Light-Sport Aircraft Manufacturers 

Assessment (LSAMA)

FINAL REPORT

Production and Airworthiness Division, AIR–200 

May 17, 2010 
Light-Sport Aircraft Manufacturers Assessment―Final Report

5/17/2010 Page ii 

DISCLAIMER 

This document is disseminated under the sponsorship 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 States Government does not endorse products or 

manufacturers. 
Light-Sport Aircraft Manufacturers Assessment―Final Report

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................ IV

INTRODUCTION ..........................................................................................................................1

1.0 Background.......................................................................................................................................1

1.1 Scope................................................................................................................................................1

1.2 Methodology .....................................................................................................................................2

1.3 Organization of Analysis in the Data Analysis/Discussion Section .................................................6

DATA ANALYSIS/DISCUSSION .................................................................................................8

2.0 Analysis― General Overall...............................................................................................................8

2.1 Continued Airworthiness System....................................................................................................11

2.2 Product Conformity to Regulations.................................................................................................13

2.3 Manufacturer Extension/Distributor Assembly 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 Documentation System ..................................................................19

2.7 Manufacturer’s Facility Questionnaire ............................................................................................21

2.8 Other Data ......................................................................................................................................22

APPENDIX A. ACRONYM LIST..................................................................................................1

APPENDIX B. GLOSSARY.........................................................................................................1

APPENDIX C. PARTICIPATING OFFICES ................................................................................1

APPENDIX D. FIGURES .............................................................................................................1
EXECUTIVE SUMMARY

This report presents the results of the Light-sport Aircraft Manufacturers Assessment (LSAMA), 

(herein referred to as assessment and team). This executive summary briefly discusses the 

assessment team’s analysis, conclusions, and recommendations based on data collected during 

the assessment. 

BACKGROUND

During the 2008 Experimental Aircraft Association (EAA)/Federal Aviation Administration 

(FAA) Recreational Aviation Summit, the FAA Aircraft Certification Service, Production and 

Airworthiness Division (AIR–200) agreed to assess the current state of the light-sport aircraft 

(LSA) industry. AIR–200 chartered and sponsored an assessment team, comprised of 

individuals from several offices within FAA Aviation Safety (AVS). 

GOAL

The assessment team’s goal was to review current LSA manufacturing industry systems and 

processes through on-site evaluation, analysis, and reporting. The team was also tasked to 

recommend enhancements to industry consensus standards for LSA design, manufacturing, 

continued airworthiness, and maintenance and FAA processes and procedures. The team’s 

methodology was to collect data from LSA manufacturers, including their extensions and 

distributors, located in the United States. The team collected data on LSA industry compliance 

with applicable regulations, standards, and existing processes. 

METHODOLOGY

The team developed survey questions and data gathering tools, performed evaluations, analyzed 

collected data, and developed conclusions and recommendations. The team designed the 

questions to evaluate the LSA industry’s understanding and application of applicable regulations, 

standards, processes and procedures. The team developed conclusions and recommendations 

based on the analysis of the collected data, team observations, and comments and suggestions of 

individuals the team interviewed during the assessment. 

The team evaluated 14 manufacturers, including their extensions and 16 distributors. This 

sample of 30 LSA facilities established a 93 percent confidence level that the results of this 

assessment represent the LSA industry as a whole. The assessment surveys began in 

September 2008 and were completed in March 2009. The assessment survey participants were 

cooperative and provided unrestricted access to their LSA facilities. They exhibited a 

willingness and desire to build and promote safe LSA. 

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CONCLUSIONS

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 assessment 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 certificates, should be reconsidered. 

2. Implementation of manufacturing systems. 

Some manufacturers have failed to implement widely 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 compounding this scenario is the fact that current 

consensus standards identify only minimum requirements without a systems-based approach 

which only exacerbates procedural and record keeping weaknesses. We conclude that these 

lack of controls may result in the production and distribution of such poorly documented 

aircraft that it may be very difficult to verify conformity. 

Distributors have not developed and implemented manufacturing and quality system 

procedures for many of the tasks they perform. When distributors perform assembly, 

inspections, and other functions, they seldom use the manufacturers’ procedures, records, or 

controls. The consensus standards do not require distributors to use process control 

procedures and as a result, distributors have only partial manufacturing and quality system 

procedures and associated records. We conclude that the consensus standards need revision 

to require documented controls and processes for assembly and other production functions 

that distributors perform prior to airworthiness inspections and flight. 

3. Understanding FAA regulatory requirements, policy and guidance, and industry 

consensus standards. 

We conclude that industry and FAA designees have inadequate knowledge of FAA 

regulatory requirements and policies and ASTM/industry consensus standards. The 

evidentiary factors for this conclusion include: (1) inadequate application of manufacturing 

process procedures necessary to establish eligibility, (2) misinterpretations of the intent of 

FAA regulatory requirements, policy and guidance, and industry consensus standards, 

(3) misinterpretations of overall roles and responsibilities of the various industry entities 

(manufacturers, their extensions and distributors), (4) non-standardized methods and 

sequencing of airworthiness certification, and (5) uncertainty of appropriate contacts for 

needed guidance. 

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4. Industry’s system for managing, assessing, and maintaining the effectiveness of the 

consensus standards. 

The industry does not have a means to communicate with manufacturers on how to comply 

with the requirements of the consensus standards. We conclude that the process for 

evaluating compliance with the standards and taking corrective action needs significant 

improvement. Additionally, the process for maintaining and updating consensus standards 

needs improvement. 

RECOMMENDATIONS 

The team developed its recommendations based on data analysis, conclusions, trending 

indicators, and industry responses to a questionnaire. Specific recommendations are located in 

section 2.1 through 2.8 of this report, and the following summarizes those recommendations: 

Industry 

 Take immediate steps to fully comply with FAA regulatory and consensus standard 

requirements. 

 Standardize the continuous airworthiness notification process for all LSA types. 

 Develop training to ensure industry fully 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 manufacturers, 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, registration marking, and designee management. 

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

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

 Continue oversight of the LSA manufacturers to assure compliance with FAA 

requirements and ASTM consensus standards. 
INTRODUCTION

1.0 BACKGROUND

1.0.1 Light-sport Aircraft Manufacturers Assessment 

On July 16, 2004, the Federal Aviation Administration (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 for operation on water) and are heavier and 

faster than ultralight vehicles. LSA include airplanes, gliders, balloons, powered parachutes, and 

weight-shift-control aircraft. Adoption of the rule 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 manufacture 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 Manufacturers 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 evaluation, analysis, and reporting under a continuous improvement 

process, and to provide recommendations to enhance aviation safety. 

1.0.2 Assessment Team 

AIR-200 chartered and sponsored an assessment team. The team comprised individuals from 

AIR-200, the Aircraft Engineering Division (AIR-100), the International Policy Office (AIR-40), 

Flight Standards Service, Aircraft Maintenance Division (AFS-300), and the Aircraft 

Certification Service Small Airplane Directorate (ACE-114). A listing of these participating 

offices is provided in appendix C to this report. The team was responsible for developing 

assessment questions and data gathering tools, performing evaluations, analyzing data, and 

developing conclusions and recommendations. All items were developed with team consensus. 

The team also developed a team operating agreement, which outlined steps to take if a significant 

safety issue requiring immediate action was discovered during an evaluation. 

1.1 SCOPE

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 

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LSA industry as a part of FAA safety oversight. The FAA did not use the assessment and 

evaluation of collected data for individual light-sport manufacturer compliance audits. 

1.2 METHODOLOGY

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 this 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 facility types is presented 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

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Population = 52 

The sample size was determined by performing calculations based on various confidence levels, 

assuming a standard distribution. No differentiation was made for facility type or aircraft type. 

The calculations consider confidence level, degree of variability, and sample precision. Table 1 

presents the confidence levels and associated sample sizes. Calculations were based on choosing 

a degree of variability of 30 percent and sample precision 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 population as of June 8, 2008. 

This confidence level corresponds to a 93 percent confidence that the results 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), Georgia (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 standard 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 current 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/Distributor Assembly Procedures and Documentation System 

 Compliance to ASTM Design Standards 

 Manufacturer’s Quality Systems 
 Maintenance Procedures and Documentation System 

The team further identified subtier categories of questions within each major section. 

1.2.4 Data Collection and Analysis Process 

The team used both formal and informal data collection methods during this assessment. The 

methods included auditing techniques, interviewing, 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 applicable (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 worksheet is provided below (figure 3). 

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Figure 3. Sample Question Worksheet
1.2.5 Manufacturer’s Facility Questionnaire 

In addition to gathering data based on specific questions, the team gave the assessed LSA 

facilities an opportunity to contribute information they considered important. During each 

assessment, the team gave a representative of the facility a Manufacturer’s Facility Questionnaire 

and return envelope addressed to AIR-200. Before the start and during the out brief of each 

assessment, the team requested that the representative 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 aspect of the assessment and about 

LSA in general. The results of the questionnaire are discussed 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 manufacturers. However, in conducting the 

assessment, the team discovered that over half of the participants were distributors. 

The assessments were limited to LSA facilities located in the United States, but many 

LSA aircraft involved in the assessment 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; however, the number of questions 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 could not respond to design or manufacturing-specific questions, 

especially if the design or manufacturing activities took place in a foreign country, 

 Some questions were tailored to very specific activities (for example, assembly by 

distributors) which were not common to all participants, and 

 Some questions asked about specific types of aircraft (for example, 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 relative to the number of 

respective participants. For example, the assessment included 22 airplane manufacturers/ 

distributors and two glider manufacturer/distributors. 

1.3 ORGANIZATION OF THE DATA ANALYSIS/DISCUSSION SECTION

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). 

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The 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/Distributor 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 Questionnaire 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 major group. It begins with a general narrative that 

summarizes a major group, followed by overall conclusions and recommendations that apply to 

the major group. 

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DATA ANALYSIS/DISCUSSION

2.0 ANALYSIS― GENERAL OVERVIEW

The FAA conducted this assessment at 30 manufacturers, extensions, and distributors. All 

provided unrestricted access to their LSA facilities. During the interviews the participants were 

cooperative and willing to answer questions to the best of their ability. The LSA facilities 

involved significantly contributed to the successful completion of this assessment. 

This report recommends correcting and improving several different areas of the LSA 

manufacturing industry and FAA policy and guidance. Many of the companies surveyed during 

this assessment exhibited exuberance and confidence in their contribution 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 come 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 manufacturer’s ability to demonstrate compliance varied a great deal. 

Conclusion: LSA manufacturers could not fully 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 establish periodic meetings to work towards full 

compliance with FAA regulatory and policy requirements. 

2.0.2 Initial Conformity Check 

Most of the aircraft reviewed during 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-time LSA models. The initial 

acceptance evaluation should include document review, manufacturing record 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 

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consensus standards, 14 CFR part 21 rules, and any LSA-related policy and guidance. The 

evaluation should encompass all requirements of the applicable standards. 

Conclusion: LSA evaluated as a part of this assessment 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, including standards, any regulatory required 

documentation and records review, along with 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. Manufacturers, their extensions 

and distributors could not show that they adhere to all consensus standard requirements. 

Additionally, many LSA facilities had no process in place to conduct external or internal audits. 

For those LSA facilities that did have audit programs in place, there was no corrective action 

process to address audit findings. 

To assure compliance, a light-sport manufacturer oversight program with periodic evaluations of 

LSA manufacturers, their extensions and distributors should be considered. The evaluation 

should sample design elements, quality system elements, continued airworthiness system 

procedures, marking requirements, production control systems, and maintenance publications 

applicable to LSA. An oversight program should 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 should be required to implement corrective action 

plans for findings discovered during the recommended oversight activities. 

Conclusion: The LSA industry is not adequately conducting oversight of its 

manufacturing operations. 

Recommendation: Industry should continue assessments of LSA manufacturers, 

extensions, and distributors. 

2.0.4 Advisory Material 

Many LSA facilities showed weaknesses in written procedures, knowledge, or experience (see 

section 2.7, Manufacturer’s Facility Questionnaire) related to the design, manufacture and 

continued airworthiness of LSA. LSA manufacturers need advisory material describing basic 

elements of manufacturing, design, quality, and continued airworthiness systems to include: 

 Continued airworthiness processes. 

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

 Processes for design elements, including testing methods to substantiate design. 

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

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 Explanation of the proper sequencing and importance for completing the aircraft before 

issuing an LSA certificate. 

 Major repair and alteration processes. 

 Maintenance instructions and their distribution. 

Conclusion: The LSA manufacturing industry lacks sufficient guidance to ensure 

compliance to FAA rules and FAA-accepted consensus standards. 

Recommendation: FAA should update existing policy (Advisory Circulars and Orders) 

pertaining to airworthiness certification requirements, registration marking, and designee 

management. 

2.0.5 Consensus Standards 

The content and development of the FAA-accepted consensus standards is currently the 

responsibility of the standard setting bodies. The FAA reviews consensus 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 current FAA-accepted consensus standards are ambiguous 

or lack basic requirements. Many of the consensus standards lack processes and requirements for 

creating records or traceability. 

Conclusion: Consensus standards need clarification 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 necessary. Dedicated resources should be provided 

for continuous maintenance. 

2.0.6 Designated Airworthiness 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 documentation, 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. 

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2.0.7 Availability of Safety Critical Information 

The LSA industry currently uses safety directives and safety alerts to disseminate safety critical 

information. ASTM requirements to disseminate that information to appropriate airworthiness 

authorities and owner/operators differ by type of aircraft (powered parachute, airplane, etc). The 

assessment results show that LSA manufacturers lack adequate systems to develop and distribute 

safety critical information. 

Conclusion: The current system for distributing safety alerts and safety directives for 

LSA aircraft is inadequate. 

Recommendation: Industry should standardize the continuous airworthiness notification 

process for all types of LSA. 

Recommendation: The FAA should establish a process to receive safety alerts, 

directives, and other pertinent information. 

2.0.8 Industry Training 

The LSA industry has been in existence for approximately 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 portion of LSA manufacturers were 

unaware of standard manufacturing practices and processes used throughout 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 regulatory and policy requirements, and the 

methods and means to comply with those requirements. FAA designees will be trained 

by the FAA. 

2.1 CONTINUED AIRWORTHINESS SYSTEM

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 recommendations are provided for those resultant areas. 

Data shows that some manufacturers provide insufficient and or inadequate instructions for their 

customers to comply with manufacturer safety directives. Related data supports a need for clear 

instructions and procedures to increase manufacturer’s understanding of compliance to standards 

in general, regarding flight and service difficulty issue requirements, and concerning operations 

safety risk assessment procedures. In response, the assessment team recommends that the 

consensus standards clarify where instruction requirements for safety directives are located. 

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And, that those instructions address all related processes and procedures for their implementation 

to achieve comprehensive continued airworthiness support. 

Additional data indicates that some manufactures lack procedures to ensure that, as equipped, 

LSA will comply with applicable ADs. Although a majority of the LSA facilities assessed do 

not integrate type-certificated products into their design, some use type-certificated products and 

technical standard order (TSO) components. The LSA manufacturer is responsible for ensuring 

the continued airworthiness of all equipment installed on any of its aircraft certified as SLSA. 

The team therefore recommends the LSA industry standards body, in conjunction with FAA 

requirements and policy, develop guidance to clarify 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 service bulletins to the FAA but had no procedure in place. 

Although there is a requirement in the consensus standards to provide safety directives to the 

appropriate civil aviation authorities, 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 directives be provided to civil aviation authorities for all types of LSA. 

The second is that the FAA should consider developing and implementing a system to receive 

and maintain service bulletins. The FAA should also provide guidance 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 source of critical safety information for LSA 

owners. Without adequate procedures to maintain owner information, LSA manufacturers may 

be unable to ensure that all their 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 recommends reviewing and verifying the LSA facility’s continued 

airworthiness process for notification during initial and periodic assessment of LSA facilities. 

Another area that requires improvement is compliance to standards for records, adherence to 

procedures, and verification that the continued airworthiness system is functioning to consensus 

standards. Some LSA manufacturers inadequately comply with consensus standards when 

performing risk assessments of customer identified 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 

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records showing the performance of those risk assessments. The lack of performance and 

records can inhibit the ability of manufacturers to perform adequate safety investigations. 

The assessment team recommends that manufacturers conduct an immediate review of safety 

directives they have issued. The review must include an application of risk assessment, with 

appropriate actions taken. In addition, a review of an LSA facility’s risk analysis procedure and 

compliance to the appropriate consensus standard should be completed during initial and 

periodic assessments of all LSA facilities. 

Seventy percent of LSA facilities provide a system that complies with the consensus standard in 

its present form. Many LSA facilities lacked processes and procedures to properly verify 

operation of their continued airworthiness systems. Low scores for the supporting questions 

indicate that the LSA manufacturers are not sufficiently verifying that their continued 

airworthiness system is functioning properly. 

One recommendation is that manufacturers review 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 that during initial and periodic 

assessments of all LSA facilities a review of the LSA facilities’ continued airworthiness process 

for notification and verification including corrective actions taken, 

Very few manufacturers have procedures or a system in place to ensure their design data and 

continued airworthiness notification systems remain accessible and viable should the company 

cease to exist. 

The team recommends that continued airworthiness processes be reviewed for adequate 

provisions that allow LSA operators access to the design data should the LSA company cease to 

exist. In addition, the review should be verified during initial and periodic assessments of LSA 

facilities. 

2.2 PRODUCT CONFORMITY TO REGULATIONS

2.2.1 General Discussion—Product Conformity to Regulations 

An analysis of the data gathered in the Product Conformity to Regulations section shows both 

positive and negative conclusions. 

Some of the positive outcomes are noteworthy. Specifically FAA Form 8130-6 and 

FAA Form 8130-7 have been properly completed 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, LSA manufacturers are generally providing the 

minimum required aircraft documentation. 

However, some manufacturer’s lack documented design 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 consensus standards should include requirements to 

develop and follow written procedures for design control systems. 

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In addition, some manufacturers are inconsistent in properly placarding aircraft systems and 

instruments. Fuel system placards were missing or incorrect in showing fuel grade or fuel tank 

capacity. Instruments were not marked in accordance 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 parachutes on the aircraft were not externally 

marked. Emergency parachutes incorporate ballistic deployment devices and can be 

inadvertently discharged if mishandled. Some LSA manufacturers are not complying with 

marking and placarding requirements of FAA regulations and FAA-accepted consensus 

standards. Therefore, an LSA oversight program should be established to include initial 

compliance audits and periodic evaluations of LSA facilities Manufacturers. 

A third of aircraft surveyed did not fully comply with the proper display of the words “LightSport” per 14 CFR § 45.23, Display of marks; general. 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 in the original rule for “lightsport” marking.

Some FAA DARs lack an understanding that manufacturers must obtain a special flight permit to 

conduct production flight tests. Furthermore, some DARs lack an understanding regarding 

application and eligibility requirements for issuing certificates to LSA. These are basic 

certification requirements that should have been reviewed by the DAR and corrected by the 

manufacturer before issuance of an LSA certificate. Survey results show some FAA DARs do 

not have a clear understanding of the requirements for issuing an SLSA certificate. 

Some LSA manufacturers lack experience and knowledge in manufacturing 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 developing procedures that include information regarding where to obtain 

and how to use the latest FAA-accepted consensus standards. 

2.3 MANUFACTURER EXTENSION/DISTRIBUTOR ASSEMBLY PROCEDURES AND 

DOCUMENTATION SYSTEM

2.3.1 General Discussion—Manufacturer Extension/Distributor Assembly 

Procedures and Documentation System 

This section addresses LSA that are manufactured outside the United States. The results are 

representative of a portion of the distributors and dealers surveyed. The assessment results 

demonstrated that some manufacturers lack controls and successive (flow-down) processes for 

quality system requirements, procedures, records, and practices. Although most of those 

surveyed have written authorization to perform 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 14 
The ASTM consensus standards 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 distributors. However, 

weight-shift-control aircraft (ASTM Consensus Standard F2448-04) do not have the requirement 

and powered parachute (ASTM Consensus Standard F2240-05, section 2.2) allows assignments 

to distributors if “the [quality assurance] QA procedures provide 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 extensions, 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 information should be accomplished through documented 

procedures, processes, practices and recordkeeping 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 standards for quality assurance require manufacturers 

to conduct initial and periodic compliance audits of their extensions, distributors, 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 manufacturing requirements and consensus standards. 

Another recommendation is that the consensus standards for quality assurance should require a 

documented process and records for identifying 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 individual(s) performing the quality tasks. 

A third recommendation is the establishment of specific requirements for a calibration system. 

Consensus standards should require manufacturers to use recognized calibration system 

standards. This calibration system should encompass all instruments, measuring devices, and 

tools necessary for the manufacturing and assembly of LSA. These new requirements should be 

applied consistently to all types of LSA. 

Some FAA DARs inconsistently applied eligibility regulations for the issuance of SLSA 

certificates of airworthiness. FAA DARs issuing airworthiness certificates inconsistent with 

FAA directives is of particular concern. The team encountered three common problems during 

the evaluations concerning inconsistent application of FAA regulations and policy: (1) DARs 

issued SLSA airworthiness certificates before completion of production or required flight testing; 

(2) DARs issued SLSA airworthiness 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 15 
of the distributorship or of a manufacturing facility performing assembly, quality and testing 

functions of the aircraft. 

The team noted an instance where a DAR who issued the SLSA airworthiness 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 SLSA certificate, and performed 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 performed according to national FAA policy within a controlled process 

and area, with the appropriate flight permit, and before a DAR issues an SLSA airworthiness 

certificate. 

The LSA team recommends the issuance of advisory material for the LSA manufacturing 

industry that explains proper sequencing 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 controlled process and area (operating limitations) with 

the appropriate flight permit. FAA Order 8100.8 paragraph 704 (f.) includes the requirement 

that no DAR may issue an airworthiness certificate for an aircraft on which that DAR performs 

maintenance, mechanical functions, or inspections. The Order should contain a further conflict 

of interest clarification when LSA DAR are owners, principle partners, managers or employees 

of the company that has applied for the airworthiness certificate. In addition, the FAA should 

expand the mandatory training in pertinent airworthiness 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 participants did not have sufficient assembly 

instructions in either separate form or within the maintenance manual. Personnel are sometimes 

not provided with written instructions or diagrams to accomplish the task. This condition is 

inconsistent with industry practices for producing airworthy aircraft 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 recommends a periodical audit 

of manufacturer extensions, distributors, and dealers for conformity of operation. 

2.4 COMPLIANCE TO ASTM DESIGN STANDARDS

2.4.1 General Discussion—Compliance to ASTM Design Standards 

Based on an analysis of the responses to the questions in this section, the assessment team 

concluded that many LSA manufacturers lack the experience and knowledge necessary for 

proper development of design control systems. 

5/17/2010 Page 16 
The team recommends that the industry publish guidance to assist LSA manufacturers in 

developing design control systems and procedures. 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 foreign LSA manufacturers. 

Most LSA are manufactured in whole or in part in a foreign country. Of the 30 LSA facilities 

assessed, seven currently produce domestically designed aircraft. In almost all cases of LSA, 

where most or all of the aircraft is manufactured outside the United 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 manufacturer’s extensions that indicate 

foreign manufacturers use their own national standards as well as FAA-accepted ASTM 

consensus standards. Rarely could the team find evidence showing comparability of the foreign 

national standard in the FAA-accepted ASTM consensus standard. 

The lack of conclusive data can be remedied by expanding this assessment to LSA manufacturers 

in other countries. However, consideration must be given to the higher cost and resource 

requirements of conducting assessments outside the United States. Comparing the response to 

questions from foreign and domestic manufacturers reveals very similar 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 needed to implement some of the recommendations in this report 

regardless of the results of additional assessments. 

There is evidence that some foreign manufacturers 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 for the signoff of the proper ASTM consensus 

standards on FAA Form 8130-15. As with domestic 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 facilities. Forty six percent of the manufacturers 

complied with the ASTM consensus standard requirement that all flight speeds be presented in 

calibrated airspeed. Some manufacturers performed inadequate tests or no tests for spin 

characteristics. And, there was a 62 percent compliance rate for documenting alternate methods 

of compliance. Additionally, some manufactures could not demonstrate compliance to usable 

fuel testing requirements. The analysis for these responses demonstrates a lack of compliance to 

the design standards. 

As stated in the first paragraph in this section, analysis indicates few LSA manufacturers have a 

system to check for the latest FAA-accepted design standard revision. The lack of an adequate 

system in this area indicates manufacturers are using design standards that are out dated or not 

yet accepted by the FAA. These are basic LSA requirements that the DAR should question, 

review, and require the manufacturer to correct before issuing an SLSA certificate. Some FAA 

DARs do not have a clear understanding of the requirements for issuing an SLSA certificate. 

Also, some FAA DARs do not have a clear awareness of their ability to require the manufacturer 

5/17/2010 Page 17 
to provide evidence supporting the statement of compliance, particularly with respect to required 

documents. The FAA should improve FAA inspector and LSA DAR training programs, and 

enhance oversight of LSA DAR performance. 

 For foreign manufacturers, simply conforming to domestic CAA requirements may not ensure 

compliance to the LSA rule. The team recommends that the ASTM consensus standards include 

language directing the LSA manufacturer to use only those design 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 airworthiness of aircraft 

designed and built to prior standards in effect at that time. 

Finally, some manufacturers did not perform a peer review of design calculations. In a technical 

profession, the concept of peer review is a significant factor in assuring the quality of work when 

that work will not be proven by a demonstration test. The ASTM committee should mandate 

second party review of design calculations that are not proven by demonstration test.

2.5 MANUFACTURER’S QUALITY SYSTEMS

2.5.1 General Discussion—Manufacturer’s Quality Systems 

There were some positive conclusions regarding 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 standards. Robust quality assurance programs are 

essential to ensure that manufactured aircraft conform to the stated design and are in a condition 

for safe operation. The assessment noted that there was a specific lack of procedures and 

objective evidence at many LSA facilities for a proper tool and gage system to control calibrated 

tools. Another specific area the team found lacking is receiving inspection. There was little 

evidence of “supplier control”, an integral part of adequate receiving inspection systems. The 

quality systems also lacked definition of roles and responsibilities as well as a process for 

delegation authorization. In some cases the manufacturer’s quality assurance program did not 

provide adequate controls of special processes, such as welding. The team also was made aware 

of manufacturers using informal, or undocumented, interim inspections and tests. Informal 

quality systems provide for inconsistent results and may compromise conformity of the items 

produced. 

The LSA manufacturing industry requires more guidance 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 production approval holders. The FAA could adapt 

much of the existing published guidance for development of an LSA-specific AC. The guidance 

5/17/2010 Page 18 
also should address the quality weaknesses identified during this assessment, such as 

development of a quality manual, control of special processes, receiving inspection procedures, 

supplier control procedures, tool and gage control procedures, and incorporation of in process 

inspections and control systems. The guidance should also address the importance of 

establishing a complete recordkeeping system. 

Many LSA manufacturers do not perform or maintain records of internal quality system audits. 

In the last few decades, FAA manufacturing has focused on internal audits by production 

approval holders as a key ingredient in any quality system. The practice of self checking is 

recognized as a good system to correct deficiencies in quality programs. The consensus 

standards require LSA facilities to perform internal audits of their quality system on a 

12- or 24-month basis. 

Some LSA facilities do not maintain 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 adequate 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 evaluated 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 checklist. Finally, conduct 

periodic evaluations for all LSA facilities to ensure continued compliance to FAA rules and 

FAA-accepted consensus standards. 

2.6 MAINTENANCE PROCEDURES AND DOCUMENTATION SYSTEM

2.6.1 General Discussion—Maintenance Procedures 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 requirements of ASTM Consensus Standard F2483-

05. This indicates that the consensus standards are not prescriptive enough. More prescriptive 

consensus standards would enable manufacturers to write maintenance manuals that better meet 

the intent of the standards. Better written manuals would help eliminate confusion for owners, 

mechanics, airports, regulatory officials, and aircraft and component manufacturers who use 

those manuals. 

5/17/2010 Page 19 
Some LSA manufacturers have a low understanding of how to comply with numerous sections of 

the consensus standard. While most maintenance 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 surveyed could not provide documentation to 

demonstrate they were in compliance with the consensus standard requirements 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 understanding of how to comply with this area of the 

consensus standard. Less than half of the manufacturers surveyed followed the 

ASTM consensus standard and provided written instructions on how to perform major repairs or 

alterations. Some manufacturers lacked any documented system and, throughout the assessment 

surveys, sought clarification from 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 general lack of understanding for the concept of major repairs and 

alterations for LSA. Further, the survey results show that currently there is a lack of control of 

major repair and alteration processes which could pose a serious safety concern. 

Data also revealed a lack of objective evidence that manufacturers provided task specific training 

as required by the consensus standards. 

The series of questions that address maintenance manual revisions and change distribution 

scored high and low. The ASTM Consensus Standard F2483-05, section 5.1.12, Revisions, 

requires maintenance manuals to contain a “section, such as a change history table, for the listing 

of any revisions to the maintenance manual by the 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 controlling or distributing maintenance manual revisions and changes, 

the survey analysis results reveal another potential safety concern. Only half of the 

manufacturers had a documented process to revise and distribute changes to their LSA 

maintenance instructions. Of those who had a process, less than half had a method to inform 

LSA owners of the changes and revisions. And, only four LSA facilities had a system to verify 

that owners received maintenance manual changes. 

Of those surveyed, about half were in compliance with ASTM Consensus Standard F2483-05, 

section 5.1.1.1, which requires an equipment listing in their maintenance manual. In some cases, 

their equipment lists were found in locations other than their maintenance manual. Many did not 

include adequate maintenance instructions for their installed equipment or track their equipment 

to inform LSA owners of changes or equipment maintenance instructions. This reinforces the 

conclusion that manufacturers are accomplishing the requirements of ASTM Consensus Standard 

F2483-05, section 5.1, with an inconsistent degree of detail and documentation, and that the 

ASTM consensus standards need to be more prescriptive. 

The questions which addressed ASTM Consensus Standard F2483-05, section 8, Overhaul, were 

removed from the survey because of team misinterpretation. Nevertheless, the team noted that 

LSA survey participants also did not have a clear understanding of the consensus standard for 

5/17/2010 Page 20 
overhaul manual requirements. This supports the team’s first conclusion that the ASTM 

consensus standards are not prescriptive enough. 

2.7 MANUFACTURER’S FACILITY QUESTIONNAIRE

2.7.1 General Discussion—Manufacturer’s Facility Questionnaire 

The team gave a Manufacturer’s Facility Questionnaire to the 30 LSA facility participants in the 

assessment surveys. The questionnaire was 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 the response length or topic. 

The questions solicited suggestions for improvement from the LSA facility’s point of view, and 

were designed to identify best practices to benchmark. 

The FAA received five responses (approximately 17 percent) which were analyzed. 

2.7.2 Manufacturer’s Facility Questionnaire Results—Analysis Summary 

The responders seem satisfied with FAA regulations on LSA, and believe that the status quo is 

appropriate and not burdensome. However, the responders expressed concerns about FAA 

standardization of policy and guidance, and receiving 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 accurate information concerning 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. Collectively, 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 consensus standards. Three respondents stated 

that the standards meet their needs, and two respondents indicated that improvements are 

necessary, citing gaps in the standards, 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 detailed steps for this process. The team has made no specific 

recommendation in response to this comment. 

Another respondent suggested changing the FAA aircraft registration process 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 determined that the requirement is 

justified, the rationale should be included in advisory material for LSA manufacturers. 

5/17/2010 Page 21 
5/17/2010 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 the FAA develop a process to perform initial 

conformity checks and continuous oversight evaluations that includes foreign LSA 

manufacturers. This recommendation is addressed throughout the report. 

The second suggestion is for a central collection point for OEM equipment service bulletins and 

other LSA regulatory information. This concept could improve safety for the LSA community, 

particularly with regard to continued airworthiness notification and maintenance. The team 

recommends developing a system for a central data collection point. As previously noted, the 

team recommends the establishment of a public Web site to post LSA safety alerts and safety 

directives. 

The third suggestion is that the FAA should reduce the response time for petitions for exemption. 

This report does not include a recommendation for improvement in this area because it is outside 

the scope of this assessment. The team will forward this suggestion to the appropriate 

FAA office. 

2.8 OTHER DATA

2.8.1 General Discussion—Other Data 

This assessment gathered company biographical information. The team asked questions about 

the nature of each facility’s business 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/distributors 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 aircraft design and manufacturing backgrounds. 
APPENDIX A. ACRONYM LIST

14 CFR Title 14, Code of Federal Regulations 

ACE-114 FAA, Aircraft Certification Service, 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 Certification Service, Engineering Branch 

AIR-200 FAA, Aircraft Certification Service, Production and Airworthiness Branch 

ASI aviation safety inspector 

CA continued airworthiness 

CAA civil aviation authority 

CAS calibrated airspeed 

DAR designated airworthiness 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 
APPENDIX B. GLOSSARY

The definitions below are for the 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 standard atmosphere at sea level 

Civil aviation authority. A government agency from any country with responsibility for 

civil aviation within that country or jurisdiction. 

Conformity. A generic term used in reference to the adherence to the approved design of the 

manufacture of an aircraft or part thereof. 

Consensus standard. A standard or group of standards developed by recognized industry 

entities. In the context of this report, this term may also refer to ASTM consensus standards and 

FAA-accepted consensus standards. 

Corrective action implementation and feedback system. An element of internal audit systems 

that incorporates a means to correct deficiencies and verify the implementation of corrections. 

Designees. Individuals or companies 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 airworthiness 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 model built by an LSA manufacturer that 

meets the 14 CFR § 1.1 definition of an LSA. 

Flutter. A self-feeding and potentially destructive 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-1 
Indicated airspeed. Speed of an aircraft as shown on its pitot static airspeed indicator calibrated 

to reflect standard atmosphere adiabatic 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 that, 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 intended for operation on water; or 1,430 pounds 

(650 kilograms) for an aircraft intended for operation on water. A maximum airspeed in level 

fight with maximum continuous power (VH) of not more than 120 knots CAS under standard 

atmospheric conditions at sea level. A maximum never-exceed speed (VNE)of not more than 

120 knots CAS for a glider. A maximum stalling speed or minimum steady flight speed without 

the use of lift-enhancing devices (VS1)of not more than 45 knots CAS at the aircraft’s maximum 

certificated takeoff weight and most critical center of gravity. A maximum seating capacity of 

no more than two persons, including the pilot. A single, reciprocating engine, if powered. A 

fixed or ground-adjustable propeller if a powered aircraft other than a powered glider. A fixed or 

auto feathering propeller system if a powered glider. A fixed-pitch, semi-rigid, teetering, 

two-blade rotor system, if a gyroplane. A nonpressurized cabin, if equipped with a cabin. Fixed 

landing gear, except for an aircraft intended for operation on water or a glider. Fixed or 

retractable landing gear, or a hull, for an aircraft 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 SLSA airworthiness 

certificates. 

LSA facilities. A generic term that includes LSA manufacturers, 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 the 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-2 
5/17/2010 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 manufactured 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 purposes only. Ultralight 

vehicles do not have any U.S. or foreign airworthiness certificate and, if un powered, weighs less 

than 155 pounds. If powered, an ultralight vehicle 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 has a fuel capacity not exceeding 5 U.S. gallons, is 

not capable of more than 55 knots calibrated airspeed at full power in level flight, and has a 

power-off stall speed that does not exceed 24 knots calibrated airspeed. 

VH. Maximum speed in level flight with maximum continuous power. 

VS. Stalling speed or minimum steady flight speed at which the aircraft is controllable. 

Weight-shift-control aircraft. Powered aircraft with a framed pivoting wing and a fuselage, 

controllable only in pitch and roll by the pilot’s ability to change the aircraft’s center of gravity 

with respect to the wing. Flight control of the aircraft depends on the wing’s ability to flexibly 

deform, rather than the use of control surfaces. 
APPENDIX C. PARTICIPATING OFFICES

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, Engineering, 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 Specialist, AIR-40, International 

Policy Branch 

5/17/2010 Page C-1 
APPENDIX D. FIGURES

The following figures present weighted averages from the assessment, grouped first overall, and 

then for each of the six major sections of the assessment (assembly procedures, product 

conformity to regulations, maintenance procedures and documentation, continued airworthiness, 

quality system, and compliance to design standards). 

For the overall chart, the bars represent the weighted 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. 

OVERALL

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-1 
MANUFACTURER EXTENSION/DISTRIBUTOR ASSEMBLY PROCEDURES AND DOCUMENTATION 

SYSTEM (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

Receiving

Subgroup

- Weighted Average +

Figure 2. All Facilities (MEDAPD) 

PRODUCT CONFORMITY TO REGULATIONS (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 Definition

Subgroup

- Weighted Average +

Figure 3. All Facilities (PCR) 

5/17/2010 Page D-2 
MAINTENANCE PROCEDURES AND DOCUMENTATION SYSTEM (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 Manual

Subgroup

- Weighted Average +

Figure 4. All Facilities (MPD) 

CONTINUED AIRWORTHINESS SYSTEM (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

Notifications

Subgroup

- Weighted Average +

Figure 5. All Facilities (CA) 

5/17/2010 Page D-3 
5/17/2010 Page D-4 

MANUFACTURER’S QUALITY SYSTEMS (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 Record

Subgroup

- Weighted Average +

Figure 6. All Facilities (QS) 

COMPLIANCE TO ASTM DESIGN STANDARDS (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 Equipment

Subgroup

- Weighted Average +

Figure 7. All Facilities (CDS)