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 December 2005 Case Study
Tim Kern is an aviation marketing consultant and writer whose work appears in several publications. He also teaches economics and business courses, part-time, at Florida Southern College. His Web site is www.timkern.com.

Case Study

Light Sport Aircraft Industry Realizes Gains through ASTM International Standards Development

The Federal Aviation Administration’s 2005 adoption of a new class of aircraft — light sport aircraft, or LSA — was made possible by its cooperation with the aviation industry on the development of private-sector consensus standards within ASTM International. The development of a portfolio of standards, and FAA’s acceptance of them, has given an enormous boost to the light sport aircraft industry, in terms of safety, marketplace acceptance, lower costs for manufacturers and consumers, sales, and technology development. Here is how it all came about.

As baby boomers reached flying age in the 1970s, new aircraft were selling like hotcakes in the United States. By the end of that decade, however, the country was in recession and the big manufacturers (notably Cessna and Piper) had abandoned the two-seat market altogether, concentrating on larger, higher-performing, higher-margin machines.

Aviators who wanted a new two-seat aircraft were forced to build their own, using plans or rudimentary kits. These early homebuilts, as they were known, provided affordable, fun air transport. But most of the builders’ products were not subject to standard construction guidelines, their performance was unverifiable, and their engines were sometimes of dubious provenance. Though the homebuilding movement grew from the mid-1980s onward, many considered owner-built aircraft merely dangerous curiosities.

A Work-Around Emerges: Ultralights
Ultralight vehicles grew out of the 1970s hang-gliding craze, as enterprising pilots, tired of carrying their machines up hills, affixed engines of varying effectiveness to their machines (and sometimes to themselves). The FAA responded with regulation Part 103, which allowed ultralight vehicles. But ultralights were severely limited — they could carry only five gallons of fuel, and only one person; they could not overfly populated areas, or exceed 62 miles per hour; and, most restrictively, they could weigh no more than 254 pounds empty. Offsetting that, there was no pilot’s license needed (which meant no flight training) and the cost of the vehicles was low.

[This paragraph was printed without attribution, which is: "Jim Campbell,Aero-News Network, January 7, 2002, www.aero-news.net." We Apologize for any inconvenience this oversight may have created.]

In the late 1980s and early 1990s, an attempt was made to expand the offerings of simple light aircraft by creating a new category known as “primary category.” Unfortunately, the two big attractions of ultralights — simplified pilot training and low-cost vehicles — were primary category’s largely unaddressed needs; the category thus evolved into merely another class of standard aircraft, but one with significant operating limitations. By the time the category was approved and viable, few manufacturers were enthusiastic and what had initially seemed like a good idea was virtually stillborn. The cost of production and certification were no different from the existing FAA certification system prior to the new category’s introduction.

But a Need Remained
What was needed, industry and enthusiasts agreed, was a return to basic and safe aviation. Fancy navigation, night-flying capability, and retractable gear, for instance, were unnecessary. The market was seeking simple, safe, affordable and functionally appealing personal aircraft for aspiring pilots who didn’t want to take out a second mortgage to pay for flying lessons.

Many manufacturers provided such aircraft in the form of kits. There was a problem, however. The FAA’s regulations required that kit aircraft be built by the owner and many prospective fliers had no desire to build; many others lacked time or suitable space for personal airplane factories. A factory-built light aircraft was the obvious answer, but the industry, stifled by old regulations and procedures that handicapped more modern technology, was not prepared to fight the anticipated bureaucratic battles.

The return to “basic and safe aviation” again began to take root, picking up where Primary Category fell short. Momentum built around a proposed regulatory framework now dubbed “Sport Pilot,” which officially introduced light sport aircraft, or LSA. As the name implies the focus was to bring the fun and simplicity back to aviation in a fashion that was more or less recreational, or “sport.”

By century’s end, the problem was again achieving critical mass. Michael Gallagher, who ran the FAA’s Small Aircraft Directorate from Kansas City, remembers, “Industry looked at the heavy ultralights, and realized these needed to be certificated [made legal] in some way to support the Sport Pilot Rule. The FAA didn’t have the resources or the inclination to develop rules and certify a new aircraft industry. Tom McSweeney, Beth Ericson and I were approached by the the Experimental Aircraft Association in 1998 and asked how we would certify the aircraft to support the developing Sport Pilot Rule, which contained language that indicated the aircraft would be certified, though it did not say how. We had the problem of integrating these, especially two-seat trainers, into the ongoing Sport Pilot Rule.”

Gallagher remembers the early discussions. “We had to have a vehicle that is different from regular certification, one that will not cost FAA resources. We then thought that industry involvement may be a way to do this. What if we develop consensus-based standards as a method of self-certification? We saw the standardization of design, construction, and quality assurance in the ultralight industry, where there were no standards, and we saw an increase in safety if we had standards and had the machines conform to the standards. Ultralights had no rules in construction, quality control, and so on, so there was a lot to do. For example, we defined clean stall speed first (45 knots); you have to have a design spec that will make that work, and that limits your top-end speed. We didn’t want people with all sorts of advanced, complicated aerodynamic devices going 200 knots with these little things, so we said, ‘No, that won’t work. Just keep it simple.’ We said, ‘How do we make LSA, and particularly integration of two-seat ultralights, work as a win-win for industry and the FAA?’”

Diverse enthusiast groups had their core interests at heart, but none was sufficiently expert to cover everything and no one had the ability to simply step in and write comprehensive standards.

Nearly all common types of propeller-powered aircraft (gyroplanes, weight-shift, lighter-than-air, gliders, and powered parachutes, as well as airplanes, with special consideration for amphibious aircraft) had to be considered and included. (Helicopters, due to unique considerations, were excluded.) Construction materials and techniques varied widely, requiring multiple areas of expertise.

The new category of aircraft demanded that several conditions be met:

• There had to be provision for ready-built (i.e., factory-built) aircraft;
• There had to be simple flight standards and characteristics;
• The aircraft had to be sufficiently utilitarian;
• Construction, inspection, and maintenance had to follow acceptable standards; and
• Standards needed to be adaptable to changing knowledge and technology.

Enter ASTM International
Gallagher explains how ASTM International united the effort: “The FAA worked with the Experimental Aircraft Association. Earl Lawrence of the EAA had previously done work with ASTM on auto fuel, and we said, ‘Why not use that process?’ The EAA supported ASTM; the FAA didn’t have a preference, so we accepted the idea. The industry went forward, and the FAA participated in the process. Scott Sedgwick [who managed the policy branch of the Small Aircraft Directorate under Gallagher] and Sue Gardner [the team leader of the sport pilot rulemaking project], worked with the industry to come up with the basic outline for the LSA category.”

ASTM’s history of standards-development expertise, rigor and review presented the background with which industry could unite, and its infrastructure would allow the quick coordination critical to an international industry group.

Consequently, driven by industry support for the initiative, ASTM International organized a new technical committee in 2002, F37 on Light Sport Aircraft, to meet these needs. Its subcommittees address specific technical areas: propulsion and propellers, airplanes, weight-shift (also known as trikes), powered parachutes, gliders, gyroplanes, and lighter-than-air vehicles. Additionally, F37 addresses special concerns surrounding airframe emergency ballistic parachutes and compression ignition (diesel) engines. They are also developing the world’s first standards for the design of light-aircraft airparks.

ASTM’s organizational skills and information technology made fast standards development possible, regardless of geography. Scott Toland, chair of Subcommittee F37.40 on Weight Shift, notes, “Most of my membership is international. My largest producers are in France and Australia. We’ve had many meetings with these people, but never in person. ASTM’s virtual meeting system is amazing. As we talked about the revisions and changes by telephone, they would appear online in real time, before the entire group. The group would see the change and make instant feedback. The entire task group can collaborate on a document on the fly. Drafting complex standards across three continents without the virtual meeting technology would have taken forever.

“While drafting our design specification, we met for two or three hours, once a week, every week, all winter,” Toland continues. “We had a lot of issues and strong opinions. Without ASTM sponsorship of the virtual meetings, there is no way we could have done what we did.”

Quite aside from the logistics of the meetings themselves, though, was the task of getting people across the industry to agree.

Dan Johnson, heading the F37 task group covering airframe emergency parachute recovery systems, explains, “We had tried to come up with an industry consensus before. There was no government pressure then, but even if there had been, I’m not sure it could have occurred if we had relied solely on industry to establish an organization to achieve such standards. ASTM gave us a ‘shell’ into which industry could fit itself — the structure of the process. Then you deal with the standard as it evolves. There is a lot of structure that is seemingly invisible, but the [items that were essential to making up the rule] couldn’t have taken place without their help.”

Time Is Money
Within two years of its formation, Committee F37 developed a portfolio of 20 standards, with many of them completed within the first nine to 16 months, that the FAA could refer to in its regulations. Those standards were accepted by the FAA earlier this year in a Notice-of-Acceptance publication in the U.S. Federal Register.

Thomas Peghiny, whose FlightStar company imports the factory-built FlightDesign CT and Comco-Ikarus C-42 vehicles, says, “Waiting for LSA almost killed our kit business; there was serious confusion in the marketplace.” With the LSA standards now set, “business has tripled this year, compared with last. One hundred percent of that increase in business is due to getting LSA done.”

“Getting LSA done” at bureaucratic warp speed, i.e., creating the standards that led to the FAA rule, amazed and impressed the manufacturers. The light aircraft market, being largely recreational in its base, can ill-afford long delays. The process took 20 months, from go-ahead to thank-you, while regulations for new categories of aircraft often have gestation periods of over a decade. F37’s fast action literally saved many businesses and provided a solid launch platform for many more.

Larry Werth, light sport aircraft program manager for FAA’s Small Airplane Directorate, said at the announcement of the FAA rule for airplanes in April 2005, “This is the last piece of the puzzle. Now, manufacturers of fixed-wing light sport aircraft can issue their statements of compliance with the ASTM consensus standards and start selling aircraft.”

John Hickey, director of aircraft certification services for the FAA, also expressed the value of the relationship between the F37 standards program and the rulemaking process during a joint ASTM-FAA meeting as well as during a press conference at EAA’s Airventure this past July. “The value of the ASTM standards system is now becoming even more apparent,” explained Hickey when announcing the FAA recognition of another series of ASTM F37 standards through the release of a Notice of Acceptance. “While the initial effort for the first batch of standards took only 20 months, the expediency at which they can be revised is incredible. Within about three months, the standards have been revised and recirculated to accommodate regulatory and industry needs. This responsiveness means that industry and regulators can quickly implement necessary changes for safety and performance of LSA through these referenced standards.”

The Process, the Organization, the Progress, the Results
James Stephenson, chair of Subcommittee F37.30 on Power Parachute, notes, “I am very enamored with the ASTM system. We tried many times before. Without any structure, various members would just leave when things didn’t go their way. We got our powered parachute standards out years ago; we ran into one of everything, and it just worked so well. This consensus standards system is a wonderful tool to get people to interact, and to come to conclusions.”

ASTM International requires that all its standards be reviewed every five years at a minimum; to ensure its standards are up to date, Committee F37 has instituted a two-year review requirement. That keeps technology current, addresses problems, and promotes innovation and progress. As noted by Johnson, “Compared to conventional [FAA] certification, in this case, not only can the standards be changed regularly, they must be reviewed — often and regularly.”

Benefits of Standardization for Industry Technology Development
When they are designed, built, inspected, and repaired, LSA factory-built aircraft conform to all the relevant standards. Also, unlike the practice in the homebuilt world, replacement parts must conform to manufacturers’ specifications and changes to the aircraft must be manufacturer-approved.

Earl Lawrence, EAA’s vice president of industry and regulatory affairs and chair of ASTM Committee F37, says, “EAA members are often at the cutting edge of aircraft technology and development. That is a large reason why so many people build their own airplanes: modern technological development is hindered by the onerous and expensive requirements of aircraft certification. ASTM International’s regular formal review, as well as the quick and effective informal exchange of ideas among knowledgeable parties, helps ensure that the best of modern technology isn’t left waiting outside the door of a regulator’s office.”

Lawrence sees further benefits of working with and through ASTM. “The discipline of having regular meetings results in the regulators, consumers and producers maintaining regular communications about all aspects of recreational aviation,” he says. “That enables the industry to address concerns before they become major issues.”

Marketing Possibilities
Getting pilots to accept and move into LSA was one thing; getting their passengers (especially wives and friends) to climb into small aircraft is another. With homebuilt aircraft, there is a requirement that the word “experimental” be prominently displayed on the door and inside the cabin, and placards are required that explain that the aircraft in question is not certified by the FAA. That requirement has left many a prospective passenger on the ground. An LSA-certified, factory-built aircraft does not require such signage and placarding.

Though great numbers of amateur-built aircraft no doubt exceed generally accepted safety margins, there is no assurance in that world that any specific aircraft does. But in the world of certified aircraft, with the standards in place, that assurance is built-in.

Lawrence explains another big marketing advantage of having robust standards. “In regard to streamlining communications, I think the best thing I can say is that the ability to have industry standards for a class of aircraft that previously did not have standards has enabled EAA to better direct members to aircraft that we know meet certain minimum safety standards. This has enabled EAA to communicate and promote a group of manufacturers to the public and our membership that we are confident in their products because they have selected themselves by producing aircraft to a set of standards that the consumers can trust.”

Lower Costs for Manufacturers and Consumers
The process of LSA certification is greatly simplified, yet retains the safety and engineering principles that were the original industry goals. These lower costs of certification translate directly into lower costs for LSA aircraft. Simple design allows affordable, high-quality maintenance. Low operating costs assure greater utilization of the aircraft, which in turn adds to pilot currency and skill. Basic designs (e.g., the prohibition of retractable gear and in-flight adjustable propellers), along with restricted flight activity and regulated performance (e.g., daytime operation, lower-level flight, a top speed limit along with low stall speeds) keep pilot training focused on the basics, allowing earlier solo flight and quicker licensing. In addition, simple construction promotes low insurance rates.

The Bottom Line
The real response to the acceptance of LSA standards will come from the marketplace: Will the machines be affordable? Will people buy them? Will light aviation expand?

Though it is extremely early to draw conclusions, the data seem to indicate that the answers to those questions will be a unanimous “yes.” Lawrence says, “Look, a year ago, we accepted the rule. Now, we have 19 complying designs from over a dozen manufacturers. That’s huge.” Looking at preliminary numbers, data tend to indicate that LSA is indeed set to become a commercial success (unlike earlier attempts, such as recreational pilot and primary category).

With the 2005 fly-in and airshow circuit now history, manufacturer feedback is encouraging. In April, at the Sun ’n Fun Fly-In in Lakeland, Fla., the first handful of LSA designs was approved and announced by the FAA. Soon after, in late July, at the Oshkosh EAA Airventure Fly-In, many manufacturers reported that their entire 2005 production had been sold; several were sold out through 2006.

Registrations in the first few months of the LSA rule’s adoption are encouraging. According to the EAA’s numbers, updated by the FAA, the first six months of LSA show that:

• 245 new factory-built LSAs were registered;
• 289 previously existing LSAs were converted from two-seat ultralight trainers;
• 560 sport pilot airmen’s tests were taken;
• More than 100 existing FAA designated pilot examiners added authorization to administer sport pilot air tests to their qualifications;
• 43 new sport pilot designated pilot examiners were created; and
• 60 new sport pilot repairman certificates were issued.

Over 250 LSAs have been purchased from approved manufacturers; at least that many more are on order, waiting for their manufacturers to get the machines qualified on the official LSA list.

Beyond the FAA and the USA
F37’s standards are now being adopted by aviation authorities throughout the world, many of whom participated as regulators in the process or had members of their industries involved.

Johnson notes that, “Though the rule is American (FAA), the standards are adoptable worldwide. It’s already happened in Australia, and it’s ready to happen all over the world. But I don’t think that many of us in the industry were really thinking about that when we started.

“Out of 19 LSA-certified airplanes today, only three are from the U.S.; 16 are international models,” Johnson adds. “Many countries have somewhat similar processes and documentation requirements for small airplanes, so many manufacturers were at least partially ready. While they had a constraint at 450 (or 472.5 kg gross weight, with a parachute) — they were getting their designs approved locally, stripped down — they wanted a higher weight limit so they could install equipment that customers wanted. We are starting to see many pre-existing European designs get redesigned to exploit the new heavier limits.”

Additional benefits will accrue to the industry as more countries adopt the ASTM-driven standards. The FAA’s Larry Werth has had preliminary contact with the aero clubs (which govern light sport aircraft in their respective countries) of Great Britain and the Czech Republic; the civil aviation administrations of Canada, Australia and New Zealand; and individuals from Israel, Columbia and Brazil to see if the LSA standards might be acceptable for use in their countries. This could open the door to wholesale adoption of the LSA standards by many other countries, leading to global marketplace advantages for LSA producers and owners.

The international advantage of F37 should not be overlooked. Toland explains, “Aircraft standards are traditionally written as regulations. We make every effort to avoid including U.S.-specific terminology and FAA-specific regulations in our documents, so the final standard is applicable internationally.”

Toland continues, “What I have been hoping all along is that we will establish the first international standards for these aircraft. As it stands now, each country has its own unique certification requirements. This forces producers to test and retest to slightly different requirements for each market. Perhaps some day, certification in one country will be accepted by many others, which would lower the cost of doing business while serving the needs of safety.”

Future Implications
Many of the areas Committee F37 is exploring could affect the future of aviation sectors worldwide. For instance, the U.S. National Transportation Safety Board is concerned about the possible hazard that undeployed airframe emergency parachutes could pose to first-responders at accident sites. (An undeployed parachute may house a live rocket motor.) F37 members are the first to examine methods of marking parachute components with international symbols, to warn unsuspecting good Samaritans.

Committee F37 is also developing standards for airparks. While myriad standards exist for runways, airport buildings, and marking and lighting (among other items), there is no comprehensive minimum standard for an entire airpark. The nature of LSA flight makes the standardization of airpark design possible and practical. This in turn will have several benefits: airpark designers will have a base plan, municipalities will be looking at a standard airpark design (and will presumably be less likely to make undesirable changes), insurers will be operating from a baseline, and the overall design and construction will thus be simplified, hastened, and more economical. Most importantly, the airpark will be safe and adequate for its designated use.

The positive work of F37 will also most likely impact future FAA–industry interaction. In the past, aircraft manufacturers’ standards came from the FAA. This time, the FAA worked within F37. Johnson noted, “This is a hugely significant change, for FAA to participate rather than use its strength as the certifying body.”

Toland adds, “The FAA Certification Office really championed the idea of using consensus standards. Doing aircraft certification the traditional way would be absolutely impossible for LSA. There are simply too many different aircraft in the market. It has been an adjustment for some of the FAA staff. They are used to being the sole authority, but they came around and saw the wisdom of the consensus process. In this method, they’re active participants, but they’re only one vote and they do not have a veto power.”

And Stephenson concludes, “ASTM has a clear place in the future. They are already addressing unmanned aircraft systems and national airspace issues — how do you integrate manned and unmanned aircraft in airspace? ASTM’s process will get it done.”

In the final analysis, the cooperation between industry and its regulating agency, using the ASTM International consensus standards developing process, has worked wonders for the light sport aircraft sector of the aircraft industry. From increased safety, reduced costs and flight access for consumers to streamlined R&D, market access and increased sales for manufacturers, the work of ASTM Committee F37 has resulted in a win-win scenario for aviation.

Acknowledgments
The author wishes to thank the following, who were instrumental in providing background and insight:
• Gary Crump, director, medical certification services, Aircraft Owners and Pilots Association
• Randy Schlitter, RANS Aircraft
• Jon Thornburgh //

 
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