LAMA Archive - January 2010

Welcome to the first edition of what we plan to be a regular LAMA Newsletter. It will be provided to all current LAMA members, sampled to potential or previous LAMA members, and offered to media and government to help keep them informed. We expect to create a place on LAMA.bz to show the latest issue and archive all previous issues.

We plan to print a small quantity of these newsletters and physically mail or distribute them at the annual LAMA Dinner at Sebring, at our LSA Malls, and at other public venues. But this is the electronic age and we see a much greater chance to distribute via email blast or online via websites. Therefore, the LAMA Newsletter will be presented in a form that looks more like you see online than the traditional magazine-style newsletter.

We expect to use this newsletter to inform you of factors that can affect your business—from new FAA rulings, investigations by NTSB, actions by member organizations and more.

Future LAMA Newsletters will offer more graphics and perhaps slicker layouts. But the important thing is the info presented herein.

We hope you enjoy it and if it truly informs you on even a single point, LAMA will consider the effort worthwhile.

Others that assist me with the affairs of LAMA include the following people and they will also have contributions to the LAMA Newsletter. But, we also invite YOU, our LAMA members, to submit material for consideration.

Of the many organization that can and do help the Light-Sport Aircraft industry — AOPA, EAA, GAMA …with our thanks to each — only LAMA is 100% focused on this industry. Other organizations derive money from people outside our industry so they must (correctly) consider the needs of others. Contrarily LAMA is YOUR organization and we never, ever lose sight of the needs of the Light-Sport Aircraft industry including kit-built aircraft and ultralights that Sport Pilots may fly. We appreciate your support of LAMA and hope you will see the LAMA Newsletter as one of several good reasons to continue your valued support.

—Dan Johnson
President and Chairman of the Board

…on behalf of…
Larry Burke, Founder and Chairman Emeritus
Dave Martin, Board Member, Journalist, and LAMA Newsletter Editor
Phil Lockwood, Board Member and President of Lockwood Aircraft Supply
Tom Peghiny, Board Member and President of Flight Design USA
Jo Konrad, Board Member and chairman of DULF (German aviation organization)
Jack Pelton, Board Member and President, CEO, and Chairman of Cessna Aircraft
Earl Lawrence, Board Member and Vice President of EAA
Randee Laskewitz, Office Manager
Gregg Ellsworth, Member Services and Air Safety Investigator
James Fasso, Webmaster

___________________________________________

FAA Field Assessments Warn of Problems

A briefing last tummer for LSA community leaders by FAA Evaluations and Special Projects Manager Brian Cable (FAA headquarters, AIR 200) notes that SLSA manufacturers and importers are trying hard to follow requirements. But many companies are falling short. Cable is a statistician who organized the surveys of 30 SLSA companies or their U.S. importers. Although representatives of the surveyed companies were left with the impression that they had done well, Cables’ brief concluded that only a few got high grades for complete compliance.

Attending the brief were representatives of U.S. and other SLSA manufacturers, suppliers, insurance companies, EAA, LAMA, and an ASTM subcommittee chairman. Cable noted that most companies visited were cooperative and welcomed the FAA survey.
According to Cable, the majority of surveyed companies lacked one or more of the documentation elements required for FAA SLSA approval. Companies from non-English-speaking contries often misunderstood the requirements, and some U.S.-based firms also lacked the documents to back up their affidavit certification of compliance with all consensus requirements.

Some Specifics
The presentation listed some topics of concern:
1. Manufacturers are not conducting required internal audits, nor are they having first-article audits done as is called for in the standards.
2. Quality assurance systems and procedures need improvement.
3. Continuing airworthiness information needs to be sent to the appropriate airworthiness authority.
4. Major repairs are not properly recorded and signed off.
5. Tools are not properly calibrated.
6. Most recent FAA-accepted revised or added LSA standards are not being incorporated into production.
7. Some form of independent oversight of the LSA industry is immediately needed.
8. Regular meetings between the FAA and industry need to be implemented.
9. The LSA rule is very clear: The aircraft must be in complete compliance with the LSA standards or no airworthiness certificate will be issued.
10. There must be line-by-line conformity with the LSA standards. So far, FAA has not gone to that level of detail, but if the LSA industry does not immediately implement improvements, the FAA will do so.
11. The message industry interpreted is that FAA encourages the LSA manufacturers to implement a mandatory third-party oversight audit system.
12. Based on field findings, the FAA notes the need for LSA manufacturer education and plans to issue documents on the proper way to comply. The FAA plans to collaborate with EAA, LAMA, ASTM and others in this project.

Major-Areas Assessment
(Interpretation is based on comments by FAA’s Brian Cable.)

General
1. Continuing airworthiness was poorest, followed in ascending order by:
2. Maintenance procedures and documentation.
3. Assembly procedures and documentation.
4. Compliance to design standards.
5. Quality system functions.
6. Product conformity to regulations was best:

Continuing Airworthiness
1. Documentation was the largest issue, folllowed in descending order by:
2. Determination of risk.
3. Risk Assessment records.
4. Notifications.
5. Compliance directives.
6. Companies going out of business.

Maintenance Procedures and Documents
1. Lack of written procedures for repairs including documenting their accomplishment was the biggest issue, followed by lesser concerns:
2. Logs and records of major repairs and alterations.
3. Overhaul manual, including qualification requirements of persons doing major repairs.
4. Equipment list.
5. Return-to-service procedure and documentation.
6. Form and content of the required maintenance manual.

Assembly Procedures and Documentation
1. Receiving was best, followed in descending order by:
2. Assembly instructions.
3. Certified components.
4. Checklists.
5. Personnel qualifications.
6. Flight tests.
7. Documented quality procedures were poorest.

Compliance to Design Standards
1. Lack of adequate design compliance checklists is the largest issue, followed closely by:
2. Compliance with standards.
3. Minimum equipment required.
4. Contents of the pilot operating handbook (POH).
5. Access to standards is the least troubling issue.

Quality System Functions
This entire area proved most troublesome to FAA.
1. Critical parts lists was said to be best, followed by:
2. Permanent QA records, and non-conforming material records.
3. Process and procedures.
4. Organizational structure.
5. Supplier control and test procedures.
6. Quality manual.
7. Corrective action.
8. Lack of internal and external audits was the most troublesome issue.

This report was prepared by LAMA co-founder Larry Burke.

LAMA’s Response

As members know, LAMA is specifically qualified and ready to provide low-cost, independent audits to help members resolve problems before they become issues for the FAA. Of particular concern to the LAMA board is that surveyed companies were under the impression that they had done well and that the survey—which was without cost to the companies—could substitute for an independent audit such as LAMA offers its members. The LAMA audit is relatively inexpensive, but companies pay a reasonable fee for the document analysis plus the auditor’s travel expenses for the factory visit part of the audit. Before the FAA’s survey, 22 LAMA member companies had signed up for the LAMA audit, and most subsequently declined to follow through.

Several points need to be made.

First, the FAA survey did not address many of the issues contained in the standard LAMA audit checklist and did not issue individual analysis and recommendations. Contrasting this, the LAMA audit checks for the presence of every document required by the ASTM standard for SLSA approval.

Second, the objectives are different. The FAA’s survey was to provide the agency with a snapshot of SLSA conformance, where the LAMA audit is aimed at helping each audited company come into complete compliance with detailed reports of individual discrepancies.

Third, the FAA survey did not visit any factories outside the U.S.; LAMA’s team in Europe offers audits there, from which about two thirds of U.S. SLSA sales originate.

At present, LAMA offers the only complete, fully objective independent SLSA audit available…plus follow-up service to guarantee compliance. Especially in light of FAA’s survey findings, the LAMA board strongly recommends that member companies sign up for LAMA’s low-cost audits and compliance sticker program. FAA recommends an independent third-party audit, and LAMA’s audit option is specifically endorsed by Avemco Insurance Company and Falcon Insurance Agency, the two groups that insure most LSA airplanes and their pilots.

Advocacy & Communications--- LAMA works with others from EAA to AOPA to GAMA interacting with FAA, EASA, NTSB, insurance companies and member organizations to protect and promote the LSA concept including self declaration to industry certification standards. LAMA works in the “front-line trenches” with our members, giving your organization a close perspective on your needs. Our website, LAMA Newsletters, and regular LSA Marketing Updates help inform the industry.

Oversight---The LAMA Audit and Label program. This is the way we help protect our members from FAA intrusion, help secure insurance for their customers, and give our members a strong defense argument when they may become involved in a lawsuit. LAMA is setting plans to offer an Internet portal for dissemination of safety information. And, as a fee service to our manufacturing members, LAMA is moving to offer professional accident investigation by an NTSB-approved team.
It’s worth noting what the LAMA audit does not do. The auditor does not verify that appropriate tests have been carried out and analyzed correctly. And LAMA auditors do not perform test flights.

Marketing---Through LAMA and its affiliates (LSA Marketing Group), we have consistently helped present the LSA industry as a significant aviation sector. LAMA has helped engineer or support events like the EAA Sport Pilot Tour, LSA malls at major airshows, and LSA-only events (Sebring, Mt. Vernon, Heart of Texas, LSA Jambo). On a regular basis LAMA represents industry to news media, member organizations, and regulatory authorities.

Members: You can help us begin this feature. Send your LAMA-related question to the newsletter at windwing1@juno.com with the subject line LAMA Q&A.
If the question and answer appear to be of general interest to the membership, we will publish them here and then move them to an archive on the web site. Provide your name and company, and we will get back to you even if your item is not destined for the newsletter.

One of the major board tasks for 2009 was to develop a LAMA business plan looking to the future of Sport Pilot and Light-Sport Aircraft and how LAMA can be of service. First we considered recent accomplishments:

--Achieved a good start on LAMA’s independent SLSA audit program. Four companies completed their audits successfully: BRS parachutes, Evektor, Flight Design and Indus. Several others are close to completion pending clearing of minor discrepancies.

--Commissioned five teams of independent auditors.

--Recruited Jan Fridrich to head a European LAMA division to explain and promote ASTM standards to the EU light aviation community and to offer independent audits for LAMA member companies working toward U.S. SLSA qualification. Hiring him on a full-time basis will require additional funding sources.

--Formalized LAMA audit procedures including line-by-line ASTM standards compliance and auditor conflict-of-interest rules. (Auditors who are also LSA consultants may not audit companies that have received their consulting services and may not consult with companies they have audited.) Audits are independent of the LAMA organization and are totally objective: The company either has the required documents or it doesn’t. LAMA will work with companies to help correct deficiencies.

--Organized LSA malls at AirVenture, Sun ‘n Fun and other venues.

--Received official insurance company endorsement for the LAMA audit program from Avemco and Falcon.

--Presented the 18th annual LAMA President’s Award for individual achievement to EAA editorial director Mary Jones, who was chosen by leaders of the light aircraft industry.

--Coordinated with EAA and AOPA in events promoting LSA discussions and events.

These are some of the tasks the LAMA board talked about for 2010 and beyond:

--Establish expanded working interfaces with AOPA and GAMA. (Despite interest by Pete Bunce—president of GAMA—the GAMA board has made clear that they have no present plan to participate in LSA activity.)
--Expand our current working interface with EAA.
--Continue and enhance LSA malls or other display presence at various venues.
--Attend and organize U.S. and overseas aircraft venues where LSAs can be properly presented.
--Create in collaboration with others a website where all LSA service bulletins and continuing airworthiness can be accessed by anyone
--Responding to the FAA assessment findings, agressively expand the LAMA oversight auditing, especially the factory audit.
--Expand membership
--Seek additional sponsorships.
--Find a way to hire Jan Fridrich as LAMA’s full-time European representative.
--Establish auditing management including audit scheduling plus recruitment and training of audit subcontractors.
--Collaborating with AOPA or GAMA relating to Sport Pilot/LSA and relying on their expertise in government advocacy in Washington DC.
--Establishing a LAMA budget to accomplish these goals.

In the fall of 2009, LAMA proposed a budget to include conservative salaries for two people in the U.S. (the president and an administrative assistant) plus office overhead and a small travel budget plus a part-time salary for an audit manager. The proposal also included a salary for Jan Fridrich to head European LAMA projects. In an economic downturn, even a modest budget proved too ambitious for participants; subsequently, a “Plan B” was proposed with much reduced costs. Negotiations with leading companies regarding the LAMA proposal continue.

LAMA expects to produce a revenue stream from the sale of LAMA Labels… a LAMA audit-compliance sticker that can be displayed on each aircraft sold. With such fees – based wholly upon the success of each company to register aircraft – LAMA believes it offers a fair and equitable way to raise funds without overburdening members.

The Sebring, Florida, Expo LSA event is scheduled for January 21 to 24. We hope to see most of our members again at this most important, all-LSA event where flying is accommodated and encouraged. We invite you and your guests to join us for the annual LAMA dinner, sponsored again by Aviator’s Hotline. Come enjoy a pulled-pork sandwich* and all the southern trimmings plus beverages followed by… “No long, boring speeches!” …in the big Expo activities tent.

Dinner begins at 6 p.m. on opening-day Thursday, January 21. Please let our sponsor know how many of your staff will join us by e-mailing Carol Harrison carol@aviatorshotline.com We will look for you in Sebring.

Thanks to sponsorship from Aviators Hot Line and Light Aviation Edition (and other companies), LAMA will again host the LSA Mall at the country’s two major airshows.

Space is already being booked for both events and we encourage your company to act soon. Space IS limited and we’ve filled all spaces in every year the LSA Mall has been offered. For Sun ‘n Fun 2010, we will have a new location on Doolittle Road. Show organizers will use our last-year front-gate location. Now, we have a large intersection location that is excellent for traffic. Most exhibitors have found it highly worthwhile to increase their visibility at the big shows by participating in the LSA Mall as well as a regular company display. Several brought more than one aircraft.

Front-line spaces are $450,00 (approx. 10 available)
Back row spaces are $350.00 (approx 8-10 available)
These fees merely help LAMA cover out-of-pocket costs. You MUST also have a paid commercial exhibit space elsewhere. The same LSA Mall rules of participation will apply based on LAMA’s agreements with Sun ‘n Fun, Inc., and EAA.

Spaces are offered under this familiar pattern: The first to pay are taken in order. As we finalize the layout of aircraft on our ground space, we will allow companies to pick the location they prefer… IN THE ORDER OF PAYMENT RECEIVED. In other words, those who pay first, get first pick of where they want to be.

IMPORTANT NOTICE --- Three companies have already paid and have the first three choices about where they want to be at both events. We urge all manufacturers, importers, or dealers who wish to exhibit in the LSA Mall of Sun ‘n Fun or AirVenture to make full payment as soon as possible. You must pay for each space you want. Partial payments cannot be accepted. We believe this is the fairest way to allocate these valuable spaces.

You may pay by credit card via PayPal --- send to LAMAPayPal@LAMA.bz or ask for details on how to do this. Or, you may send a check, made out to LAMA
Send to:

LAMA
Att’n: Randee Laskewitz
2001 Steamboat Ridge Court
Port Orange FL 32128-6918
(until May 1, 2010 only)