2008 ASTM International Advantage Award Second Place
Light Sport Aircraft Industry Takes Flight on ASTM International Standards
This paper demonstrates that the use of ASTM International standards in the new light sport segment of aviation provides major benefits in both cost and process. The standards for this sector, developed by ASTM Committee F37 on Light Sport Aircraft, support a new industry that is the combined outgrowth of ultralights and light general aviation. The development of these standards evolved from the new sport pilot and light sport aircraft rules released by the Federal Aviation Administration in September 2004.
In the early transition to these new LSA rules, the communities turned to ASTM International to help them frame the standards and form a solid basis for the design, development and maintenance of the LSA class. The light sport standards are the product of a cooperative effort between ASTM, the FAA, industry, associated users and potential buyers. This is the first time aircraft qualification criteria have been developed by consensus standard. The success of this effort is worth noting, especially given the expense and delay of previous processes.
Using the Private Sector Standards System
Prior to the development of the ASTM consensus standards for LSA, the FAA depended on 14 CFR Part 21 as the primary standard for certifying aircraft even for very light aircraft. According to FAA documentation, the costs for certification of one aircraft model are likely to be $20,000,000 or more when certified to the FAA 14 CFR Part 21 Regulations. Part 21 methods for FAA certification include the need for more test hardware, more test aircraft and FAA labor costs that would be exorbitant relative to the reduced complexity of these light aircraft. Airliner standards make no sense for light, relatively low-speed sport aircraft.
The product of this union, ASTM International, the aviation community and the FAA, is a set of standards for design and performance, quality control, continued airworthiness, required information, production acceptance testing and maintenance manuals for each of six different types of aircraft. These standards are providing a new way for aircraft to exist that is consistent with their form and function. The consensus standards for six different types of aircraft that have been developed and released by ASTM Committee F37 exemplify this union. No longer do these relatively simple, lower energy LSA need to be forced into an excessively burdensome governmental standard from the 1950s.
These aircraft types include powered parachute, weight-shift control, airplane, glider, gyroplane and lighter-than-air aircraft. The consensus standards are complete standards for all the key functions of design and performance, quality control, continued airworthiness, required information, acceptance testing and maintenance manuals. In total, there are currently 29 standards under the jurisdiction of Committee F37.
From the beginning of this process many people said that consensus could not be achieved in our community. The diverse opinions and strong positions on many engineering matters made this thinking appear to be correct. Yet the standards were completed and are now functioning better than anyone could have anticipated. The F37 standards are indeed an exciting product, especially given the demonstration of how the ASTM process makes agreement and consensus possible in such a diverse community.
The framework for the F37 standards has separate criteria for each key area. Standards for each type of aircraft allow requirements that best fit the unique qualities of their type. Powered parachute aircraft, for example, conform to the following standards:
Benefit to Manufacturers
Using ASTM Committee F37 standards, a manufacturer can complete the design and evaluation of its aircraft, review its own compliance documentation and sell finished aircraft. These aircraft may then be used for rental, instruction or recreation. The manufacturer finalizes this process by having a designated airworthiness representative inspect the aircraft and review the paperwork. These inspectors are knowledgeable about the aircraft type and familiar with the requirements of acceptance. DARs are trained, supervised and monitored by the FAA.
The costs for the manufacturer are reduced by applying appropriate levels of testing, tracking and evaluation. As a result, the expenses to complete the consensus standardization process are only on the order of $10,000 to $20,000, with the individual cost applied per aircraft being approximately $1,000. Compare this with FAA estimates for similar aircraft under traditional 14CFR Part 21 Certification of $20,000,000. In realizing these savings, the ASTM LSA consensus standards are a most valuable product.
New LSA models are continually being developed and are now including competitively priced units as manufacturers embrace the new system. Powered parachutes are being marketed as low as $18,000 for an ASTM-compliant aircraft that can carry two people. Some airplanes are being marketed at a cost of less than $42,000.
In comparison, even though an average price LSA airplane may reach $130,000, these higher priced versions are true bargains when compared with traditional general aviation aircraft. A low end general aviation aircraft with 14CFR Part 21 certification has retail pricing typically greater than $240,000. The LSA prices would not be possible without the consensus standard process of ASTM International.
The cost-effectiveness and appropriate application of requirements for these light aircraft contribute to the development of such a large number of models. With proper development, it is possible to design, build, test and produce an aircraft with a much lower cost and time investment. The companies that manufacture these new models are able to test their own products and complete ASTM-compliant processes within simple and affordable frameworks. Even a small entrepreneurial manufacturer can now successfully produce a new model following these standards.
The impact of these valuable ASTM consensus standards is worldwide. There are now more than 76 new aircraft models flying solely due to the creation of these standards. While 18 of these are U.S.-based, the rest come from all over the world and represent all types. These are 76 aircraft that would not exist today without the methods and support of ASTM Committee F37 and its many members.
In the case of one manufacturer, the total costs, including structural tests, flight tests and manual development, were less than $19,000. This manufacturer estimates per-aircraft costs of about $1,000. These expenses consist of DAR fees of $200 for a special flight test permit inspection, $300 for an airworthiness inspection and $300 for the added costs of special tracking and continued airworthiness. These investment costs are manageable for a smaller manufacturer.
One might argue that the number of new aircraft represents a savings of nearly $20 million per model, or $1.5 billion for the industry. That conclusion would not be accurate. At the higher costs for traditional FAA certification, many of these aircraft would not exist. The cost-effectiveness for initial setup through manufacture of the completed product would have precluded their development. The absolute face value of these standards is that they make LSA and the ensuing industry possible.
The F37 standards have provided the impetus for the certification of the many products that are needed in the manufacture of LSA. As a result, standards now exist for engines (spark and diesel), recovery parachutes, kit assembly guidance, night operations and airports. These are all products and services that would not have been completed cost-effectively in the traditional FAA environment. The F37 consensus standards process has contributed to the development of these supporting standards.
One of the driving forces in this transition was the U.S. Office of Management and Budget, which through its Circular A119 directed the FAA and other agencies to participate in the use of consensus standards for rulemaking whenever possible. The number of F37 and peripheral standards being developed clearly supports the validity of that direction.
The Value of the ASTM Process
It was a very important milestone when the LSA community turned to ASTM International for help. The process that has stood for more than 100 years is the real “gold” in this story. Committees and subcommittees, working first in series and then in parallel, produced the concepts that were then developed into the standards. Not only are these processes of consensus ones that ASTM has used for years, but processes that are expanding to include new technologies that augment the system.
The tendency is to look only at the product to evaluate a process. This fails to recognize the importance of process. Without process, there would be no product. Without good process, there would absolutely be no successful product. To understand the importance of the ASTM process, look to the aviation community failures prior to using ASTM. There are at least three examples where the light aviation community has tried to come together to complete design and performance standards to regulate the manufacturers. In each case there was a real effort to achieve a worthy goal. Organizations were formed and named, committees were established and draft documents were started. However, with no regulated process or system of managing differences or disputes, these efforts all failed to complete the needed standards.
In each case there were problems that could not be overcome. Without a clear process for dispute resolution, members would leave disgruntled that they had no say in the process. Sometimes overly zealous individuals would come to the forefront of a discussion and relentlessly fight for their viewpoints. Other business could not proceed and members left disheartened that progress toward their final goals was not achievable. Negatives would linger unresolved and result in the loss of participants. Ideas were hard to cycle within the organization and were lost. In all, it was frustrating to see well-intended efforts fail.
Enter ASTM and its processes, which have survived the test of time. Gone are the days where the cycling of ideas was difficult. Today, the ASTM process has matured; the new electronic frontier has been mastered. In an age before the Internet, there was a higher dependency on face-to-face meetings with significant costs and delays for participation. Now Web meeting systems are being used both at home and internationally. The use of e-mails promotes the early circulation of ideas and avoids the problems of specific time schedules for teleconferences or Web meetings. Early preparation enhances the process. Balloting on the Web makes responding simple and more likely to be completed on time. Web-based ballot reporting makes coordinating vote closures easier.
Technology alone is not enough to make the standards possible. ASTM International staff support committee work and make sure ideas are heard and evaluated. By assuring the appropriate circulation of ideas and balloting, standards participation is established. This is the ASTM process that guarantees an individual’s right to express their ideas and concerns and be confident that their issues will be addressed. Each person has a clear opportunity to participate in standards building.
The negative vote resolution process, when followed rigorously, as guided by ASTM staff, does not dispatch the lone voice but rather gives it a platform for fair evaluation. The individual may not be able to change the standard, but he or she is assured that the issue has been reviewed. Once stated the committee can resolve the issue and move on by either accepting the proposed change or finding it not persuasive. The person knows that he or she has been heard. The committee is not stalled on one issue. In this way negatives are addressed, they are debated and resolved within the process.
In Figure 1, the overall process can be viewed in detail. The process starts at the upper left with a task group developing a standard or change for ballot. The task group works to draft and ballot proposed standards and changes. This is the open time for input and debate. Not all issues can be fully resolved by the task group. By initiating a task group ballot, the basic concepts of the proposal can be tested.
The task group level ballot allows individuals to place a negative that stops the document’s progress until it is resolved. Under the guidance of the task group chair, the negative rationale is presented to the task group. If it is found persuasive then the document is reworked by the task group and returned for ballot. If the negative is found not persuasive, the document moves on to the subcommittee level ballot.
At the subcommittee level, the document is reviewed and balloted by the entire subcommittee and the society. A negative at this level again holds the document. If the negative voter withdraws the negative, the document can proceed to publication. If the negative is not withdrawn, the subcommittee can do one of three things, make “no motion,” make a motion of “not related” or make a motion of “not persuasive.”
When “no motion” is taken, the document must go back to the task group for rework. However, in the case of “not related” and “not persuasive” the issue goes to the ASTM International Committee on Standards for review. If the COS upholds the negative in review, the document again goes back to task group for rework. COS is responsible for the review and approval of all technical committee recommendations for actions on standards. COS verifies that the procedural requirements of the society’s regulations and its criteria for due process have been satisfied. The committee acts to resolve jurisdictional disputes with respect to standards. In the case that COS does not find against the motion, the standard is approved for publication.
Two additional levels are open to the dissenting voter. These are an appeal to COS and an appeal to the board. In each case, if the subcommittee is sustained, particularly in its process, then the document can proceed to become a standard.
This process protects the individual who has a valid issue with a standard. There are nine points at which a person can express their concern and assure rational consideration if necessary. These points include development of the document, task group ballot, subcommittee action, subcommittee ballot, subcommittee action, confirming letter ballot, COS review, COS appeal and finally appeal to the board.
This process assures the ability of the committee to proceed by using clear methods of negative resolution, all the while giving individuals clear opportunities to state their case. The subcommittee must consider the issues to proceed. Once the issue is properly considered, the committee can move forward.
Shortened Time Frames
This process works very well for light sport aviation. As an example, powered parachute ASTM standards were completed in a remarkably short nine months. This is an amazing feat considering the alternative of FAA regulations that can take up to two years for any minor change. Since 2003, the F37 committee has completed 29 standards for six types of aircraft and maintained and revised these standards to keep them current. Figure 2 shows just how quickly a set of standards can be developed. The powered parachute standards were the first standards released by ASTM Committee F37.
Expediency is part of the value of the process. In important cases, Committee F37 could complete needed changes to aircraft standards in as little as 60 days. The example of powered parachute standards shows that when there is a need, standards can be developed quickly. The ASTM process and controls are what make these standards’ development remarkably effective.
Today the ASTM standards from F37 are accepted by the FAA as shown in Table 1. These standards are being used worldwide to produce new and exciting LSA. The ASTM process has opened the door to a much broader, more affordable aviation community. Without a process to complete the product, there is no value. For LSA, the value of these products is only eclipsed by value of the ASTM process that made them possible.
Beyond the products, methods and processes are the dreams. Like the dream of flight itself, building aircraft has been a dream for many people. The light sport aircraft made possible by the use of ASTM International consensus standards allows the dream to be fulfilled by many. This value is hard to measure in mere dollars.
James Stephenson is president and CEO of Aero Sports Connection in Marshall, Mich. While his experience includes space shuttle design and certification, with a B.S. in Aerospace from the University of Michigan and an M.B.A. from California State – Fullerton, he has always focused on lighter, slower aircraft. This includes designing two one-of-a-kind light aircraft and aiding manufacturers in their design and compliance efforts. Currently, Stephenson supports the light sport aircraft industry by helping manufacturers show compliance to ASTM standards and chairs Subcommittees F37.30 on Powered Parachute and F37.60 on Lighter than Air.
Deborah Stephenson is administrative director of Aero Sports Connection in Marshall, Mich. While a registered nurse, she is editor in chief of the national magazine for light aviation, Aero Connections. She is also president and CEO of SAFE, Stephenson Aviation Fastrac Engineering. She is the secretary of Subcommittee F37.30 on Powered Parachute.