A priori : LSA accepté en Europe ?!?!

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A priori : LSA accepté en Europe ?!?!

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Lu seulement en diagonale (donc pas tout compris). Je ne lirai probablement pas les messages qui suivent celui-ci ... :lol:
Bonne lecture à vous ...

Ce message concerne surtout ceux qui comprennent bien l'anglais ...

ED Decision 2011/005/R
27/06/2011
TE.RPRO.00035-001 © European Aviation Safety Agency. All rights reserved.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.

Page 1 of 2
European Aviation Safety Agency
DECISION No 2011/005/R
OF THE EXECUTIVE DIRECTOR OF THE EUROPEAN AVIATION SAFETY AGENCY
OF 27 JUNE 2011
on
Certification Specifications and Acceptable Means of Compliance
for Light Sport Aeroplanes
‘CS-LSA’

THE EXECUTIVE DIRECTOR OF THE EUROPEAN AVIATION SAFETY AGENCY,
Having regard to Regulation (EC) No 216/2008 of the European Parliament and
of the Council of 20 February 2008 on common rules in the field of civil aviation and
establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC,
Regulation (EC) No 1592/2002 and Directive 2004/36/EC1 (hereinafter referred to as the
‘Basic Regulation’), and in particular Article 38(3)(a) and (e) thereof,
Having regard to Commission Regulation (EC) No 1702/2003 of 24 September 2003 laying
down implementing rules for the airworthiness and environmental certification of aircraft and
related products, parts and appliances, as well as for the certification of design and production
organisations2, in particular 21A.16A of the Annex to Commission Regulation (EC)
No 1702/2003 (Part-21) thereof,
Whereas:
(1) The Agency shall, pursuant to Article 18 of the Basic Regulation, issue Certification
Specifications and Acceptable Means of Compliance, as well as Guidance Material for the
application of the Basic Regulation and its Implementing Rules.
(2) The Agency is obliged, pursuant to Article 19 of the Basic Regulation, to reflect the
state of the art and the best practices in the fields concerned and to update the

Page 2 of 2
Certification Specifications taking into account world wide aircraft experience in service,
and scientific and technical progress.
(3) The Agency, pursuant to Article 52(1)(c) of the Basic Regulation and articles 5(3) and 6
of the Rulemaking Procedure3, has widely consulted interested parties on the matters
which are the subject of this Decision and has provided thereafter a written response to
the comments received4,
HAS DECIDED:

Article 1
The Certification Specifications and Acceptable Means of Compliance for Light Sport Aeroplanes
(‘CS-LSA’) are those laid down in the Annex to this Decision.

Article 2
This decision shall enter into force on 4 July 2011. It shall be published in the Official
Publications of the Agency.

Done in Cologne, on 27 June 2011.

P. GOUDOU


1 OJ L 79, 19.3.2008, p. 1. Regulation as last amended by Regulation (EC) No 1108/2009 of 21 October 2009 (OJ L 309, 24.11.2009, p. 51).

2 OJ L 243, 27.9.2003, p. 6. Regulation as last amended by Regulation (EC) No 1194/2009 of 30 November 2009 (OJ L 321, 6.12.2009, p. 5). ED Decision 2011/005/R 27/06/2011 TE.RPRO.00035-001 © European Aviation Safety Agency. All rights reserved.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.

3 Management Board Decision concerning the procedure to be applied by the Agency for the issuing of
opinions, Certification Specifications and Guidance Material (Rulemaking Procedure), EASA MB/08/07, 13.6.2007.

4 See NPA 2008-07 and CRD 2008-07 Part II on the Rulemaking Archives page
http://easa.europa.eu/rulemaking/r-archives.php.





Bonnes traductions !
Bons résumés !
Bons commentaires !

Tout le reste est "imbuvable" à cause de la mise en page et du volume. N'ayant pas le lien internet de ce document, et ne pouvant pas le mettre en pièce pointe, je mets ses 23 pages dans les 23 messages qui suivent.

Bon courage ...
Que les courageux nous disent ce qu'il faut en tirer comme conclusions !
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CS-LSA Initial issue
Explanatory Note
Page 1 of 23
European Aviation Safety Agency
EXPLANATORY NOTE
CS-LSA INITIAL ISSUE
1. General
Background
On 27 September 2002 Regulation (EC) No 1592/2002 of 15 July 2002
(the ‘Basic Regulation’) entered into force. On 8 April 2008 it was replaced by
Regulation (EC) No 216/2008 of 20 February 20081. In addition, the Commission
has adopted the necessary rules (Commission Regulations) for the
implementation of the Basic Regulation for the certification and continuing
airworthiness of products, parts and appliances2.
Pursuant to Article 18 of the Basic Regulation the European Aviation Safety
Agency (the ‘Agency’) shall, where appropriate, issue Certification Specifications
and Acceptable Means of Compliance, as well as Guidance Material for the
application of the Basic Regulation and its Implementing Rules.
Agency measures
Certification Specifications (CSs) are used to demonstrate compliance with the
Basic Regulation and its Implementing Rules.
AMC illustrate a means, but not the only one, by which a specification contained
in the Certification Specifications or a requirement of an Implementing Rule, can
be met. Satisfactory demonstration of compliance using a published AMC shall
provide for presumption of compliance with the related specification or
requirement; it is a way to facilitate certification tasks for the applicant and the
competent authority.
Guidance Material (GM) is issued by the Agency to assist in the understanding of
the Basic Regulation, its Implementing Rules and CSs.
1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of
20 February 2008 on common rules in the field of civil aviation and establishing a
European Aviation Safety Agency, and repealing Council Directive 91/670/EEC,
Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1).
Regulation as last amended by Regulation (EC) No 1108/2009 of 21 October 2009
(OJ L 309, 24.11.2009, p. 51).
2 Commission Regulation (EC) No 1702/2003 of 24 September 2003 laying down
implementing rules for the airworthiness and environmental certification of aircraft and
related products, parts and appliances, as well as for the certification of design and
production (OJ L 243, 27.9.2003, p. 6) and Commission Regulation (EC) No 2042/2003
of 20 November 2003 on the continuing airworthiness of aircraft and aeronautical
products, parts and appliances, and on the approval of organisations and personnel
involved in these tasks (OJ L 315, 28.11.2003, p. 1).
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CS-LSA Initial issue
Explanatory Note
Page 2 of 23
General structure and format
This CS consists of two ‘Books’. Book 1 is referred to as ‘Certification
Specifications’ and contains the Agency’s technical interpretation of the essential
requirements. Book 2 contains the means acceptable to the Agency for the
applicant to show compliance with the Certification Specifications. Each Book is
divided into ‘subparts’.
CS-LSA — Structure and format
The structure and format of the CS-LSA is different from other Certification
Specifications that are issued by the Agency. The reason for this is that the
CS-LSA is based on a specific revision of the existing industry standards issued by
the ASTM International, formerly known as the American Society for Testing and
Materials (ASTM). The Agency has applied the rulemaking process to review the
relevant ASTM standards at the referred specific revision for acceptance. For that
reason, the CS-LSA consists of a reference to the ASTM standards followed by a
deviation list showing modifications, additions and deletions of the requirements
in the ASTM standards that the Agency finds appropriate for the scope of the
CS-LSA. Future revisions of the referenced ASTM standards will be subject to the
rulemaking process for adoption in amendments of CS-LSA.
Publication
The full text of the Certification Specifications and Acceptable Means of
Compliance as well as of the Guidance Material is available on the website of the
European Aviation Safety Agency.
The referenced ASTM standards are available from:
ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken,
PA, 19428-2959 USA
http://www.astm.org
For more information please contact the Agency at: RPS@easa.europa.eu.
2. Consultation on draft proposals
CS-LSA for Light Sport Aeroplanes is developed by the Agency following a
structured process as required by Article 52(1) of the Basic Regulation. Such a
process has been adopted by the Agency’s Management Board and is referred to
as ‘The Rulemaking Procedure’3.
The Executive Director Decision 2011/005/R adopts the initial issue of CS-LSA:
Certification Specifications and Acceptable Means of Compliance for Light Sport
Aeroplanes that is the output from the following Agency’s rulemaking task:
Rulemaking
Task No
Title NPA No
MDM.032 Regulation of aircraft other than complex
motor-powered aircraft, used in noncommercial
activities
2008-07
The Notice of Proposed Amendment (NPA) has been subject to consultation in
accordance with Article 52 of the Basic Regulation and Article 15 of the
Rulemaking Procedure established by the Management Board. For detailed
3 Management Board decision concerning the procedure to be applied by the Agency for
the issuing of opinions, certification specifications and guidance material (‘Rulemaking
Procedure’), EASA MB 08-2007, 13.6.2007.
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CS-LSA Initial issue
Explanatory Note
Page 3 of 23
information on the proposed changes and their justification please consult the
above NPA 2008-074 which is available on the Agency's website.
The Agency has addressed and responded to the comments received on the NPA.
The responses are contained in a Comment Response Document (CRD) which has
been produced for this NPA (CRD 2008-07 Part II5) and which is also available on
the Agency's website.
4 See Rulemaking Archives page: http://easa.europa.eu/rulemaking/r-archives.php
5 See Rulemaking Archives page: http://easa.europa.eu/rulemaking/r-archives.php
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CS-LSA Initial issue
Explanatory Note
Page 4 of 23
In response to the CRD 2008-07 Part II, the Agency received the following
substantive reactions, which are reproduced below together with the Agency’s
responses. As indicated in the publication of the CRD 2008-07 Part II, a revision
to the ASTM standards F2245 was issued after the publication of that CRD. The
changes of that revision F2245-10c are also reflected in the table below including
the disposition by the Agency. Some of the reflected changes from the ASTM
F2245-10c revision do not result in a change in the CS-LSA but are listed to
highlight that there is a change compared to the previous revision.
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
General
UK CAA It is agreed that it is
inappropriate to include
non-Day/VMC flight for
what should be a “simple”
aircraft but flight in IMC is
surely beyond “simple”
and is outside the scope of
the VLA code.
Noted
These issues will be discussed
in a separate task for CS-VLA.
In that task it will also be
determined if this should be
applicable to CS-LSA.
UK CAA Comment: It is not clear
that EASA will retain
control over the specific
certification standard (i.e.
the ASTM Standard).
Justification: There
would be a loss of Agency
control over the
certification standards. It
is believed that legal
constraints would prevent
the adoption of a standard
not under EASA control.
Noted
EASA will retain full control
over technical standards
because each revision of a
standard will be reviewed via
the current NPA process and
only adopted by EASA when
they have been found to be
acceptable.
CRD 2008-07 Reactions to comments
UK CAA Page 81, Paragraph No:
UK CAA Comment 549
Comment: EASA has not
totally answered the
original comments. The
answer given to the first
two questions is that there
is no reason to limit
operations from the
technical point of view but
the response to question 3
states “This TC will use a
process that is
proportionate to the
aircraft covered by ELA.”
CAA believes that the
depth of the technical
investigation depends
heavily on the intended
use of the aircraft. An
The Part-21 certification
process does not contain a
concept where the depth of
the technical investigation
can be dependant on the
intended use of the aircraft.
The differences in safety
levels between e.g. CAT and
leisure aircraft is reflected in
the applicable certification
basis. When balancing the
airworthiness risks against
the operational risks, the
HAWK study (reference
EASA.2009.C.53 on the EASA
website) shows that very few
of the fatal accidents can be
contributed to failures of
initial airworthiness. The risks
for these aeroplanes are
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CS-LSA Initial issue
Explanatory Note
Page 5 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
amateur built one-off
aircraft used for noncommercial
purposes is not
expected to achieve an
exhaustive compliance
check list against each
design requirement of a
code. However, even a
microlight used for training
is required by some NAAs
to show fully documented
compliance, when
considered commercial
operation. A surveyor or
PCM carrying out the
design
assessment/approval will
not necessarily require a
detailed assessment if
he/she is assured that the
aircraft is not to be used
for commercial purposes.
This is regulation
proportionate to the risk.
Justification:
Clarification.
predominantly operational.
UK CAA Page 101, Paragraph
No: UK CAA Comment
551
Comment: The
underlying concern behind
the comment is that the
depth of design
investigation (materials
sources etc., parts release
or provenance),
appropriate to an aircraft
which may be operated
commercially, has to be
more rigorous than that
which may be allowed
more “subjectively” for
non-commercial operation.
The latter is what CAA
believes is being sought for
ELA.
For clarification of part of
the original comment (not
understood by EASA), a
split fleet is one where
aircraft of the same Type
Design are certificated to
differing standards or
processes.
Justification: Clarification.
The comment mixes up
design and production when
material sources and release
of parts is mentioned as
design investigation
examples.
It is suggested in the
comment that design
investigation levels should be
adapted to the type of
operation. This is not
contained in the Part-21
certification process.
AMC that provide acceptable
design investigation means
do not differentiate between
types of operations. The
details of the certification
process other than these
AMC are not prescribed.
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CS-LSA Initial issue
Explanatory Note
Page 6 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
UK CAA Page 102-103,
Paragraph No: UK CAA
Comment 555
Comment:
EASA’s response to
comment 1): Merely
classifying an aircraft as
“simple” does not render it
simple enough that any
applicant will find it easy to
achieve certification. As an
example, some may seek
to avoid demonstration of
acceptable stall handling
behaviour by merely
demonstrating that the
aircraft behaves down to
the 35 mph maximum stall
speed allowed by the code.
There would then be no
assurance that stall
characteristics are
acceptable. Another
example would be the
publication of unrealistic
landing distances.
Properly qualified
experienced people need
to be used to assess
designs - it is not enough
to rely on the design code.
In addition, F2245 is an
over simplified code. It is
believed, from experience,
that EASA has misjudged
the time, effort and
standardisation issues that
will arise from more direct
NAA or QE involvement.
EASA’s response to
comment 2): CAA would
welcome the proposed
simplified AMC; this sort of
approach is very helpful to
designers who genuinely
want to justify their
product properly.
EASA response to
comment 8): EASA has
noted that “Such meetings
may be held with the TC
holder if necessary”. CAA
believes that such
meetings will always be
necessary to ensure that
When a certification
programme is used for type
certification of an ELA1
aircraft, this programme will
contain the certification basis
and means of showing
compliance to the
requirements.
It is true that the means of
showing compliance to ASTM
codes is currently not
available. This indeed will
require considerable effort
and bring new
standardisation challenges
between EASA teams.
Further development of AMC
to CS-LSA is therefore
proposed and at the same
time considered by ASTM.
This is an important
standardisation issue,
especially when QE would
start to take part in the
certification process keeping
in mind that QE will be under
the EASA control. With
regards to the design code
F2245; recent research on
different regulatory systems
show that the safety record
of aeroplanes builds to e.g.
F2245, is comparable to the
safety level of aeroplanes
certified to CS-VLA. Even
though some caution should
be exercised because of
inconsistencies and
incompleteness of this data;
it is believed that for scope of
these aeroplanes (MTOM up
to 600/650kg) it is adequate.
The response to comment 8
from EASA is intended to say
that meetings between the
TC holder and EASA would
remain applicable. This is
irrespective of the fact of the
TC holder has a DOA or not.
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CS-LSA Initial issue
Explanatory Note
Page 7 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
the continued
airworthiness of the
product will continue to be
maintained to a
satisfactory standard.
Justification: Clarification.
UK CAA Page 119, Paragraph
No: UK CAA Comment
559
Comment: Although it is
agreed that the level of
safety for ELA2 type
balloons is currently
satisfactory, this has been
achieved with an existing
regime of regulatory
oversight that is
appropriate to the number
of passengers being
carried. The proposed
changes introduced by NPA
2008-07 ELA 2 would
significantly alter the
regulatory regime from
current practice and is
likely to result in a
significant change in safety
levels for a class of aircraft
that can carry 30
passengers plus 1 or 2
crew.
Justification: EASA’s
response to the original
comment does not seem to
recognise or respond to the
significance of this
proposed change.
The proposed changes for
ELA2 certification are not
different to the current rules,
and AP-DOA remains the
minimum for design
capabilities. Also the
certification code has not
changed. EASA therefore
does not agree that there is a
significant change from the
current regulatory oversight.
UK CAA Page 159, Paragraph
No: UK CAA Comment
554
Comment: Whilst it is
agreed that NPA 2008-07
introduces a different
regime for the certification
of ELA aircraft, it is not
clear how such a system
will identify when such
aircraft are no longer
supported by a TC Holder
and become an “ELA
Orphan” aircraft.
Justification: Clarification.
If a certification programme
is used for the type
certification of an ELA1
aircraft, there will be a (R)TC
holder but no DOA. Only
when there is no TC holder it
would be an orphan aircraft.
This is not different from
other aircraft TC.
UK CAA Page 169, Paragraph
No: UK CAA Comment
562
The paragraph (b)(7) in CRD
2008-07 Part I explains that
there is no limitation to the
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CS-LSA Initial issue
Explanatory Note
Page 8 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
Comment: Although
reference is made to CRD
2008-07 Part I Paragraphs
(b) (7) a number of the
points raised in the original
comment have not been
addressed. These include
life limited parts and the
commercial use of aircraft
that may have parts,
including critical parts,
produced by an individual
or organisation not having
a POA.
Justification: Clarification.
type of operation resulting
from the fact that parts
without an EASA Form are
fitted.
Acceptance of parts without
an EASA Form-1 is not
possible for life limited parts
and appliances, parts of the
primary structure and parts
of the flight controls.
LAA of CZ Rep. We are very sorry that our
proposals (see our
comment 151,152) are not
taken seriously in account,
even we present them for
long time. EASA answer to
these comments is not
acceptable for us.
The proposal was taken
seriously and therefore task
BR.010 is proposed by EASA.
UK CAA Page No 244, Paragraph
No: UK CAA Comment 547
Comment: Whilst NPA
2008-07 refers to
“preservation of the safety
level” no quantitative
demonstration has been
provided to support this
statement. The UK CAA’s
previous comment,
supported by the EASA
Hawk report, details a
safety record that has been
achieved to date for the UK
but also includes figures
for other NAAs. It is not
clear how the capability
and standardisation of
NAAs and QEs will be
managed so that the
current safety record being
enjoyed by individual
countries will be preserved.
Justification: Clarification.
Comment 547 from the UK
CAA refers to statistical
analysis for the UK GA fleet
providing a comparison
between the fatal accident
rate of full-regulation,
devolved regulation and Selfregulation.
A further, more
detailed quantitative
demonstration of design
approval process related fatal
accidents could not be
derived from that data. The
HAWK study similarly shows
that very few of the fatal
accidents can be contributed
to failures of initial
airworthiness.
Similar to the above, a
quantitative demonstration
for the preservation of the
current safety level related to
the changes within the
current regulated system can
not be provided by EASA, as
stated in the response to the
comment. It should be noted
that the proposal for the
changes to Part-21 are not
perceived by EASA as a
devolved regulation. If NAA
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Explanatory Note
Page 9 of 23
Reaction from
Reaction to
CRD 2008-07 Part II
EASA response
and QE would become
involved in the certification
process, the process in itself
would not change only the
involved entities.
UK CAA Page 247, Paragraph
No: UK CAA Comment
550
Comment: Whilst the
response to comments
indicates a revision to the
requirements for those
parts that do not require a
Form 1, it is not clear what
the changes are.
Justification: Clarification.
Parts without an EASA Form
1 have been restricted for
ELA1 to the same scope as
proposed for ELA2.
UK CAA Page 251, Paragraph
No: UK CAA Comment
563
Comment: EASA’s
response does not appear
to address the issue of
equity and fairness with
the existing system of
Parts M and 145 approval
raised in the comment.
Justification: Clarification
The changes to Part-21 do
not provide privileges for the
release of maintenance,
repair or modifications. They
only introduce another
process for obtaining data
that can be used for
maintenance.
The only issue with possible
impact on equity and fairness
was the maintenance
privilege introduced for the
combined DOA/POA approval.
This is however not retained.
UK CAA Page 332, Paragraph
No: UK CAA Comment
567
Comment: EASA’s
response states that
“concept of organisational
reviews is not retained”
and refers to “CRD Part I
paragraph 4”. CRD Part 1
(b) 4 states that “… the
requirement for a quality
system would be replaced
by a requirement for
organisational reviews….”.
It is not clear if
organisational reviews are
to be a substitute for a
Quality Assurance system.
Justification: Clarification.
The text referred to in this
reaction is the original NPA
proposal that was not
retained.
There is therefore no change
to the current Part-21
Subpart G.
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CS-LSA Initial issue
Explanatory Note
Page 10 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM revision
EASA response
CS-LSA - General
EASA ASTM standard F2245-09
has been updated to
F2245-10c.
The new revision of F2245-
10c is incorporated in this
CS-LSA initial revision. This is
reflected in the referenced
standards and in the
subsequent Subpart B.
European Sailplane
Manufacturers
Association
We want to point out that
we expect from EASA a
clear separation between
the
"aeroplane CS codes"
(including CS-23, a new
CS-23light, CS-VLA and
CS-LSA) and the "sailplane
CS code" CS-22.
In the ultralight scene
today several designs have
emerged which are by
design self-launching
powered sailplanes but
which are certified through
national ultralight
airworthiness codes.
This has lead to the
situation that certain
safety standards
established in the JAR-
/CS-22 evolution like
crashworthiness of
cockpits or energy
absorbing landing gears
have become lost in these
designs.
This not only distorts
competition in some
market segments but even
worse decreases the safety
level in gliding.
EASA has to make sure
that this will not also be
happening in the part of
aviation controlled by the
basic regulation.
It is understood that within
the ASTM system a
separate code (ASTM
F2564) has been issued for
gliders which of course is
not part of the proposed
CS-LSA.
Nevertheless it is not
apparent how EASA will
As far as CS-LSA, this is not
applicable to sailplane but to
aeroplanes which are by
definition engine-driven fixed
wing aircraft. This is reflected
in the Applicability of the CSLSA.
The ASTM standard for
gliders (F2564) provides both
a standard and a definition
that can be used to verify the
appropriateness of the
applied standard.
F2564 states that a glider is
defined as a heavier than air
aircraft that remains airborne
through the dynamic reaction
of the air with a fixed wing
and in which the ability to
remain aloft in free flight
does not depend on the
propulsion from a power
plant. A powered glider is
defined for the purposes of
this specification as a glider
equipped with a power plant
in which the flight
characteristics are those of a
glider when the power plant
is not in operation.
In order to put emphasis on
the fact that powered
sailplanes are not within the
applicability of this CS-LSA,
additional AMC is added.
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Re: A priori : LSA accepté en Europe

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CS-LSA Initial issue
Explanatory Note
Page 11 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM revision
EASA response
react upon an application
according to CS-LSA for an
aircraft which is essentially
a powered sailplane for
one or two occupants.
European Sailplane
Manufacturers
Association
Regarding the technical
content and the format of
the proposed CS-LSA the
European sailplane
manufacturers have the
following general
comments:
The proposed code relies
on the ASTM specifications
(most important the F2245
and several more). This is
indeed a good and wanted
approach giving the LSA
manufacturers the
possibility to seek EASA
certification under CS-LSA
when fulfilling already the
US-american regulations.
As the ASTM specifications
become amended very
often it may happen that
the versions used for this
CS-LSA become fast
outdated and then it will be
difficult to obtain these old
documents. EASA should
make shure that these
versions remain available
through ASTM or directly
by EASA.
The format of taking a
base document (e.g. the
F2245-09) and then adding
the amendment for each
affected paragraph makes
it difficult to work with
such an airworthiness
code.
A consolidated version
would surely make life
easier for the applicant and
for the responsible Agency.
Ideally EASA and ASTM
could come to an
When ASTM standard are
amended, these will be
reviewed by EASA, just like
the FAA. Where the FAA
publishes a list of accepted
standards, EASA will publish
an NPA containing the
proposal to amend the CSLSA
as a result of the change
to the ASTM standard.
EASA and the FAA both do
not publish the ASTM
standards that are the
property of ASTM. All
versions of the ASTM
standard are available on the
ASTM website. (A printed
copy of F2245-10c costs $55)
EASA will discuss options with
ASTM to create a
consolidated ASTM/EASA CSLSA
document.
CS
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Re: A priori : LSA accepté en Europe

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CS-LSA Initial issue
Explanatory Note
Page 12 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM revision
EASA response
agreement that such a
consolidated version will be
published free of charge on
the EASA web page as the
other CS.
This would certainly spur
development of many more
designs and help all
manufacturers of small
aircraft to co-develop their
respective airworthiness
codes.
(side comment: and if the
numbering system could
be re-converted to the
FAR-23-like system used in
all other CS this would be a
great time saver and
making things much better
structured)
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
Subpart B - Standard Specification for Design and Performance of a Light
Sport Airplane
Rev F2245-10c 2.1 Specification for Pilot’s
Operating Handbook F2746
added.
Accepted. No change to CSLSA
Rev F2245-10c 2.2 and 2.3 References to
regulatory documents
amended.
Accepted. No change to CSLSA
Rev F2245-10c 2.4 Other GAMA standard
added for the Pilot’s
Operating Handbook.
Accepted. No change to CSLSA
Rev F2245-10c 3.1.2 and 3.1.3 editorial
corrections
Accepted. No change to CSLSA
LAA UK 3.1.4 and 3.1.4.1 This
definition conflicts with the
definition proposed in Part-
OPS. We suggest deleting
these paragraphs from CSLSA.
Accepted.
It is indeed not appropriate to
define the operational term
‘night’ in this technical
standard.
LAA UK 3.2 This definition is not
required for CS-LSA and
should be deleted.
Not accepted. 3.2 is the
header for this paragraph.
Rev F2245-10c 3.2.1 editorial corrections Accepted. No change to CSLSA
LAA UK
Rev F2245-10c
3.2.23 As presented, the
equation for ‘q’ is
misleading and would be
Partially accepted.
The ASTM standard has been
amended in a slightly different
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Re: A priori : LSA accepté en Europe

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CS-LSA Initial issue
Explanatory Note
Page 13 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
better presented as “=
0.5ρV2”
manner in revision 10c,
therefore ‘partially accepted’.
Rev F2245-10c 3.2.30 (VDF £ VD) is
removed
Accepted. No change to CSLSA
Rev F2245-10c 3.2.34 (VH £ VNE £ 0.9VDF)
is removed
Accepted.
The proposed change to
3.2.34 will be removed from
the CS-LSA table of
differences because it is now
consistent with revised ASTM
standard F2245-10c
Rev F2245-10c 3.2.36 VS1 Stalling speed
or minimum steady flight
speed at which the
aircraft is controllable with
the flaps in a specific
configuration.
Accepted. No change to CSLSA
Rev F2245-10c 3.2.37 VS0 Stalling speed
or minimum steady flight
speed at which the
aircraft airplane is
controllable in the landing
configuration (flaps fully
deployed).
Accepted. No change to CSLSA
LAA
Rev F2245-10c
“Modify 4.1.1.2” The text
of the whole paragraph
must be included for
clarity.
Comment not accepted.
The proposed change to
4.1.1.2 will be removed from
the CS-LSA table of
differences because it is now
consistent with revised ASTM
standard F2245-10c.
Rev F2245-10c 4.1.2 editorial corrections Accepted. No change to CSLSA
LAA
“Add 4.1.3” It would add
clarity to specify which
paragraph numbers (or
range of numbers) need to
be considered.
It is not supported to add the
specific internal references in
4.1.3. because this would
over complicate the standard
and make it prone to errors
in future amendments.
LAA
“Add 4.2.1.3” This
paragraph should read
“The maximum empty
weight WE (N) as defined
in 3.1.2 and 4.2.1 shall
be determined. WE shall
be provided as an
operational limitation for
the aircraft.”
Accepted.
CS-
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Re: A priori : LSA accepté en Europe

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CS-LSA Initial issue
Explanatory Note
Page 14 of 23
Reaction from/
ASTM revision
Reaction to CRD 2008-
07 Part II and changes
from ASTM F2245-10c
revision
EASA response
Rev F2245-10c 4.5.4.2 Changed to 1.1 VS1 Accepted.
The proposed change to
4.5.4.2 will be removed from
the CS-LSA table of
differences because it is now
consistent with revised ASTM
standard F2245-10c.
Rev F2245-10c 4.5.5.2 Changed to 1.2 VS1 Accepted.
The proposed change to
4.5.5.2 will be removed from
the CS-LSA table of
differences because it is now
consistent with revised ASTM
standard F2245-10c.
LAA
Rev F2245-10c
“Modify 4.5.6” The text of
the whole paragraph must
be included for clarity.
Comment not accepted.
The proposed change to 4.5.6
will be removed from the CSLSA
table of differences
because it is now consistent
with revised ASTM standard
F2245-10c.
EASA 4.6 Remove the proposed
change.
The proposed change to 4.6
will be removed from the CSLSA
table of differences
because this paragraph was
not changed as anticipated in
ASTM standard F2245-10c.
European Sailplane
Manufacturers
Association
page 433 - CS-LSA 4.6.1 ff
In the new ground
vibration test paragraph:
it becomes not really clear
how the requirements
listed under 4.6.2.2.2 ff fit
into the wording
V-tai instead of V-tail in
4.6.2.2.2
...compliance with all of
the following....what is this
all?
Accepted. Propose to read:
4.6.2 This ground vibration
test and analysis may
be omitted when there
is clear reason to
assume freedom of
flutter due to
compliance with all of
the following:
(a) Reasonable analysis
following the
Airframe and
Equipment
Engineering Report
No. 45 (as
corrected)
‘Simplified Flutter
Prevention Criteria’
(published by the
Federal Aviation
Administration)
shows the aircraft to
be free from flutter
risk
(b) The airplane does
not have T-tail, V
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