"T o d d P a t t i s t" wrote in message
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[...]
You might read the Exemption as saying that the reasoning
behind granting it applies only to the specific design of
the Mermaid:

"The FAA finds the structural integrity of the Mermaid
aircraft is enhanced by its "flying boat" design. This
design offers increased protection for the occupants in
event of landing with improperly positioned landing gear. "

Interesting.

The finding of "structural integrity" would apply to any amphibian,
boat-hull or float-equipped. It's almost as though the FAA was not at all
concerned about gear-down water landings, but rather gear-up land landings,
and that it's really just the prohibition against retractable gear as it
relates to the usual landplane retractable gear issues that they were
focused on.

If so, I take back what I said about the FAA's thinking making sense. As an
owner of an amphib myself, I suppose I might have jumped to conclusions and
given the FAA the benefit of the doubt, thinking that they correctly
identified gear-down water landings as a significant safety risk that LSA
ought to avoid (gear-up on land is usually just expensive, gear-down on
water is often fatal and at a minimum almost always involves injuries). But
based on a reading of the text you've quoted, it seems they might have
foolishly just been worried about gear-up landings on land and don't really
care about the water-flying issues.

It will be interesting to see if they extend this waiver from the "no
retractable gear" rule for all amphibious LSA aircraft. If so, then they
are just being foolishly inconsistent, as usual.

Pete