May 30, 2025

Mr. Ludovic Masson,
Chief Standards
Transport Canada

PROPOSAL TO EXPAND THE AULA DESIGN STANDARDS
Reference: January 10-11, 2006 CARAC Part V Recreational Aircraft Working Group Final Report (attached)

BACKGROUND

During the last few years, UPAC members have approached the association for a way to carry passengers on a wider variety of ultralight aircraft types. The creation of Light Sport Aircraft (LSA) category in the United States with a higher MTOW resulted in a reduction in the number of new AULA types are not being added to the Canadian AULA list.

In 2006, a Transport CARAC Technical Committee established a Recreation Aircraft Working. The Working Group made recommendations that were received by Transport Canada but most of which were never implemented. Twenty-four years have passed since those recommendations were made. UPAC believes it?s time to reexam and update those recommendations, specifically those relating to Advanced Ultralight Aeroplanes.

PROPOSAL
UPAC and LAMAC propose that alternate design standards be included in DS10141 as appendices. One set of alternate design standard might be the current ASTM US Light Sport Aircraft design standards. Others might come from EASA and other countries.

UPAC suggests Transport Canada establish a Working Group to look at the possibility of expanding LAMAC?s Design Standards for Advanced Ultralight Aeroplane (DS10141). Initially, this can be a subgroup of the CGAJSC Ultralight Working Group since various stakeholder groups are already represented there.

At this time, UPAC is not proposing to a new Canadian Light Sport Aircraft category. We propose that since these aircraft fall under that Advanced Ultralight Standards, Transport staff could handle any new design standards under the current AULA procedures.

GOAL
The goal of this proposal is to allow the ASTM Light Sport Aircraft standards to be an acceptable means of including an aircraft in the AULA category.

POSSIBLE TOPICS for WORKING GROUP DISCUSSION

Find a mechanism to identify LSA Standards from other countries and append them to DS10141.

Find a way for manufacturers of aircraft accepted as LSA in another country to have reciprocity in Canada so that that a Document of Compliance would not be required. This would reduce a manufacturers? paperwork.

Other topics will be identified during Working Group meetings.

Kathy Lubitz, President
Ultralight Pilots Association of Canada (UPAC)
519-684-7628

KL/jb

c.c.:
Mr. Jeff Phipps, Chief Operational Airworthiness
Mr. Ryan Johnson, Chief Pilot Training and Licensing
UPAC Board of Directors

907289 Twp. Rd 12, RR #4, Bright, Ontario N0J 1B0
519-684-7628 www.upac.ca