European light sport aircraft market awaits European decision

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Czech manufacturer CSA's aircraft now carry the original Sportcruiser brand after its distribution deal with Piper ended this year

It was the Federal Aviation Administration's light sport rule of September 2004 that disseminated the term "light sport aircraft".

By the FAA's definition, an LSA is a simple single- or two-place aircraft, with fixed gear and piston engine, weighing no more than 600kg (1,320lb) or, in the case of a seaplane or amphibian, 650kg.

It must have a clean-stall speed less than 45kt (85km/h) and a maximum level speed of 120kt or less. There are other parameters for stability, strength and minimum useful load.

The new rule was a big change for the FAA. Instead of the regulator dictating how aircraft were made, a group of industry professionals was tasked with developing standards.

It chose the American Society of Testing and Materials (ASTM) as the forum to develop those standards. Similar to British Standards, DIN Standards or Euro Norms, ASTM standards govern everything from fuel to electric light bulbs, automobiles, quality systems and material classifications.

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 ©AirTeamImages
Czech manufacturer CSA's aircraft now carry the original Sportcruiser brand after its distrubution dealwith Piper ended this year

A committee called F37 develops standards that are adopted by the FAA, but not every revision produced by F37 has been accepted by the regulator, which publishes a list of accepted standards on its website.

Once certificated, an aircraft is always certificated, even if regulations are updated, but an LSA manufacturer has to keep up to date with the latest revision of the standards.

The FAA applied the same logic to manufacturers' quality systems and continued airworthiness programmes. Quality system requirements are specified by a separate standard. Instead of airworthiness directives being issued by the FAA, each manufacturer is responsible for issuing service bulletins to each aircraft owner/operator.

Traditional aircraft certification requires the FAA to witness and audit each stage of the design verification. Under the LSA rule, the FAA passed complete responsibility for the validation of conformance to the manufacturer. Each LSA producer signs a declaration that the aircraft conforms to the standards applicable at the time the airworthiness certificate is granted. This gives the FAA permission to audit the producer's records at any time.

In practice, producers operate with little oversight from the FAA, except for the inspection carried out before granting a certificate of airworthiness on each aircraft. Declaration of adherence to a standard, rather than regulatory oversight, is the process used for almost all products, including fuel, automobiles and electronics. Applying it to aircraft removes a layer of FAA conformance checking.

With these new rules, and without the complex, time-consuming oversight to which traditional aircraft manufacturing is subject, LSA sales took off in the USA. Many European ultralight designs were tweaked to be LSA-compliant and certificated in the USA.

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The new aircraft classification brought a new class of pilot: the sport pilot. Limited to day visual flight rules flight, the sport pilot's training requirements are reduced to a minimum of 20h, because the instrument appreciation, radio navigation and night portions of the private pilot syllabus are omitted.

The sport pilot licence allows people to get into aviation at a more affordable level. All sport pilot training and all flying experience in LSAs count toward higher certificates.

The new rule helped LSAs find their way into flight schools, to be used for flight training for sport and private certificates, as well as for instrument training. In the six years since the rule was introduced, about 2,000 LSA aircraft have been registered in the USA.

The sport pilot rule also allowed the FAA more oversight of ultralights, for which there were previously no common pilot standards and no continued airworthiness programme.

Continued airworthiness

Ultralight pilots had to obtain sport pilot licences within three years of the rule's introduction. Also, any two-place or heavy single-place ultralights had to carry an N-registration and be subject to continued airworthiness within that same three-year period.

The sport pilot rule integrated the ultralight movement with the rest of the aviation family. Since it was introduced in 2004, a number of other countries have adopted the same rules and approach - South Korea, Israel, Australia, New Zealand and China.

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Many LSAs available in the USA originate in Europe. Quite a few are descendants of ultralights designed and produced there.

But rules covering ultralights in Europe are a patchwork, at best. The various European national authorities, while not having a common standard, at least agree on the same basic parameters: a maximum gross weight of 450kg (up to 475kg when fitted with a ballistic parachute) and a minimum stall speed of 32kt.

But that is where the similarity ends. There are anomalies, because each country has a different standard to which the aircraft must adhere, and pilot certification requirements also vary between nations. Hours flown on ultralights count toward flying experience in some countries, but not others. And only some jurisdictions impose airspace limitations.

Estimating the size of the European ultralight market is complicated by the fact that data is tracked differently by each national authority. It is conservatively estimated at 1,000 aircraft a year, which would make it three times bigger than the US market. Lower costs of acquisition, operation and maintenance are the market drivers. Countries friendly to ultralights have seen their foreign registrations grow, overcoming the hurdle of different regulations under different national authorities.

The lack of a common pilot qualification does not appear to have hampered the market, but standardising pilot qualifications and the regulation framework would make the market more attractive, and drive an acceleration of production growth.

With European manufacturers dominating the LSA export market, most are keen to sell the same products at home. On 17 April 2008, the European Aviation Safety Agency issued a notice of proposed amendment on initial airworthiness. For the new European Light Aircraft (ELA) category subject, the working group MDM.032 set out to define similar design limitations as LSA in the USA.

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First European delivery of a Cessna Skycatcher is due this year

It was aiming to pull the diverse "microlight" and "ultralight" categories across Europe under rules that share traits with LSA rules. At the time, the EASA said: "ELA is not a new category of aircraft defined by criteria such as stalling speed or certification code, but is a substantially simpler new process for the regulation of aircraft and related products, parts and appliances."

The EASA-industry committee was due to publish a final rule in November 2009, but has yet to do so. However, it is obvious EASA is not taking the FAA approach. ELA (LSA in Europe) is likely to be more complex and costly for manufacturers. Even though it has been agreed to base certification on ASTM standards, LSAs in Europe will have to obtain a restricted type certificate. This requires the manufacturer to have design organisation approval, which brings copious amounts of paperwork and a yearly fee to EASA. Next, the manufacturer has to design, develop and test the aircraft, overseen by EASA.

Before the aircraft can be built in volume, the manufacturer must obtain production organisation approval, incurring yet another fee. Instead of passing the responsibility for conformance to the producer, EASA wants to witness and audit each stage of the design and production verification in a similar way as for a fully certificated aircraft.

Manufacturers that have built solid business throughout the US LSA boom will continue to flourish. They have talent and resource depth to meet the new requirements. Flight Design, Tecnam, Evektor and others are growing in the GA market. All these manufacturers have grown from ultralight roots.

But for smaller ultralight and LSA producers, this top-heavy regulatory approach will be prohibitively costly. They are likely to campaign for the continuation of Europe's current ultralight regulations.

What made the light sport rule so effective in the USA was the inclusion of most of the existing ultralight fleet, coupled with a new pilot qualification. Both of these elements are missing from the EASA proposal.

EASA's new CS-LSA (certification standard - light sport aircraft) has the potential to put this market on course for exponential growth, but only if a sensible framework, similar to that in the USA, is adopted. The current format could stifle opportunity altogether.