21 May 2012

I am writing to seek an exemption from sections 61.113 of Title 14 of the Code of Federal 

Regulations (CFR).

§ 61.113

 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a 

private pilot certificate may act as pilot in command of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft.

I hold a private pilot certificate and am seeking this exemption to achieve the Coast to Coast 

Biofuel Airplane Project, a flight from Rhode Island to California that will take place in a Cessna 

182 equipped with an SMA aviation diesel engine fueled with an ASTM approved 50-50 blend 

of renewable jet fuel mixed with petroleum Jet A. 

The purpose of this flight will be to demonstrate the use of renewable aviation fuels and aviation 

diesel engines, to further aviation and aviation safety, and to educate both students and the 

general public on the benefits and potential of aviation and renewable energy. Both renewable 

aviation fuels and aviation diesel engines have numerous benefits to both aviation and aviation 

safety. The benefits of renewable aviation fuels include domestic production, no lead additives 

as in 100LL aviation fuel, and the potential to be sustainably produced. The benefits of aviation 

diesel engines include greatly improved fuel efficiency over traditional aviation engines in the 

range of 30-40%, and greater reliability and safety over traditional aviation engines as they have 

no magnetos, spark plugs, or other ignition components that are subject to failure with avgas 

engines.

I am seeking this exemption to enable the use of funds to be raised for this project from 

sponsorships, including corporate and other sponsors, and other sources to be used to pay for the 

costs required to achieve the Coast to Coast Biofuel Airplane flight including cost per hour for 

use of the airplane, fuel costs, and other costs associated with the flight such as food and lodging. 

I am also seeking the exemption to allow for the sponsorship and/or donation of equipment that 

will be used to achieve this flight. None of the pilots, private or commercial, flying the airplane 

during this flight will receive any payment other than the expenses needed to meet the costs of 

this one time round trip from Rhode Island to California and back.

As a science teacher at Ponaganset High School in Rhode Island I have already safely and 

successfully achieved innovative renewable energy projects designed to provide outstanding 

educational opportunities to students and promote the benefits of clean, renewable energy

technologies. My first major project was Protium, the World’s First Fuel Cell Powered Band. 

This rock and roll band comprised of Ponaganset High School students powered the entire show 

using hydrogen fuel cells and demonstrated fuel cell technology around the country at fuel cell 

conferences and other events. The success of this fuel cell powered band led to the development 

of a Fuel Cell and Alternative Energy course at the school and to the next major project, a full 

size, street legal Fuel Cell Model T hot rod that cruises with an astonishing silence and produces 

zero emissions. To demonstrate the benefits of biodiesel and engage students in real world, 

hands on learning, three students and I drove cross country using essentially pure biodiesel on 

the Coast to Coast Biodiesel Pickup Project. The biodiesel fuel performed perfectly on the entire 
round trip over 7,000 miles and the project successfully demonstrated the reliability and 

feasibility of biodiesel. As with all these projects, educational is a primary goal and a great 

number of students benefitted from the learning. Thanks to extensive media coverage the 

educational component was brought to the general public as well.

Information on these projects can be seen on the websites 

www.protium.us

www.biodieselpickup.blogspot.com

The Coast to Coast Biofuel Airplane Project is based on the foundation of success built through 

these previous projects. While the education component is just as important, due to the nature of 

aviation projects this project will not be done through the school. The organizations involved 

with this project are the Paramus Flying Club, a non-profit organization based in New Jersey, 

and the Aero Energy Association, a Rhode Island non-profit organization.

Safety is the first priority of this project and this request will not adversely affect safety in any 

way as the exemption only addresses compensation for the costs needed to achieve this project. 

I have been working to achieve this project for over four years and have done extensive research 

and planning to achieve this goal safely and properly. The fuel used for this flight will be ASTM 

approved renewable jet fuel mixed in the ASTM approved ratio of 50% renewable jet fuel with 

50% Jet A. The producer of this fuel is UOP, a company that was selected after discussion with 

FAA fuel specialist Mark Rumizen, whom I have been talking with since October 2009 and has 

been a major help. After ASTM approval in 2011, the technical data on UOP’s renewable fuel 

blend was provided to aviation diesel engine manufacturer SMA, and after reviewing the 

technical data for this fuel blend, SMA has no objections to the use of this 50-50 blend of 

renewable jet fuel with Jet A in their aviation diesel engines. 

Information on this ASTM approved renewable jet fuel and Jet A blend is available on the FAA 

Special Airworthiness Information Bulletin: NE-11-56 from September 14th 2011

The level of planning on all aspects of this flight will ensure that it is not only as safe as any

other cross country flight, but safer. Members of the Aircraft Owners and Pilots Association 

(AOPA) the Experimental Aircraft Association (EAA), Paramus Flying Club, and other 

organizations and individuals have been consulted on numerous aspects of the flight including 

route planning, best altitudes, stopovers, refueling, preferable time frame and other areas 

essential to flight planning. Pilots on this flight will include me and other members of Paramus 

Flying Club, who will share the flight responsibilities in the safest manner possible.

To achieve the maximum potential of this flight media coverage is an integral component. 

Through the extensive use of media the many positive aspects of aviation, aviation biofuels, and 

aviation diesel engine technology can be shared with the widest audience possible. Positive 

media coverage has not only greatly benefitted all my previous projects, but has made many of 

them possible. As with all my previous projects, the educational aspect of this flight has 

enormous potential. As a science teacher, one of my goals for this project is to get students and 

others more excited and interested in science and to share with them the many opportunities in 

science that aviation holds, ranging from pilot to aeronautical and aerospace engineering. 

Aviation is also a vast frontier for the use of American grown and produced biofuels that will 

create a great many jobs in our country. Media coverage including newspapers, television, the 

internet, and other sources will enable the Coast to Coast Biofuel Airplane Project to reach the 

widest audience possible and maximize the many positive benefits of this flight. With this in 

mind, if media is considered compensation in any way I am also seeking an exemption to allow 

media coverage of this flight.
The Coast to Coast Biofuel Airplane Project will benefit the public as a whole by clearly 

demonstrating the emerging technologies of renewable aviation fuels and aviation diesel engines 

and will certainly benefit aviation, aviation safety, and renewable aviation fuels. This project 

will also benefit students and the public through educational outreach on aviation, aviation 

safety, and the use of renewable fuels in aviation and other applications.

Summary for the Federal Register:

To meet the costs required to achieve the Coast to Coast Biofuel Airplane Project an exemption 

from sections 61.113 of Title 14 of the Code of Federal Regulations (CFR) addressing Private 

Pilot privileges and limitations regarding for compensation or hire is requested. The purpose of 

this flight will be to demonstrate the use of renewable aviation fuels and aviation diesel engines, 

to further aviation and aviation safety, and to educate both students and the general public on the 

benefits and potential of aviation and renewable energy. The Coast to Coast Biofuel Airplane 

Project will benefit aviation, and the emerging technologies of aviation biofuels and aviation 

diesel engines. The educational component of this project will benefit students through the many 

connections between aviation and Science, Technology, Engineering, and Math (STEM) 

education.

 

Thank you for your help with this endeavor.

Sincerely, 

Ross McCurdy

10 Meadow View Drive

Smithfield, RI 02917

rkmccurdy@yahoo.com

401-231-7986 home

401-241-6506 cell