A priori : LSA accepté en Europe ?!?!

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 15 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
tail or boom-tail or
other
unconventional tail
configurations
(c) is equipped with
fixed fin tail surfaces
(d) does not have
significant amount
of sweep
(e) does not have
unusual mass
concentrations along
the wing span (such
as floats or fuel
tanks in the outer
wing panels)
Rev F2245-10c 4.7 Formatting change to
TABLE 1 Pilot Force
Accepted. No change to CSLSA.
LAA UK 5.1.2
This paragraph does not
reference composite
factors that specifically
cater for variation in
environmental effects.
LAA recommend that a
reference is made to AMC
VLA 619, or other means
of accommodating these
variations (such as LBA
document: I4-FVK/91
“Standards for structural
substantiation of sailplane
and powered sailplane
components consisting of
glass or carbon fibre
reinforced plastics”, July
1991).
Not accepted.
Although we agree that
factors are needed to cater
for the variations, EASA
prefers to include such
information only after public
consultation. It will therefore
be suggested to the ASTM
committee to introduce
guidance on the use of
composite materials.
Reference to such guidance
can be included in a future
revision of the CS-LSA.
Until such a change is
implemented, details will be
established during the
certification process.
Composite factors for
variation in environmental
effects or material variations
which influence might vary
depending on the chosen
materials and manufacturing
methods will be determined
using the mentioned
references.
LAA
Rev F2245-10c
“Modify 5.1.3.1” The text
of the whole paragraph
must be included for
clarity.
Comment not accepted.
The proposed change to
5.1.3.1 will be removed from
the CS-LSA table of
differences because it is now
consistent with revised ASTM
standard F2245-10c.
Rev F2245-10c 5.2.4 Formatting change. Accepted. No change to CS

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 16 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
LSA.
Rev F2245-10c 5.2.4.3 Formatting
change.
Accepted. No change to CSLSA.
Rev F2245-10c 5.3.7 Formatting change. Accepted. No change to CSLSA.
Rev F2245-10c 5.8.1.7 Changes to FIG. 6 Accepted.
The proposed change to FIG.
6 will be removed from the
CS-LSA table of differences
because it is now consistent
with revised ASTM standard
F2245-10c.
LAA UK 6.8 The LAA doesn’t believe
that flight testing is a
satisfactory method of
structural testing, and it
would in any case only test
the limit load condition.
LAA proposes that the last
sentence of 6.8 be deleted.
Not accepted to delete the
last sentence.
LAA is suggested to raise the
issue for clarification with
ASTM.
Our interpretation is that
Flight testing is not replacing
the structural requirements
for showing of compliance
(e.g. 5.1.3.2.) but could
support assumptions chosen
for load and strength analysis.
LAA
EASA
“Modify 6.10.1” The text of
the whole paragraph must
be included for clarity.
Comment not accepted.
The proposed change to
6.10.1 will be removed from
the CS-LSA table of
differences because this
paragraph was not changed
as anticipated in ASTM
standard F2245-10c.
LAA “Add 6.11.4” This
paragraph needs to read
as follows “If a retractable
landing gear is used, there
must be a means to inform
the pilot that the gear is
secured in the extended
and retracted positions”.
Partially accepted.
The text is amended to show
that position information
must be provided for both the
retracted and extended
position.
LAA
Rev F2245-10c
“Modify 7.2” The text of
the whole paragraph must
be included for clarity.
Comment not accepted.
The proposed change to 7.2
will be removed from the CSLSA
table of differences
because it is now consistent
with revised ASTM standard
F2245-10c.
EASA 7.6.1 Remove the proposed
change.
The proposed change to 7.6.1
will be removed from the CSLSA
table of differences
because this paragraph was
not changed as anticipated in

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 17 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
ASTM standard F2245-10c.
EMF/BMAA
LAMA
LAA of CZ Rep.
This comment is related to
the section 7.Powerplant
Some companies already
experienced problem with
the proof of conformity of
the non-certified engines.
The idea that the aircraft
manufacturer is
responsible for initial and
continuing airworthiness if
there is no TC for the
engine/propeller is
problematic, because the
airframe manufacturer
could have problems to get
drawings and
specifications of the engine
from the engine
manufacturer in order to
show the compliance with
the certification
specification. This is a
huge effort for a company
producing aircraft and not
the engines without
involvement of the engine
supplier.
We think that EASA must
try to find the solution to
avoid this problem. EASA
must clearly describe
what is required.
LAMA EUROPE is ready to
help to find such solution.
Noted.
Further details will be
developed as AMC in
rulemaking task MDM.032(d)
EMF/BMAA
LAMA Europe
LAA of CZ Rep.
This comment is related to
the Section 8.5.
8.5.1.requires that only
ATC equipment must be
approved. For the success
of the LSA it is necessary
that the remaining avionic
and instruments need not
be type certificated.
Noted.
This is consistent with the
requirements contained in
CS-LSA. Because of the scope
of aeroplanes in CS-LSA
(Simple, single engine
propeller, day VFR) it is
considered appropriate not to
require approval of the other
instruments.
LAA UK “Add 8.5” This paragraph
number, and subparagraph
numbers, need
to start with 8.6 as there is
already a paragraph 8.5.
Accepted.
LAA UK “Add 8.5.2.5” Should read Accepted.

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 18 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
“be described and
labelled appropriately
regarding limitations and
operation”
Flight design CS-LSA defines that ATC
equipment must be
approved. For all other
equipment approval is not
required by CS-LSA. I
want to clearly support
this definition. Experience
from several years of
usage of aircraft equipped
this way in US and several
other countries has
proven this to be
absolutely suitable to this
type of aircraft
(remember - we talk of
VFR day aircraft, as CSLSA
defines it in this
CRD). As this is one of the
main factors that are the
basis for acceptable
aircraft purchase cost and
low aircraft operation
cost, this is a key to the
success of these aircraft
also in Europe.
Noted.
EASA thanks the
commentator for his support
and shared experience.
EASA is of the same opinion
that for this type of
aeroplanes and their
operation it is appropriate not
to require approval of the
other instruments.
Rev F2245-10c 9.1.1.4 Reference to 10.10
removed
Accepted. No change to CSLSA.
Rev F2245-10c New requirement
9.1.1.5 The language used
in markings and placards
may be adjusted to
accommodate language
and localization concerns.
For example, the word
"aeroplane" may be
substituted for the word
"airplane".
Accepted.
9.1.1.5 will be removed from
the difference table in CSLSA.
Rev F2245-10c New requirement
9.1.3 A placard that
specifies the kinds of
operation to which the
airplane is limited or from
which it is prohibited and
that the airplane is to be
operated according to the
limitations in the Pilot’s
Operating Handbook. The
kinds of operation
Accepted.
9.1.3 will be removed from
the difference table in CSLSA.

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 19 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
specified on the placard
must be within the limits
given in 9.2.
LAMA Europe
LAA of CZ Rep.
This comment is related
to the Annex A1
ADDITIONAL
REQUIREMENTS FOR
LIGHT SPORT AIRPLANES
USED TO TOW GLIDERS
There is problem with new
EASA proposed
modification of paragraph
A1.6.1.6 - original ASTM
F2245 has there ...
weak link shall not be less
than 900N (202.3 lb).
....
This was changed by
EASA to 300daN.
The result of this is, that
according to the A1.6.1.4
the loads for testing of
release forces are now
about three times higher
than before (because
requirement for loads up
to 180% of the nominal
strenght of the week
link)- this is non-realistic
requirement.
Proposal:
We propose to :
a) either initiate proces
to modify the ASTM
standards related to
towing the gliders and
make them similar to
requirements of German
LTF-UL or Czech UL-2
requirements for towing
gliders by microlights..
b) replace Annex A1 by
the corresponding section
from German LTF-UL or
Czech UL-2 regulation for
towing gliders by
microlights. These rules
are already proved by the
real operation of the
microlights towing the
gliders.
Partially accepted.
Because of inconsistencies
between CS-22 and ASTM
Standard F2245, EASA has
decided to delete the Annex
A1 from CS-LSA.
When aircraft need to be
certified for glider towing;
special conditions will be
used.
ASTM will be contacted to
develop consistent
requirement for towing.
LAA UK
Rev F2245-10c
“Add 9.1.3.1” Should read
“ “No Intentional Spins”, if
The proposed new 9.1.3.1 in
the CRD is removed because

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 20 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
applicable” (missing quote
marks).
it is now consistent with the
revision F2245-10c. Refer to
the paragraph 9.1.5.
Rev F2245-10c New requirement added
9.1.4 "This aircraft was
manufactured in
accordance with Light
Sport Aircraft
airworthiness standards
and does not conform to
standard category
airworthiness
requirements."
Not Accepted.
9.1.4 will de added to the
difference table in CS-LSA as
‘Delete’.
Rev F2245-10c New requirement 9.2
Kinds of operation and
sub-chapters added.
Not Accepted.
The content of the new 9.2
and subsequent sub-chapters
will de added to the
difference table in CS-LSA as
‘Delete’ 9.2 incl. subchapters.
Only airworthiness
standards are included in CSLSA.
LAA UK
Rev F2245-10c
“Modify 10.1” The word
‘airplane’’ is used here, but
generally in the document
‘aeroplane’ or ‘aircraft’ is
used.
Not accepted.
The wording ‘airplane’ is used
for consistency with the ASTM
standard. ‘Aeroplane’ will be
replaced by ‘airplane’.
The difference to the rev
F2245-10c is kept for
consistency with Subpart G1.
Rev F2245-10c CS-LSA deletes 10.2 –
10.11 incl. sub-chapters.
This is no longer required
since these are removed in
F2245-10c
Accepted.
The deletion of 10.2 – 10.11
will be removed from the
differences table.
LAA UK “Modify A1.6.1.6” A weak
link minimum strength of
300 daN is used. CS-
22.581b)2) uses 500 daN:
there should be
consistency between the
codes. Also, the ASTM
standards use units of
Newtons rather than daN:
Newtons should be used
for consistency.
Not accepted.
Because of inconsistencies
between CS-22 and the ASTM
Standard, EASA has decided
to delete the Annex A1 from
CS-LSA.
Rev F2245-10c Format change to A2.7.3.5 Accepted. No change to CSLSA.
Rev F2245-10c Format changes and
editorial correction in the
Appendixes to F2245-10c
Accepted. No change to CSLSA

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 21 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Subpart G1 - Operating Limitations and Information
LAA UK 3.2 This definition is not
required for CS-LSA and
should be deleted.
Accepted.
LAA UK 4.6 The references to F2295
and F2279 are not consistent
with the EASA approach and
this paragraph should refer to
Part-21 procedures.
Partially accepted
This paragraph will be deleted
instead of modified because it is
as stated covered by Part-21.
LAA UK 6.4.1 Should be modified to
read “A list of the standards
used for the design,
construction, continued
airworthiness, and reference
compliance with this
standard”.
Accepted.
LAA UK a) The word ‘airplane’’ is
used here, but generally in
the document ‘aeroplane’ or
‘aircraft’ is used.
Accepted.
LAA UK b)1) Should read “Each part
of the Flight Manual
containing information
required by the following
chapters or paragraphs of a
Pilot’s Operating Handbook
according to F2746-09”.
Accepted.
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Subpart G2 – Maintenance Limitation and Information
LAA UK “Delete 3.1.7” Sections
3.1.7.1 and 3.1.8 should also
be deleted.
Accepted to also delete Sections
3.1.7.1 and 3.1.8 from ASTM
F2483-05.
EASA Section 5.3.1 to 5.3.6 should
be deleted as they are
replaced by the modified 5.3
Accepted.
LAA UK Section 9 of ASTM F2483-05
needs to be replaced with
references to Part-21, Part-
66 and Part-M.
Partially accepted. See also the
reaction below.
EASA Section 8, Section 9, Section
10 and Section 11 should be
deleted because these are
covered by EU Regulation
1702/2003 and 2042/2003.
As a consequence deletion of
contents regarding “ELSA” is
no longer separately
required.
Accepted.

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 22 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Subpart H – Engine
LAA UK “Applicable specifications”
Should read “Installed
engines shall conform to
ASTM F2339-09, ASTM
F2538-07a, 14 CFR Part 33,
CS-E or CS-22 Subpart H
standards.”
Partially accepted.
The revision of F2339 is 06
instead of 09.
LAA UK The table shown is correct for
F2339, but another table
needs to be added for F2538
which deletes paragraphs
1.2, 3 and 9.
Accepted.
The equivalent Sections not
applicable in F2538-07a are
Section 1.2, 3, 5, 8 and 9. See
also the reaction below.
EASA Section 4 and 7 should be
deleted in ASTM F2339-09
and Section 8 and 9 in ASTM
F2538-07a because these are
covered by EU Regulation
1702/2003.
Accepted.
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Subpart J – Propeller
LAA UK “Applicable specifications”
Should read “Installed
propellers shall conform to
ASTM F2506-07, 14 CFR
Part 35, CS-P or CS-22
Subpart J standards.”
Accepted.
LAA UK “Add 5.5” Presumably this
paragraph, and its subparagraphs,
need to be
numbered 5.6 as there is
already a paragraph 5.5.
Accepted.
The added Section 5.5 needs to
be corrected to 5.6 as indicated.
LAA UK “Modify” Include the
complete wording of the
intended paragraph 6.5, also
the reference to “(e) below”
doesn’t appear to make
sense.
Accepted.
LAA UK “Add 6.5” Similarly, this
paragraph needs to be
numbered 6.7, or a
statement needs to be made
that this paragraph is
inserted after 6.4 and does
not replace the existing 6.5.
Accepted.

[administrateur]

CS-LSA Initial issue
Explanatory Note
Page 23 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Subpart K - Airframe Emergency Parachute
EASA Section 12 should be deleted
like in other standards.
Accepted.
LAA UK Appendix X1 We understand
that there is a Europe-wide
initiative to standardise the
placards relating to
emergency parachute
systems. CS-LSA should
conform to that standard
Noted.
In the absence of a European
standardized placard the ASTM
standard is kept for consistency.
LAA UK “Modify Fig X1.1” Presumably
should read “shows the
placard explained under
11.3.3.1”.
Accepted.
LAA UK “Modify Fig X1.2”
Presumably should read
“shows the placard explained
under 11.3.3.2”.
Accepted.
LAA UK “Modify The reference...”
Needs to be deleted.
Accepted.