial Conformity Check Most of the aircraft reviewed dur ing the assessment exhibited deficiencies in the ability to fully meet basic requirements in certain ASTM consensus standards. Therefore, an initial standardized evaluation should be conducted for all first-tim e LSA models. The initial acceptance evaluation should include document revi ew, manufacturing reco rd review, audit of compliance to standards, and special light-sport aircraft (SLSA) conformity inspection. The evaluation should inspect aircraft and verify whether they meet applicable FAA-accepted

5/17/2010 Page 8consensus standards, 14 CFR part 21 rules, a nd any LSA-related polic y and guidance. The evaluation should encompass all requirem ents of the applicable standards.
Conclusion : LSA evaluated as a part of this as sessment did not fully conform to certain FAA-accepted ASTM consensus standards.
Recommendation : LSA manufacturers should conduct an initial conformity inspection of all first-time-manufactured LSA models, in cluding standards, any regulatory required documentation and records review, along w ith an SLSA conformity inspection. Airworthiness certificates should not be issued until all issues are resolved. 2.0.3 Oversight A review of the data identified that many assessed LSA facilities did not fully comply with ASTM consensus standards in the area of continuous oversight. Manufactu rers, their extensions and distributors could not show that they adhe re to all consensus standard requirements. Additionally, many LSA facili ties had no process in place to conduc t external or internal audits. For those LSA facilities that did have audit pr ograms in place, there was no corrective action process to address audit findings. To assure compliance, a light-spor t manufacturer oversight program with periodic evaluations of LSA manufacturers, their extens ions and distributors should be considered. The evaluation should sample design elements, quality system elements, continued airworthiness system procedures, marking requirements, production co ntrol systems, and maintenance publications applicable to LSA. An oversight program shoul d evaluate those items against the appropriate FAA-accepted consensus standards, applicable 14 CFR part 21 rules, and other policy and guidance relevant to LSA. Manufacturers shoul d be required to implement corrective action plans for findings discovered during the recommended oversight activities.
Conclusion : The LSA industry is not adequa tely conducting oversight of its manufacturing operations.
Recommendation : Industry should continue as sessments of LSA manufacturers, extensions, and distributors. 2.0.4 Advisory Material Many LSA facilities showed weaknesses in writt en procedures, knowledge, or experience (see section 2.7, Manufacturer’s Facil ity Questionnaire) related to the design, manufacture and continued airworthiness of LSA. LSA manufacturers need adviso ry material describing basic elements of manufacturing, design, quality, and continued airworthiness systems to include:

 Continued airworthiness processes.

 Handling of airworthiness directives (ADs) on products w ith type certificates (TC).

 Processes for design elements, including te sting methods to substantiate design.

 Explanation of the sequencing and importan ce of special flight permits for testing.

5/17/2010 Page 9 Explanation of the proper sequencing and im por tance for completing the aircraft before issuing an LSA certificate.

 Major repair and al teration processes.

 Maintenance instructions and their distribution.
Conclusion: The LSA manufacturing industry l acks sufficient guidance to ensure compliance to FAA rules and FAA-accepted consensus standards.
Recommendation: FAA should update existing polic y (Advisory Circulars and Orders) pertaining to airworth iness certification requirements, registration marking, and designee management.
2.0.5 Consensus Standards The content and development of the FAA-accep ted consensus standards is currently the responsibility of the standard se tting bodies. The FAA reviews c onsensus standards to provide a minimum acceptable level of safety when LSA are designed, manufactured, and continuously supported by LSA facilities.
The data indicates that some areas of curre nt FAA-accepted consensus standards are ambiguous or lack basic requirements. Many of the consensu s standards lack processes and requirements for creating records or traceability.
Conclusion: Consensus standards need clarificat ion and expansion, plus incorporation of additional requirements. Also, there are insufficient resources for continuous maintenance of consensus standards.
Recommendation: Current ASTM and FAA accepted consensus standards should be reviewed for adequacy and revised as necessar y. Dedicated resources should be provided for continuous maintenance. 2.0.6 Designated Airworth iness Representatives (DAR) There is evidence that DARs have not adequately followed FAA directives. Data recorded at manufacturers, extensions, and distributors indicates multiple errors in DAR review of application packages and supporting documenta tion, to include FAA Form 8130-15, Light Sport Aircraft Statement of Compliance.
Conclusion: In specific areas, some FAA DARs are not following FAA directives.
Recommendation: The FAA should update DAR and FAA advisor training.

5/17/2010 Page 102.0.7 Availability of Sa fety Crit ical Information The LSA industry currently uses safety directives and safety alerts to di sseminate safety critical information. ASTM requirements to disseminate that information to a ppropriate airworthiness authorities and owner/operators diffe r by type of aircraft (powered parachute, airplane, etc). The assessment results show that LSA manufacturers l ack adequate systems to develop and distribute safety critical information.
Conclusion: The current system for distributing sa fety alerts and safety directives for LSA aircraft is inadequate.
Recommendation: Industry should sta ndardize the continuous ai rworthiness notification process for all types of LSA.
Recommendation: The FAA should establish a pro cess to receive safety alerts, directives, and other pertinent information. 2.0.8 Industry Training The LSA industry has been in existence for approxi mately 5 years. The data indicates a segment of the LSA industry needs more experience and knowledge in developing and maintaining an LSA manufacturing infrastructure. In addition, a significant porti on of LSA manufacturers were unaware of standard manufacturing practices and processes used th roughout the aviation industry.
Conclusion: Increasing the knowledge base of the LSA industry will improve manufacturer competence, resulting in safer and more reliable products.
Recommendation: Industry should develop initial and continuous training to ensure the manufacturers fully understand FAA regulat ory and policy requirements, and the methods and means to comply with those re quirements. FAA designees will be trained by the FAA.


### 2.1 C ONTINUED 

### A IRWORTHINESS 

### S YSTEM
2.1.1 General Discussion

― Continued Airworthiness System Specific data for this section has been analyzed and is combined below to provide a general discussion of concerns relating to LSA Continued Airworthiness. Data results are discussed to exemplify areas for improvement and recommenda tions are provided for those resultant areas.
Data shows that some manufacturer s provide insufficient and or inadequate instructions for their customers to comply with manufact urer safety directives. Related data supports a need for clear instructions and procedures to increase manufacturer’s understa nding of compliance to standards in general, regarding flight and service difficu lty issue requirements, and concerning operations safety risk assessment procedures. In res ponse, the assessment team recommends that the consensus standards clarify where instruction requirements for safety directives are located.

5/17/2010 Page 11And, that those instructions addr ess all related processes and pro cedures for their im plementation to achieve comprehensive continued airworth iness support.
Additional data indicates that some manufactures lack procedures to ensure that, as equipped, LSA will comply with applicable ADs. Alt hough a majority of the LSA facilities assessed do not integrate type-certifi cated products into their design, some use type-certificated products and technical standard order (TSO) components. Th e LSA manufacturer is responsible for ensuring the continued airworthine ss of all equipment installed on any of its aircraft certified as SLSA. The team therefore recommends the LSA indus try standards body, in conjunction with FAA requirements and policy, develop guidance to clar ify and expand a Continued Operational Safety Monitoring/Notification system for LSA manufacturers. Only one manufacturer had procedures in place to provide service bulletins to the FAA. One other manufacturer provided se rvice bulletins to the FAA but had no procedure in place. Although there is a requirement in the consensus standards to provi de safety directives to the appropriate civil aviation au thorities, it only applies to powered parachutes and weight-shift-control aircraft. The FAA does not have a formal system in place to receive or maintain safety critical information such as safety directives, safety alerts, and service bulletins.
There are two recommendations for this conclusion. The first is that the consensus standards be revised to require safety directiv es be provided to civi l aviation authorities for all types of LSA. The second is that the FAA should consider de veloping and implementing a system to receive and maintain service bulletins. The FAA s hould also provide guida nce to manufacturers addressing where and how to provide safety critical information to the FAA. Objective data supporting these recommendations are located in Manufacturer’s Facility Questionnaire, section 2.7. Sixty three percent of the LSA facilities indicated a lack of adequate procedures to ensure that LSA manufacturers maintain owner information for the aircraft they manufacture. This is of concern because LSA manufacturers are the sole s ource of critical safety information for LSA owners. Without adequate procedures to ma intain owner information, LSA manufacturers may be unable to ensure that all th eir LSA owners receive critical safety information in a timely
manner. The assessment team recommends that a standardized procedure for ownership change notification be included as part of the consensus standard. This should be considered a top priority. The team also reco mmends reviewing and verifying the LSA facility’s continued airworthiness process for notific ation during initial a nd periodic assessment of LSA facilities. Another area that requires impr ovement is compliance to standa rds for records, adherence to procedures, and verification that the continued airworthiness syst em is functioning to consensus standards. Some LSA manufact urers inadequately comply with consensus standards when performing risk assessments of customer identifie d service difficulties. Inadequately performed risk assessments increase the possibility of misjudging the severity of safety of flight issues. The low assessment scoring indicated a number of LSA facilities lacked procedures for safety of flight assessments. Furthermore, those LSA facilities that had procedures lacked appropriate

5/17/2010 Page 12records sho wing the performance of those risk assessments. The lack of performance and records can inhibit the ability of manufacturers to perform adequa te safety investigations.
The assessment team recommends that manufacturers conduct an immediat e review of safety directives they have issued. Th e review must include an appli cation of risk assessment, with appropriate actions taken. In addi tion, a review of an LS A facility’s risk an alysis procedure and compliance to the appropriate consensus sta ndard should be completed during initial and periodic assessments of all LSA facilities. Seventy percent of LSA facilities provide a system that complies wi th the consensus standard in its present form. Many LSA facilities lacked processes and procedures to properly verify operation of their continued airworthiness syst ems. Low scores for the supporting questions indicate that the LSA manufact urers are not sufficiently veri fying that their continued airworthiness system is functioning properly.
One recommendation is that manufacturers revi ew LSA facilities’ continued airworthiness processes for notification and verification. This is to include records of corrective actions taken for consensus standards compliance. Another recommendation is th at during initia l and periodic assessments of all LSA facilities a review of the LSA facilities’ continued airworthiness process for notification and verification in cluding corrective actions taken, Very few manufacturers have procedures or a system in place to ensure their design data and continued airworthiness notifica tion systems remain accessible and viable should the company cease to exist.
The team recommends that continued airworth iness processes be re viewed for adequate provisions that allow LSA operators access to th e design data should th e LSA company cease to exist. In addition, the review s hould be verified during initial a nd periodic assessments of LSA facilities.


### 2.2 P RODUCT 

### C ONFORMITY TO 

### R EGULATIONS
2.2.1 General Discussion—Product Conformity to Regulations An analysis of the data gathered in the Produc t Conformity to Regulations section shows both positive and negative conclusions. Some of the positive outcomes are notewor thy. Specifically FAA Form 8130-6 and FAA Form 8130-7 have been properly complete d by applicants and DARs. The aircraft reviewed during the assessment were found to be largely in compliance with the regulatory definition in 14 CFR § 1.1. In addition, LS A manufacturers are ge nerally providing the minimum required aircraft documentation. However, some manufacturer’s lack documented de sign control systems. For example, the data shows a lack of consistency in ensuring that every consensus standard is the latest FAA “accepted” consensus standard. ASTM consensu s standards should include requirements to develop and follow written procedures for design control systems.

5/17/2010 Page 13In addition, som e manufacturers are inconsistent in properly pl acarding aircraft systems and instruments. Fuel system placards were missing or incorrect in showing fuel grade or fuel tank capacity. Instruments were not marked in accord ance with 14 CFR § 91.9, Civil aircraft flight manual, marking, and placard requirements, and the applicable consensus standards. There were also cases when the presence of emergency para chutes on the aircraft were not externally marked. Emergency parachutes incorporate ballistic deployment devices and can be inadvertently discharged if mishandled. So me LSA manufacturers are not complying with marking and placarding requirements of FA A regulations and FAA-accepted consensus standards. Therefore, an LSA oversight prog ram should be establishe d to include initial compliance audits and periodic evaluations of LSA facilities Manufacturers. A third of aircraft surveyed di d not fully comply with the prop er display of the words “LightSport” per 14 CFR § 45.23, Display of marks; ge neral. During the surveys it became apparent that this rule is being interpreted in many ways regarding how and where to locate the placard. Manufacturers, inspectors, and DARs are confused about how to properly mark the aircraft. Also, there is an overall lack of understanding about the intent inthe original rule for “lightsport” marking.
Some FAA DARs lack an understand ing that manufacturers must obtai n a special flight permit to conduct production flight tests. Furthermore, some DARs lack an understanding regarding application and eligibility requirements for i ssuing certificates to LSA. These are basic certification requirements that s hould have been reviewed by the DAR and corrected by the manufacturer before issuance of an LSA certific ate. Survey results show some FAA DARs do not have a clear understanding of the require ments for issuing an SLSA certificate.
Some LSA manufacturers lack experience and knowledge in ma nufacturing design systems for the production of aircraft. It is recognized that LSA are simple aircraft and should require the least burdensome procedures to ensure conformance to regulations. The team recommends that the consensus standards be reviewed and clarified. And, that advisory material be published to assist LSA facilities in developi ng procedures that include inform ation regarding where to obtain and how to use the latest FAA- accepted consensus standards.


### 2.3 M ANUFACTURER 

### E XTENSION 

### /D ISTRIBUTOR 

### A SSEMBLY 

### P ROCEDURES AND 

### D OCUMENTATION 

### S YSTEM
2.3.1 General Discussion—Manufacturer Extension/Distributor Assembly Procedures and Documentation System This section addresses LSA that are manufactured out side the United States. The results are representative of a portion of the distributors and dealers surveyed. The assessment results demonstrated that some manufact urers lack controls and succe ssive (flow-down) processes for quality system requirements, procedures, record s, and practices. Although most of those surveyed have written authorization to perf orm assembly operations, many do not have the documented processes, procedures, and quality practices that are common for an aircraft manufacturing quality system.

5/17/2010 Page 14The ASTM consensus s tandards lack specific requirements and are inconsistent when addressing quality systems for different types of LSAs. For example, the ASTM consensus standard for airplanes and gliders (ASTM Consensus Standard F2279-06, sections 2.1.9 and 9) provides that manufacturers “may assign” quality system requirements for distri butors. However, weight-shift-control aircraft (ASTM Consensus St andard F2448-04) do not have the requirement and powered parachute (ASTM Consensus Standa rd F2240-05, section 2.2) allows assignments to distributors if “the [quali ty assurance] QA procedures pr ovide for training, reporting, and tracking consistent with the overall QA system.” A major contributing factor to the lack of quality system controls is that LSA manufacturers are not required to establish an audit of performance and capabilities of their extensions, distributors, and dealers. There is a greater risk to safety when manufacturer’s exte nsions, distributors, and dealers have no quality systems or quality manuals of their own. The consensus standards for quality assurance should be revised to include requirements for LSA manufacturers to control and flow-down their quality system requirements to their affiliates (i.e., distributors). This flow-down of inform ation should be accomplished through documented procedures, processes, practices and recordkeepi ng for regulatory compliance, flight and delivery preparation, flight testing, and assembly tasks. This consensus standards revision should apply consistently to all types of LSA.
One recommendation is that the consensus standa rds for quality assurance require manufacturers to conduct initial and periodic co mpliance audits of th eir extensions, distri butors, and dealers (reference ASTM Consensus Standard F2279- 06, “satellites” language). In addition, manufacturers should be required to maintain records of these audits that demonstrate performance and compliance to manufacturi ng requirements and consensus standards.
Another recommendation is that the consensus standards for quali ty assurance should require a documented process and records for identifyi ng specific individual qualifications in the performance of quality tasks, including in-process and final inspections. And, that the standards require a documented process and record of all inspections and checks performed on each aircraft that identifies the indivi dual(s) performing the quality tasks.
A third recommendation is the establishment of specific requirements for a calibration system. Consensus standards should require manufact urers to use recognized calibration system standards. This calibration system should enco mpass all instruments, measuring devices, and tools necessary for the manufact uring and assembly of LSA. These new requirements should be applied consistently to all types of LSA. Some FAA DARs inconsistently applied eligib ility regulations for the issuance of SLSA certificates of airworthiness. FAA DARs issui ng airworthiness certificates inconsistent with FAA directives is of particular concern. Th e team encountered three common problems during the evaluations concerning inconsistent application of FAA regulations and policy: (1) DARs issued SLSA airworthiness certificates before co mpletion of production or re quired flight testing; (2) DARs issued SLSA airworthin ess certificates before the aircraft has been completed, and; (3) issuance of an SLSA airworthiness certificate by DARs who are also the principal or owner

5/17/2010 Page 15of the distributorship or of a m anufacturing f acility performing assembly, quality and testing functions of the aircraft.
The team noted an instance where a DAR who issu ed the SLSA airworthin ess certificates was also the sole owner of the LSA distributorship. In this case, the DAR/owner performed assembly and inspection of the LSA as well as applied for the airworthiness certificates. Therefore, the same person inspected the aircraft, issued the SL SA certificate, and perfor med a flight test or “tuning” of the aircraft. FAA Order 8130.2F, paragraph 121(e)(1) states clearly, “ IN NO INSTANCE WILL THE FAA PERFORM ANY OF THE FABRICATION, CONSTRUCTION, ASSEMBLY, OR CLOSING WORK ON OR TO THE AIRCRAFT. ” Consensus standards should require flight testing after shipping reassembly for all LSA types. Flight testing should be performe d according to national FAA polic y within a controlled process and area, with the appropriate flight permit, a nd before a DAR issues an SLSA airworthiness certificate.
The LSA team recommends the issuance of advi sory material for the LSA manufacturing industry that explains proper se quencing including the importance of a permit for flight testing, and completion of the aircraft before issuance of an SLSA certificate. The FAA should enhance guidance in FAA Order 8130.2 to clarify that all LSA flight testing or check flight(s) must be conducted in a contro lled process and area (ope rating limitations) with the appropriate flight permit. FAA Order 8100.8 paragraph 704 (f.) includes the requirement that no DAR may issue an airworthiness certificat e for an aircraft on which that DAR performs maintenance, mechanical functions, or inspectio ns. The Order should contain a further conflict of interest clarification when LSA DAR are owne rs, principle partners, managers or employees of the company that has applied for the airwor thiness certificate. In addition, the FAA should expand the mandatory training in pertinent airwor thiness certification procedures for LSA DARs and for ASIs that advise and perform certification functions at LSA facilities. Data analysis shows that a small portion of pa rticipants did not have sufficient assembly instructions in either separate form or within the maintenance manual. Personnel are sometimes not provided with written instructions or diag rams to accomplish the task. This condition is inconsistent with industry pract ices for producing airworthy airc raft that conform to design criteria. It is recommended that at the time of the issuance of the first SLSA airworthiness certificate at an LSA facility, a full appraisal survey for conformity of the assembly and inspection operations should be conducted. In addition, the team recomm ends a periodical audit of manufacturer exte nsions, distributors, and dealer s for conformity of operation.


### 2.4 C OMPLIANCE TO 

### ASTM D ESIGN 

### S TANDARDS 2.4.1 General Discussion—Complia nce to ASTM Design Standards Based on an analysis of the responses to the questions in this sec tion, the assessment team concluded that many LSA manuf acturers lack the experience and knowledge necessary for proper development of design control systems.

5/17/2010 Page 16The team recommends that the industry publis h guidance to assist LSA manufacturers in developing design control systems and procedur es. The guidance should include a documented system to ensure the LSA industry uses the most recent FAA-accepted consensus standards. The guidance should also include information about conducting spin tests, determining airplane freedom from flutter, and acceptable methods of testing for useable fuel quantity. The team was not able to gather a sufficient quantity of data to make confident statistical determinations of the status of compliance to design standards for forei gn LSA manufacturers. Most LSA are manufactured in whole or in part in a foreign country. Of the 30 LSA facilities assessed, seven currently produce do mestically designed aircraft. In almost all cases of LSA, where most or all of the aircraft is manuf actured outside the Unite d States, there was no engineering analysis or test data available at the facility. The team did gather anecdotal information from discussions with the distributors and manufactur er’s extensions that indicate foreign manufacturers use their own nationa l standards as well as FAA-accepted ASTM consensus standards. Rarely could the team fi nd evidence showing comparability of the foreign national standard in the FAA-accep ted ASTM consensus standard.
The lack of conclusive data can be remedied by expanding this assessment to LSA manufacturers in other countries. However, consideration mu st be given to the hi gher cost and resource requirements of conducting assess ments outside the United States . Comparing the response to questions from foreign and domestic manufacturers reveals very sim ilar results. Therefore, when implementing changes, if any, based on the recommendations in this report, FAA should consider how the change can be applied to foreign manufactured LSA. Dialogue and cooperation with other CAAs is n eeded to implement some of the recommendations in this report regardless of the results of additional assessments. There is evidence that some foreign manufacturer s are not in compliance to the ASTM consensus standards. Examples include failure to properly placard the instrument panel or fuel tank inlet area and failure to provide documentation fo r the signoff of the proper ASTM consensus standards on FAA Form 8130-15. As with dom estic manufacturers, foreign manufactured LSA aircraft generally meet the 14 CFR § 1.1 definition of LSA aircraft.
There are areas of concern common to all LSA faci lities. Forty six percent of the manufacturers complied with the ASTM consensus standard require ment that all flight sp eeds be presented in calibrated airspeed. Some manuf acturers performed inadequate tests or no tests for spin characteristics. And, there was a 62 percent co mpliance rate for documen ting alternate methods of compliance. Additionally, some manufactures could not demonstrate compliance to usable fuel testing requirements. The analysis for thes e responses demonstrates a lack of compliance to the design standards. As stated in the first paragraph in this section, analysis indica tes few LSA manufacturers have a system to check for the latest FAA-accepted desi gn standard revision. The lack of an adequate system in this area indicates manufacturers are us ing design standards that are out dated or not yet accepted by the FAA. These are basic LS A requirements that th e DAR should question, review, and require the manufactur er to correct before issuing an SLSA certifica te. Some FAA DARs do not have a clear understand ing of the requirements for issu ing an SLSA certificate. Also, some FAA DARs do not have a clear awarene ss of their ability to require the manufacturer

5/17/2010 Page 17to provide evidence supporting the statem ent of comp liance, particularly with respect to required documents. The FAA should improve FAA insp ector and LSA DAR training programs, and enhance oversight of LSA DAR performance. For foreign manufacturers, simply conforming to domestic CAA require ments may not ensure compliance to the LSA rule. The team recommends that the ASTM consensus standards include language directing the LSA manu facturer to use only those de sign standards currently accepted by the FAA. Data analysis further shows many LSA facilities do not maintain access to copies of the prior consensus standard. This is a critical requirement to maintain continued ai rworthiness of aircraft designed and built to prior standards in effect at that time. Finally, some manufacturers did not perform a peer review of desi gn calculations. In a technical profession, the concept of peer review is a signifi cant factor in assuring the quality of work when that work will not be proven by a demonstrat ion test. The ASTM co mmittee should mandate second party review of design calculations that are not proven by demonstration test.


### 2.5 M ANUFACTURER 

### ’ S 

### Q UALITY 

### S YSTEMS
2.5.1 General Discussion—Manuf acturer’s Quality Systems There were some positive conclusions regard ing quality systems. Most manufacturers maintained control of nonconforming or scrap parts. Many conclusions for this section reflect a lack of understanding, for some manufacturers, that the development and use of a good quality system to control production of LSA provides both safety and economic value. Data analysis shows that many LSA facilities do not maintain a quality manual that meets the minimal requirements of the ASTM consensus sta ndards. Robust quality assurance programs are essential to ensure that manufact ured aircraft conform to the stat ed design and are in a condition for safe operation. The assessment noted that th ere was a specific lack of procedures and objective evidence at many LSA facilities for a prope r tool and gage system to control calibrated tools. Another specific area the team found lacking is receiv ing inspection. There was little evidence of “supplier control”, an integral part of adequate receiving inspection systems. The quality systems also lacked definition of role s and responsibilities as well as a process for delegation authorization. In some cases the manufacturer’s quality a ssurance program did not provide adequate controls of speci al processes, such as welding. The team also was made aware of manufacturers using informal, or undocumente d, interim inspections and tests. Informal quality systems provide for inc onsistent results and may compromise conformity of the items produced. The LSA manufacturing industry requires more gui dance for the development and use of strong quality systems. The FAA has published advisory material and policy material to assist and oversee manufacturing quality systems for producti on approval holders. The FAA could adapt much of the existing published guidance for deve lopment of an LSA-specific AC. The guidance
5/17/2010 Page 18also should address the quality weaknesses id entified during this assessm ent, such as development of a quality manual, control of special processes, receiving inspection procedures, supplier control procedures, tool and gage contro l procedures, and incorporation of in process inspections and control systems. The guida nce should also addre ss the importance of establishing a complete recordkeeping system. Many LSA manufacturers do not perform or maintain records of inte rnal quality system audits. In the last few decades, FAA manufacturing has focused on internal audits by production approval holders as a key ingredie nt in any quality system. The practice of self checking is recognized as a good system to correct defici encies in quality programs. The consensus standards require LSA facilities to perform in ternal audits of their quality system on a 12- or 24-month basis.
Some LSA facilities do not mainta in a configuration control system as required by the applicable consensus standards. A well-defined and followed configuration control system is essential to manufacturing duplicate products and in providing ad equate continued operational safety for the existing fleet. The team recommends that the FAA evaluate LSA facilities for the completeness of their quality system and their compliance to procedures. An LSA evaluation checklist based on FAA rules, policy, and accepted consensus standards should be developed as a guide to conducting evaluations. New LSA facilities’ quality systems should be evalua ted before presentation of the initial production aircraft for certification. An evaluation of existing manufacturers should be conducted as soon as practical after development of an evaluation checkl ist. Finally, conduct periodic evaluations for all LSA facilities to ensure continued compliance to FAA rules and FAA-accepted consensus standards.


### 2.6 M AINTENANCE 

### P ROCEDURES AND 

### D OCUMENTATION 

### S YSTEM
2.6.1 General Discussion—Maintenance Pr ocedures and Documentation System An analysis of the Maintenance Procedures and Documentation System data resulted in positive and negative conclusions. The conclusions and examples listed in this section have four resultant and related recommendations which appear throughout this report. They are the need for advisory materials, an oversight program , improved consensus standards, and enhanced training for the LSA industry. Survey results and observations show that LSA manufacturers understand the requirements for formatting a maintenance manual; however, they are inconsistent in the degree of detail and documentation. This inconsistency demonstrates that some manufacturers do not completely understand how to apply and accomplish the requir ements of ASTM Consensus Standard F2483- 05. This indicates that the consensus standard s are not prescriptive e nough. More prescriptive consensus standards would enable manufacturers to write maintenance manuals that better meet the intent of the standards. Better written ma nuals would help eliminate confusion for owners, mechanics, airports, regulatory officials, a nd aircraft and component manufacturers who use those manuals.

5/17/2010 Page 19Som e LSA manufacturers have a low understanding of how to comp ly with numerous sections of the consensus standard. While most ma intenance manuals addressed the required subjects/headings the manuals failed to do so in enough detail to satisfy the intent of the requirement. Many of the manufacturers su rveyed could not provide documentation to demonstrate they were in compliance with the c onsensus standard requirem ents for major repairs and alterations, level of certification, manual revisions, and equipment list. Analysis of data for questions addressing major repairs and alterations shows manufacturers, and possibly the LSA industry, have a low understandi ng of how to comply w ith this area of the consensus standard. Less than half of the manufacturers surveyed followed the ASTM consensus standard and provided written in structions on how to pe rform major repairs or alterations. Some manufacturers lacked any documented system and, throughout the assessment surveys, sought clarification fr om team members on how to comply with specific required items by ASTM Consensus Standard F2483-05, section 9.2. Overall the low rating for this series of questions indicates there is a ge neral lack of understa nding for the concept of major repairs and alterations for LSA. Further, the survey results s how that currently there is a lack of control of major repair and alteration processes wh ich could pose a serious safety concern. Data also revealed a lack of objective evidence th at manufacturers provided task specific training as required by the consensus standards. The series of questions that address mainte nance manual revisions and change distribution scored high and low. The ASTM Consen sus Standard F2483-05, section 5.1.12, Revisions, requires maintenance manuals to c ontain a “section, such as a change history table, for the listing of any revisions to the maintenance manual by th e manufacturer.” Most of those assessed knew about this requirement. This reinforces the previous conclusion that manufacturers have a positive understanding of the FAA-accepted consensus standard requirements concerning maintenance manual format. However, because the consensus standards do not include a requirement or process for contro lling or distributing maintenan ce manual revisions and changes, the survey analysis results reveal another po tential safety concern. Only half of the manufacturers had a documented process to re vise and distribute changes to their LSA maintenance instructions. Of those who had a pr ocess, less than half had a method to inform LSA owners of the changes and revisions. And, onl y four LSA facilities had a system to verify that owners received maintenance manual changes. Of those surveyed, about half were in comp liance with ASTM Consensus Standard F2483-05, section 5.1.1.1, which requires an eq uipment listing in their maintenance manual. In some cases, their equipment lists were found in locations othe r than their maintenance manual. Many did not include adequate maintenance instructions for th eir installed equipment or track their equipment to inform LSA owners of changes or equipment maintenance instructions. This reinforces the conclusion that manufacturers are accomplishing th e requirements of ASTM Consensus Standard F2483-05, section 5.1, with an inconsistent degr ee of detail and documentation, and that the ASTM consensus standards need to be more prescriptive. The questions which addressed ASTM Consensu s Standard F2483-05, section 8, Overhaul, were removed from the survey because of team misint erpretation. Nevertheless, the team noted that LSA survey participants also di d not have a clear unde rstanding of the consensus standard for

5/17/2010 Page 20overhaul m anual requirements. This supports the team’s first conclusion that the ASTM consensus standards are not prescriptive enough.


### 2.7 M ANUFACTURER 

### ’ S 

### F ACILITY 

### Q UESTIONNAIRE
2.7.1 General Discussion—Manufact urer’s Facility Questionnaire The team gave a Manufacturer’s Facility Questionnair e to the 30 LSA facility participants in the assessment surveys. The questionnaire wa s an opportunity to obtain candid, anonymous information in areas of interest associated with LSA manufacturing and certification. The questionnaire contained comment areas without limitations to th e response length or topic. The questions solicited suggestions for improveme nt from the LSA facility’s point of view, and were designed to identify best practices to benchmark. The FAA received five responses (approxima tely 17 percent) which were analyzed. 2.7.2 Manufacturer’s Facility Qu estionnaire Results—Analysi s Summary The responders seem satisfied with FAA regulati ons on LSA, and believe that the status quo is appropriate and not burdensome. However, the responders e xpressed concerns about FAA standardization of policy and guidance, and rece iving timely information about the LSA rule’s intent. Given the variety of sources the LSA industry uses to obtain information, there appears to be a lack of knowledge regarding where to obtain acc urate information con cerning LSA regulations and standards. In addition, the responses indicate that there is a general lack of knowledge of how LSAs are addressed within the FAA. Coll ectively, these remarks, conclusions, and report data indicate that more extensive training for DARs, ASIs, and FAA advisors and managers is warranted. Furthermore, the FAA should provide additional guidance, such as a series of ACs for LSA manufacturers and the industry. Respondents were divided on adequacy of the co nsensus standards. Three respondents stated that the standards meet thei r needs, and two respondents in dicated that improvements are necessary, citing gaps in the st andards, but acknowledged that the industry is working toward resolution of this problem. One responder recommended changing the process for deciding what new ASTM consensus standards to write and provided de tailed steps for this process. The team has made no specific recommendation in response to this comment. Another respondent suggested changing the FAA airc raft registration proce ss and stated that the current process for LSAs manufactured overseas requires a separate document stating that the aircraft was never registered in the country of manufacture. The respondent felt that this requirement is redundant, unnecessary, and time consuming. The team recommends that justification for the requirement be researched. If it is determ ined that the requirement is justified, the rationale should be included in advisory material for LSA manufacturers.

5/17/2010 Page 215/17/2010 Page 22 Another respondent made three specific suggestions for process change. The first suggestion is to continue the assessment (and surveys) for LSA manufacturer’s located outside the United States. The team recommends that th e FAA develop a process to perform initial conformity checks and continuous oversigh t evaluations that includes foreign LSA manufacturers. This recommendation is addressed th roughout the report. The second suggestion is for a central collectio n point for OEM equipment service bulletins and other LSA regulatory information. This concep t could improve safety for the LSA community, particularly with regard to c ontinued airworthiness notificatio n and maintenance. The team recommends developing a system for a central da ta collection point. As previously noted, the team recommends the establishment of a public We b site to post LSA safety alerts and safety directives. The third suggestion is that the FAA should reduce the response tim e for petitions for exemption. This report does not include a recommendation for im provement in this area because it is outside the scope of this assessment. The team w ill forward this suggestion to the appropriate FAA office.


### 2.8 O THER 

### D ATA
2.8.1 General Discussion

— Other Data This assessment gathered company biographical information. The team asked questions about the nature of each facility’s busine ss and the extent of its experience. 2.8.2 Specific Analysis

— Other Data The information collected indicates that many LSA facilities have limited experience in both LSA and aviation manufacturing. The biographical information revealed that 7 of 18 manufacturers/dist ributors have less than 2 years of LSA manufacturing experience. In addition to recorded data, the team gathered anecdotal information from interviewees that indicated very few of them have airc raft design and manufacturing backgrounds.

### A PPENDIX 

### A. A CRONYM 

### L IST

14 CFR Title 14, Code of Federal Regulations ACE-114 FAA, Aircraft Certification Se rvice, Small Airplane Directorate, Light-Sport Office AC advisory circular AD airworthiness directive AFS-300 FAA, Flight Standards Service AIR-40 FAA, Aircraft Certification Service, International Policy Office AIR-100 FAA, Aircraft Certificati on Service, Engineering Branch AIR-200 FAA, Aircraft Certification Serv ice, Production and Airworthiness Branch ASI aviation safety inspector CA continued airworthiness CAA civil aviation authority CAS calibrated airspeed DAR designated airworth iness representative EAA Experimental Aircraft Association ELSA experimental light-sport aircraft ELT emergency locator transmitter FAA Federal Aviation Administration IAS indicated airspeed LSA light-sport aircraft LSAMA Light-Sport Aircraft Manufacturer Assessment POH Pilot Operating Handbook QA quality assurance SLSA special light-sport aircraft TSO technical standard order WSC weight-shift-control

5/17/2010 Page A-1

### A PPENDIX 

### B. G LOSSARY

The definitions below are for th e purposes of this report only. Advisory circular . Guidance published by the FAA on acceptable means, but not the only means, of compliance to Title 14, Code of Federal Regulations.
Airworthiness certificate . A certificate issued to an aircraft when it has been shown to be in compliance with an approved design and in condition for safe operation. Best practices . Design or manufacturing process that experience has shown to be beneficial. Calibrated airspeed . Indicated airspeed of an aircraft , corrected for position and instrument error. Calibrated airspeed is equal to true airspeed in stan dard atmosphere at sea level Civil aviation authority . A government agency from any country with responsibility for civil aviation with in that country or jurisdiction. Conformity . A generic term used in reference to th e adherence to the approved design of the manufacture of an aircra ft or part thereof.
Consensus standard . A standard or group of standa rds developed by recognized industry entities. In the context of this report, this te rm may also refer to ASTM consensus standards and FAA-accepted consensus standards. Corrective action implementa tion and feedback system . An element of internal audit systems that incorporates a means to correct deficienci es and verify the implementation of corrections. Designees . Individuals or companie s appointed at the discretion of the FAA for performing authorized functions on behalf of the FAA.
Distributor . A person who sells and distributes LSA but does not sign, except on behalf of another company, FAA Form 8130-15. Experimental light-sport aircraft . A specific category of airwor thiness certificate for certain experimental LSA. FAA-accepted consensus standard . A consensus standard submitted for review and acceptance by the FAA and published on FAA’s public Web site.
FAA rules . A reference to 14 CFR.
First-time LSA models . A first model or derivative mode l built by an LSA manufacturer that meets the 14 CFR § 1.1 definition of an LSA.
Flutter . A self-feeding and potentially destructiv e vibration where aerodynamic forces on an object couple with a structure’s natural mode of vibration to produce rapid periodic motion. 5/17/2010 Page B-1Indicated airspeed . Speed of an aircraft as show n on its pitot static airspeed indicator calibrated to reflect standard atmosphere ad iabatic compressible flow at sea level uncorrected for airspeed system errors.. Industry stakeholders . Any interested party, owner, operator, manufacturer, industry organization, or government entity involved in LSA. Light-sport . An aircraft, other than a helicopter or powered-lift th at, that since its original certification, has continued to meet the following : A maximum takeoff weight of not more than 1,320 pounds (600 kilograms) for aircraft not in tended for operation on water; or 1,430 pounds (650 kilograms) for an aircraft intended for ope ration on water. A maximum airspeed in level fight with maximum continuous power (V H ) of not more than 120 knots CAS under standard atmospheric conditions at sea level. A maximum never-exceed speed (V NE )of not more than 120 knots CAS for a glider. A maximum stalling sp eed or minimum steady flight speed without the use of lift-enhancing devices (V S1 )of not more than 45 knots CAS at the aircraft’s maximum certificated takeoff weight and mo st critical center of gravity. A maximum seating capacity of no more than two persons, includ ing the pilot. A single, recipr ocating engine, if powered. A fixed or ground-adjustable propeller if a powered ai rcraft other than a powered glider. A fixed or auto feathering propeller system if a powered glider. A fi xed-pitch, semi-rigid, teetering, two-blade rotor system, if a gyropl ane. A nonpressurized cabin, if equipped with a cabin. Fixed landing gear, except for an aircraft intended fo r operation on water or a glider. Fixed or retractable landing gear, or a hull, for an aircra ft intended for operation on water. Fixed or retractable landing gear for a glider.
LSA DAR . A DAR who has function codes for issuing ELSA or SL SA airworthiness certificates.
LSA facilities . A generic term that includes LSA manuf acturers, extensions, and distributors.
Manufacturer . Any person or company that signs and submits an FAA Form 8130-15 attesting to the manufacture of an LSA.
Manufacturer extension . Any person or company that acts on behalf of a manufacturer to complete or otherwise fabricate an LSA.
Material Review Board . A designated group of individuals that review and disposition parts that do not conform to approved data.
Order . A policy document issued by th e FAA and available to the public. Powered parachute . A powered aircraft comprised of a flexible or semi-rigid wing connected to a fuselage so that the wing is not in position for flight until the aircraft is in motion. The fuselage of a powered parachute contains the aircraft engine, a seat for each occupant and is attached to the aircraft's landing gear. Special light-sport aircraft . A specific category of airworthiness certificate for certain LSA. The 14 CFR §1.1 definition applies.

5/17/2010 Page B-25/17/2010 Page B-3 Supplier control . A means of selecting and controlling suppliers of materials and services for the manufacture of aircraft or parts thereof. Type-certificated product . An aircraft, engine, or propeller manufactur ed to an FAA-approved type certificate. Ultralight vehicles . An aircraft used or intended to be used for manned operation in the air by a single occupant, and used or intended to be used for recreation or sport pu rposes only. Ultralight vehicles do not have any U.S. or foreign airwor thiness certificat e and, if un powered, weighs less than 155 pounds. If powered, an ultralight ve hicle weighs less than 254 pounds empty weight, excluding floats and safety devices intended for deployment in a potentially catastrophic situation. In addition, an ultralight vehicle ha s a fuel capacity not exceeding 5 U.S. gallons, is not capable of more than 55 knots calibrated airspeed at full po wer in level flight, and has a power-off stall speed that does not ex ceed 24 knots calibrated airspeed.
V H . Maximum speed in level flight with maximum continuous power.
V S . Stalling speed or minimum steady flight sp eed at which the aircraft is controllable. Weight-shift-control aircraft . Powered aircraft with a fram ed pivoting wing and a fuselage, controllable only in pitch and roll by the pilot’s ability to change th e aircraft’s center of gravity with respect to the wing. Flight control of the ai rcraft depends on the wing’s ability to flexibly deform, rather than the use of control surfaces.

### A PPENDIX 

### C. P ARTICIPATING 

### O FFICES

Role in the Assessment Affiliation Sponsor Manager, AIR-200, Production and Airworthiness Division Responsible Branch Manager, AIR-230, Airworthiness Certification Branch Team Leader ASI, AIR-230, Airworthiness Certification Branch Team Member Manager, AIR-240, Evaluation and Special Projects Branch Team Member LSA Program Manager ACE-114, Programs and Procedures Branch Team Member ASE, AIR-110, Engi neering, Aircraft Certification Team Member ASI, AFS-350, Flight Standards Team Member Transportation Industry Analyst – Light Sport Prog. ACE-114, Aircraft Certification, Central Region – Small Airplane Directorate Team Member ASI, AIR-230, Airworthiness Certification Branch Team Member ASI, AIR-240, Evaluation and Special Projects Branch Team Member Foreign Affairs Sp ecialist, AIR-40, International Policy Branch

5/17/2010 Page C-1

### A PPENDIX 

### D. F IGURES The following figures present weighted averages from the assessment, grouped first overall, and then for each of the six majo r sections of the assessment (assembly procedures, product conformity to regulations, maintenance procedur es and documentation, continued airworthiness, quality system, and compliance to design standards). For the overall chart, the bars represent the weight ed averages for each of the six major sections of the assessment, while for the six major section charts, the bars represent the weighted average of each subgroup of questions within the major section.

O VERALL

2.53 3.74 3.57 3.27 4.56 2.16 3.3

Maintenance Procedures and Documentation Quality System Functions Compliance to Design Standards Assembly Procedures and Documentation Product Conformity to Regulations Continued Airworthiness Overall Weighted Average:Major Area



### - Weighted Average 

### + Figure 1. All Facilities (Overall)

5/17/2010 Page D-1M ANUFACTURER E XTENSION /D ISTRIBUTOR A SSEMBLY P ROCEDURES AND D OCUMENTATION S YSTEM (MEDAPD)

3.93 2.94 0.63 3.64 3.21 4.25 4.64

Compenents Certified Flight Test Documented Quality Procedures Checklist Personnel Qualifications

Assembly Instructions ReceivingSubgroup

- Weighted Average + Figure 2. All Facilities (MEDAPD)

P RODUCT C ONFORMITY TO R EGULATIONS (PCR)

4.57 4.97 4.26 4.02 4.70 4.26 4.78

Test Reports Registration Regs and Standards Met 8130-15 Compliance Required Documents Aircraft Marking Meets DefinitionSubgroup

- Weighted Average + Figure 3. All Facilities (PCR) 5/17/2010 Page D-2M AINTENANCE P ROCEDURES AND D OCUMENTATION S YSTEM (MPD)

1.32 0.28 1.71 2.82 2.89

3.04 2.22 3.94

Log and Records Affidavit After Major Repair Major Repairs and Alterations Equipment List Revision Process Return to Service Authority Overhaul Manual Form and Content of ManualSubgroup

- Weighted Average + Figure 4. All Facilities (MPD)

C ONTINUED A IRWORTHINESS S YSTEM (CA)

1.04 1.82 4.83 3.69 1.34 2.20

Companies Ceasing Ops Risk Assessment Records Documentation Requirement Determination of Risk Directives Compliance NotificationsSubgroup

- Weighted Average + Figure 5. All Facilities (CA)

5/17/2010 Page D-35/17/2010 Page D-4 M ANUFACTURER ’ S Q UALITY S YSTEMS (QS)

2.61 1.86 5.00 3.15 3.66 2.71 4.71 5.00 2.91 4.05 4.70

Corrective Action Internal and External Audits Critical Parts List Test Procedures Organizational Structure Quality Manual Non-conforming Material Kits Supplier Control Process And Procedures

Permanent QA RecordSubgroup

- Weighted Average + Figure 6. All Facilities (QS)

C OMPLIANCE TO ASTM D ESIGN S TANDARDS (CDS)

3.96 3.82 4.14 2.42 3.86

Design Compliance Checklist Contents of POH Determination of Compliance to Standards Access to Standards Minimum EquipmentSubgroup

- Weighted Average + Figure 7. All Facilities (CDS)