November 2008 -- Newsletter Archive |
| FAA Assessment Project: LAMAs Overview and Advice
FAA Briefing
The FAA has emphasized that this will NOT be an audit of any kind, but they need to see for themselves the excellent results so far of this grand experiment of LSA Self-Regulation and Consensus Standards. Our success has serious implications for the rest of aviation, the mechanism of self-regulation, and in particular, consensus standards creation having the potential of bringing greater innovation at less cost for standards and certification to aviation in general. Selection of Manufacturers/Importers to Visit The FAA has randomly selected some 29 LSA manufacturers/importers from the 52* in place so far in the USA, and will be sending letters of planned visit during the next 2 months or so. Their findings are planned for publication in September 2009. *LAMA is aware of 61 producers of all aircraft types. FAA Assessment Schedule
LAMA has met separately with the FAA regarding this planned FAA assessment, and the FAA has encouraged LAMA to contact the LSA industry in preparation for this audit. FAA will not divulge the 29 producers to be visited but the agency says you may tell LAMA when you are contacted. Therefore, please tell us if you have been contacted by the FAA for the planned assessment. If we get requests, we will plan, as part of LAMA no-cost services to its membership, to provide you information about what we consider important as you prepare for the FAA visit. Please understand that the FAA has not revealed its questions to anyone, so as to provide a proper state of affairs of the LSA community to them, but LAMA has done several oversights of the LSA community, and believes it can use these findings to help the LSA industry prepare properly. Excellent Value of Assessment We consider this FAA assessment a very valuable inquiry of the LSA community, and look forward to working closely with the FAA in their inquiries, and their findings. Please understand, as it was in the beginning of our work on the ASTM Standards, and continues to the present, the FAA has been a valuable part of, and in close collaboration with LAMA, EAA and our LSA community in the consensus process of creating these standards. LAMA Audit Program and Its Importance to the LSA CommunityThe FAA has always envisioned a LSA self-regulating industry that would utilize third-party oversight for credibility. Otherwise, under the LSA Rule, the FAA would have to be much more aggressive in their oversight and determining the safety of the LSA industry and product. They dont want that and you certainly dont want that.So far, LSA has been a grand and successful experiment in self-regulation and consensus standards. If the LSA industry is ever-watchful, and utilizes third party oversight, then the FAA would continue to monitor, but not perform auditing and other more intrusive examinations of the LSA industry. It is far superior that we "police" ourselves. Benefits to LSA and Other Aviation If LAMA completes audits on most LSA producers such action will buttress FAAs view of "self-regulation" of the LSA industry. According to the FAA and other government entities, the benefits of innovation and reduced costs of certification in GA and other aviation would be substantial. If the experiment with a self-regulating LSA industry is judged a failure, it will not be passed on to larger general aviation aircraft and FAA may step in to regulate all of aviation. Again, they say they do not want this and we certainly dont want it. FAA AND LSA Rule Keeping in mind the FAA vision for LSA, they are pleased with what LAMA has done so far utilizing the LAMA oversight/auditing programs. At the present time, the FAA does not plan to conduct similar audit functions. However, they may, from time to time under the provisions of the LSA Rule, assess the LSA industry to assure themselves that all is proceeding as expected. LAMA assistance to the LSA industry In accordance with the FAA vision for a self-regulating LSA industry, LAMA has been conducting oversight duties with the encouragement of the FAA and at the request of the LSA community since the LSA rule became effective in Sep 2004. Most of you reading this letter know these actions as the LAMA audits. About 11 companies have been audited and three have fully passed the program without deficiencies. The others are fixing deficiencies, which were largely of a paperwork (not aerodynamic engineering) nature and most can be remedied easily. LAMA audit action are comprised of the following: 1. Compliance and On-Site Audits These oversight duties consist of a Compliance Audit (comparing manufacturer ground and flight test results to the LSA Rule and ASTM LSA standards) and an On-site audit that reviews the manufacturers QA system with emphasis on corrective action and model-specific training for pilots transitioning into LSA. 2. Consulting for SLSA Certification In addition, LAMA can assist a manufacturer in preparing for and completing the necessary documentation preparatory to obtaining the FAA SLSA airworthiness certificate. 3. Manuals/Continuing Airworthiness Part of the preparation for SLSA is the very important creation of the Maintenance and Pilot Operating Manuals, QA Plan, and Continuing Airworthiness. LAMA has agreements with knowledgeable personnel with direct experience in this activity. Scheduling work is a function of contacting LAMA. For the time being, following the departure of past LAMA president Tom Gunnarson who departed to work for FAA, contact Larry Burke at 925-216-6446. Rates for Auditing and Consulting and Site Visit The following charges are assessed and paid to LAMA. In turn the association will contract with personnel working under agreement with LAMA. 1. Compliance auditing and consulting rate is $175/hour Based upon our present compliance auditing, well-organized ASTM documentation allowing paragraph-by-paragraph comparison to a manufacturers test results can be completed in about 30 hours, which equals $5,250. If documents are not well organized to ASTM standards format, the hourly count can go much higher, so it behooves a manufacturer to send understandable documents following ASTM standards. 2. The on-site visit is a flat fee of $2,000 plus travel expenses, and takes a day or more. 3. Consulting at $175/hour can be arranged to your satisfaction, with a cap for the work required. Such work must be scheduled well in advance to allow contractors to plan properly. "Look for the LAMA Label" Program Where the non-producer community - that is, customers, insurance companies, member organizations, and more - meets the LAMA audit program is through a current program being relaunched as "Look for the LAMA Label." This is a familiar action for consumers and businesses serving consumers. You know the Underwriter Laboratories seal of approval; the Good Housekeeping seal of approval and Americans know the phrase, "Look for the Union Label." When LAMA has audited a sufficient number of companies (perhaps those companies supplying 80% or more of the aircraft being purchased, sometimes referred to as "critical mass"), then LAMA can seek support from organizations like EAA, AOPA, insurance companies, media outlets and more. All these organizations have already been appraised of this program and they are enthusiastic about supporting Look for the LAMA Label once enough of the marketplace is covered. With 11 audits underway or completed, LAMA is well on its way to reaching this plateau. At that time, member organizations, insurance suppliers, or others may strongly encourage customers to "Look for the LAMA Label." Those airplanes wearing the Label stand to gain from participation. Lest you think this is merely a marketing program (which is also is), be advised. FAA, NTSB, insurers, airlines, and the entire general aviation community are watching closely, now, to see if self-regulation is working, that is, if the LSA industry consensus standards method works. The audit program adds immense credibility to the industry and to the way outsiders view LSA. And - this is very important - this is a cooperative effort between producers and LAMA. Your association is most emphatically not the FAA. The goal is to accredit all worthy companies producing ASTM-compliant aircraft and LAMA intends to do that by working with companies not by challenging your every move. Following a successful compliance and on-site audit, a certificate of completion will be presented to a successful company. After that date, LAMA labels may be affixed to your airplanes, for a fee per airplane ($250 has been discussed by LAMAs board and with a small number of producers). Please note that the LAMA Label program is LAMAs single largest potential source of revenue, and provides recognition for your product suitable to the public and FAA. It is also a very fair program. Small producers pay low LAMA dues ($500/year) and only pay more if they successfully sell more aircraft. Larger producers, whose total payment will be capped, will help provide more for LAMAs budget and should gain the most from it. In this way, the LAMA Label program is highly progressive and welcoming of new innovation yet acknowledges the support of our most successful producers of Light-Sport Aircraft. Insurance Industry Concerns and Requests: Meetings with Avemco and Falcon InsuranceExecutive SummaryA) Insurance representatives will brief the insurance suppliers on the LAMA oversight program and the planned FAA LSA assessment project. B) Insurance community would look upon the LAMA oversight program as a means of reducing risk if, as a result of the oversight, the manufacturer would take measures to:
Falcon is a broker for several leading insurance companies, and they say they insure about 75% of LSA aircraft, dealers, and distributors. Avemco is the largest direct insurer, a term that means they sell directly to pilot owners. Comments from Falcon Falcon underwriters primary concern revolves around adequate transition training of purchasing pilots, followed by the price of repair parts and the cost of those repairs. Insurers feel sellers should provide formalized model-specific training for pilots transitioning into LSA. A 5-hour minimum was often mentioned. They advise every LSA manufacturer or importer implement such training. Falcon understood the value of the LAMA audit and, commented that the insurance community, given successful LAMA audits, would look favorably upon reducing premiums to those LSA aircraft and general liability insurance to the manufacturer or importer. Falcon was particularly impressed by the "Look for the LAMA label" program as public statement of credibility. Comments from Avemco Avemco feels that the consumer should know that the LSA product has been looked at by someone else, by a third party not profiting from the sale of the aircraft. Avemcos major effort in LSA would be to determine cause of losses, and to decide what is important to reduce losses. As with Falcon, properly transition training pilots is the major concern. Avemco is investigating their claim results and the LSA industry to determine what the major issues are in transition training. Based on what theyve found so far, Avemco feels that more hours in transition training are needed. The visits with leading insurers brought home the value of the "Look for the LAMA Label" program, preceded as it is by a thorough ASTM-oriented audit. Passing an ISO 9000 audit or a country-specific aviation-authority audit may be a worthy exercise but is very definitely not a LAMA audit to ASTM standards. And, only the LAMA audit program will allow successful producers to wear the LAMA Label on their approved models. LAMA invested many hours at Oshkosh to attend vital meetings and to seek out industry suppliers. We present the results of these meetings to the LSA producer and selling community to help the entire industry. If we all cooperate, we can become a real and important segment of aviation. If we dont take it all seriously, we cannot expect others with finances at risk to take us seriously either. |