I Oppose the Weight Exemption for the Icon Aircraft on Several Grounds

I oppose the weight exemption for the icon aircraft on several grounds: First, safety, pilots who are used to the handling of an aircraft equipped with “fixed devices” to help prevent the onset of stalls but are not familiar with these characteristics at an increased max weight will suffer at a higher accident rate at low altitude based to final accidents. Being able to recover from a stall is a fundamental of flying and should not be ignored. Secondly, manipulation of the system, I believe that many of the supporters of this weight increased exemption have ulterior motives. Some of them are equipment suppliers and standard gain financially. Others are hoping that this will set a precedent allowing themselves to produce heavier aircraft than the LSA rule intended under the guise of safety. This is an example of the all mighty dollar at work, where profits precede safety. We should not allow the sacrifice lives of pilots to set a precedent, there are mechanisms in place to have the rule changed if that is your desired intention but not by attempting to manipulate the FAA. Thirdly, potential FTC Anti-Trust Violations, if this exemption is granted it gives Icon Aircraft a competitive advantage over every other LSA manufacturer in the industry. In the interest of taxpayers, I do not want to see the time, money, and resources wasted debating this issue between these two federal institutions. The FAA spent considerable amount of time and taxpayers dollars putting together the LSA rules and to disregard them because one company presold or at least took deposits for 700 aircraft that does not fit into the category in which it was promised is absurd. Fourthly, the audacity of icon aircraft to ask for 250 pounds for wing cuffs and airfoil shift and presenting it to the public and FAA as a new technology that they invented is preposterous. The “Spin Resistance Technology”, as they refer to it, has been known for over half a century. Proper design of the aircraft would allow them to incorporate their “SRT” within the allowable limit of the existing LSA rule. If you refer to the attached “ICON A5™Aircraft Delivery Position Agreement” you will see their standard and optional equipment list as follows: ICON A5 – Amphibious Light Sport Aircraft (S-LSA) Performance Specifications: ASTM Standards: Aircraft will meet or exceed the requirements as established by the ASTM F2245 standard: “Standard for Specifications for Design and Performance of a Light Sport Airplane.” Seats: 2 Maximum Takeoff Weight: 1430 lbs Useful Load: 430 - 530 lbs (option dependent) Baggage: 60 lbs (maximum) Fuel (Auto Gas or Av Gas): 20 gal Maximum Speed (Vh): 105 kts (120 mph) Range: 300 nm Takeoff & Landing Distance: 750 ft Engine (Rotax 912 ULS): 100 hp Standard Equipment: Retractable landing gear Manual wingfold GPS moving map Analog flight instrumentation (per ASTM LSA standards) Intercom system VHF Communication Radio Mode C Transponder Standard Documentation: Pilot Operating Handbook (POH) Airworthiness Certificate Weight and balance data Optional Equipment: (Pricing and Availability to be provided at Production Notice) ICON Complete Airplane Parachute Automatic Wingfold Night Lighting Package Seaplane Configuration (no landing gear) Attitude Indicator Custom A5 Towing Trailer Glass (LCD) multifunction display In their petition for weight exemption they make no mention of any of these non-essential and extremely heavy features. If they were to remove the non-essential equipment illustrated in ASTM F2245 they would be under the allowable existing limit and no exemption for weight would be necessary. Either reduce the weight by elimination of unnecessary features or adhere to Part 23 Type Certification. .

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