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REQUEST FOR EXEMPTION

This petition requests an Exemption to certain sections of 14 CFR Part 61 Subparts J 

and Subpart K, which defines the privileges and limits of a sport pilot certificate and flight 

instructors with a sport pilot rating. This exemption would permit individuals possessing 

a sport pilot certificate and/or an instructor certificate with sport pilot rating to operate an 

I-TEC/Beyond Roads LLC Maverick SP roadable powered-parachute that has been 

certificated with a maximum take-off weight of not more than 1,430 pounds and has 

been issued an FAA airworthiness certificate under FAA Exemption Numbers 10299 or 

10450. The requested Exemption would not alter any other provisions, privileges and 

requirements in 14 CFR Part 61 Subparts J or Subpart K.

This Exemption would be granted to I-TEC, the designer of the Maverick SP roadable 

powered-parachute. The operator of a Maverick SP roadable powered-parachute, if 

operating under the provisions of this granted Exemption, would be required to carry a 

copy of the approved Exemption on board the aircraft at all times.

BACKGROUND

On September 28, 2010, the I-TEC received a special airworthiness certificate for the 

Maverick SP roadable powered-parachute as an ASTM-compliant Special-Light Sport 

Aircraft. This milestone was the result of 6 years of development work to create a safe 

and practical solution to two distinct marketplace needs. The original design criterion 

was to create a multimodal solution to serve the needs of the indigenous people’s 

mission and humanitarian operations. A later-defined design purpose was as a simple, 

roadable aircraft that could meet the emerging interest and demand of recreational and 

utility marketplace. Due to the extremely simple operation and maintenance of the 

Maverick SP, development for the US recreational and utility marketplace was 

specifically intended to be operated by individuals meeting the requirements of the sport 

pilot regulations and light sport aircraft (LSA) repairmen certificates. This intended 

design criterion, as a simple powered-parachute (PPC), has been achieved.

On June 27, 2011, I-TEC was granted an FAA Exemption #10299 permitting I-TEC to 

issue special airworthiness certificates for Maverick SP Special-Light Sport Aircraft in 

excess of the 1,320 pound-defined weight limit for a light-sport powered-parachute under 

specific conditions. The additional weight allowance was determined to be recognition of 

the weight penalty of including a ground-drive transmission, road contact propulsion, 
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heavier wheels, etc, at the same weight increase permitted within the Regulations for 

fixed-wing LSAs "intended for use in water." On February 15, 2012, FAA Exemption 

#10450 was issued granting similar authority for certificate issuance of ExperimentalLight Sport Aircraft. 

As noted above, the intended design criterion of the Maverick SP was to be operated 

and maintained by minimally-trained individuals in the world’s frontier areas as well as

sport pilot and repairman certificate-trained individuals in the United States. Despite the 

granting of the airworthiness certificate exemptions mentioned above, the petitioner 

understands that pilots must still comply with 14 CFR Part 61 Subparts J and Subpart K, 

which refers to LSA definitions in 14 CFR Part 1. This restricts the operation of a 

Maverick SP issued an airworthiness certificate with the weight exemption, to holders of 

a private pilot certificate if an S-LSA and/or E-LSA Maverick SP exceeds 1,320 pounds 

maximum take-off weight. It is this onerous pilot certificate requirement which is the 

subject of this petition and detailed below.

The requirement that Maverick SP Powered Parachute LSA operators achieve private 

pilot powered parachute status puts a grievous and unnecessary burden on both 

Maverick SP operators and on I-TEC and Beyond Roads, LLC as the Maverick SP

designer and manufacturer. There are several reasons this restriction is unnecessary, 

burdensome, beyond reason and inconsistent with existing regulations for similar aircraft 

in this category. 

SUMMARY OF BURDEN

It is the opinion of the petitioner that individuals that hold a valid sport pilot certificate 

and/or a flight instructor certificate with a PPC rating are totally qualified to safely 

operate a Maverick SP that have been certificated under Exemptions #10299 and 

10450. The petitioner asserts that not permitting operation by sport pilot-qualified 

individuals:

1. is inconsistent with the intent and the spirit of the original SP/LSA regulations,
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2. is excessive and does not take into consideration the inherent safety of poweredparachute type aircraft and the unique design characteristics of the Maverick SP

roadable powered-parachute,

3. is difficult and unduly expensive for operators of a recreational vehicle to fulfill, and,

4. substantially reduces the marketability of this innovative, multimodal aircraft.

EXPANDED EXPLANATION

The petitioner asserts that not permitting operation by sport pilot qualified-individuals is 

inconsistent with the intent and the spirit of the original SP/LSA regulations and the 

exemptions granted for the Maverick SP.

It is the petitioner’s understanding that the original intent and the spirit of the SP/LSA 

regulations was, among other purposes, to provide for creation of a category of flying 

machines that would expand the opportunity of recreational flying though innovative 

design, affordable operation and assured appropriate safety by industry consensus 

standards. 

The Maverick SP has accomplished all of those regulatory intentions:

 innovative design - Awarded the 2009 BREAKTHROUGH Award by Popular 

Mechanics Magazine,

 affordable operation - fueled by automotive gas, maintained as a recreational vehicle 

and without the burden of airport use and storage costs, and,

 appropriate safety – assured by testing under ASTM standards.

Numerous years and considerable resources have gone into the development of the 

Maverick SP with the specific intended result of an innovative, yet simple and safe 

design and configuration. A restriction requiring a private pilot certificate to operate a 

Maverick SP LSA aircraft (with the exempted weight) is clearly inconsistent with the 

nature of the SP/LSA regulations. It is true that the Maverick SP is a unique, multimodal

aircraft, designed for use on public roads as well as for flight as a PPC. However, it 
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appears punitive to the innovation and creativity that has resulted in this safe aircraft to 

not be operated in the very strata of recreational flying machines that promoted the 

SP/LSA regulations in the first place.

The petitioner asserts that not permitting operation by these sport pilot qualifiedindividuals is excessive and does not take into consideration the inherent safety of 

powered-parachute type aircraft and the unique design characteristics of the Maverick

SP roadable powered-parachute.

Powered-parachutes fly slowly. Typical PPC speeds in all flight configurations are 30 

miles per hour (MPH) or less. The Maverick SP, due to its wing design and total weight

flies at about 40 MPH. Inherent in the creation of the SP/LSA regulations was the 

Agency’s intention to limit risk in the use of this segment of recreational vehicles. This 

was accomplished by limiting the passenger count to one, and mandating both a 

maximum stall speed and top cruise speed. PPCs, by their very design, cannot even 

approach the minimum speeds for other LSAs. The very slow speed of operating PPCs 

(and the Maverick SP), further, justify the adequacy of sport pilot training for operation of 

the Maverick SP, including those exempted to the 1,430 pound weight limit.

The Maverick SP structural design further contributes to the safety of operation by a 

sport pilot. While many PPC designs do not provide for much structural protection for 

the pilot and passenger, the Maverick SP design has considerable structure ahead and 

totally surrounding the pilot and passenger. The Maverick SP is built for rugged, off-road 

use (in the drive-mode) and therefore has structural integrity far in excess of any PPC, 

and many aircraft in other LSA categories. Further, the Maverick SP, when properly 

rigged for flight, will effectively land itself without pilot input. When the power is reduced 

to establish a decent rate, the inherent design and structural integrity provides for an

added margin of safety.

Operationally, standard PPCs use steering arms or pedals for directional control in flight. 

These control inputs are easy to master and intuitive (push the right pedal to turn right). 

To even further simplify this activity, the Maverick SP primary directional inputs are 

made with a steering wheel, which is intuitive to all automobile drivers and even natural 

to non-drivers (who have been regular passengers in automobiles with steering wheels). 

Additionally, the Maverick SP also has “back-up” steering pedals, which would be natural 

to all PPC-trained sport pilots.
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Probably the most significant justification for permitting sport pilots and flight instructors 

with PPC ratings to operate the exempted weight (not more than 1,430 pound gross 

take-off weight) is that the “Maverick” can be certificated and operated legally and safely 

by a sport pilot, IF the original certificated maximum take-off weight is below the 14 CFR 

Part 1-defined 1,320 pounds (e.g., the Maverick FT model). However, while this weight 

restriction was exempted in FAA Exemption Numbers 10299 and 10450 for the Maverick 

SP to allow “roadable requirements and features,” it also restricts the Maverick SP from 

being operated by sport pilots. In fact, the exempted-weight Maverick SP’s operational 

regime and maintenance requirements are identical to the lower-weight Maverick FT. 

There is no difference in aircraft preparation for flight, operation in flight and transition 

from ground-to-flight mode or flight-to-drive mode between these two models. 

Therefore, there is simply no safety or operational justification for limiting sport pilots

(and flight instructors) from operating the exempted-weight Maverick SP.

Additionally, the requirement for a private pilot certificate for the weight-exempted 

Maverick SP appears inconsistent with the obvious complexity of LSAs intended for use 

on water, which have been granted an allowable weight of 1,430 pounds and therefore

can be operated by a sport pilot. The requirement for a private pilot certificate to operate 

the Maverick SP at the higher weight appears in fact, to be discriminatory to this 

particular aircraft model.

All LSAs intended for use on water are more complicated to operate than Mavericks 

intended for use on public roads. The added operational complexity for water-intended

airplanes is not related to their greater weight (which is permitted under FAR Part 1), but 

rather the additional structure and systems needed to operate safely on water. In fact, 

the operational transition from flight mode to “sailboat” mode requires transition to 

different skills, utilizing different control inputs. This is not the case with the Maverick, 

which unitizes an integrated control system, requiring no such transition. Control input 

on the ground (in drive-mode) and in take-off and flight is with a steering wheel and footpedal accelerator, with no transition required. Even though (water-intended) aircraft 

operators must develop additional skills and decision-making abilities/proficiencies

necessary for water operations, rightfully, these operators are not burdened with a 

private pilot requirement. 

Finally, some - particularly those unfamiliar with the Maverick SP - might assume that a 

machine that can both fly and be driven, is not “simple.” The petitioner would assert that 

the definition of “complex” as related to LSAs was clarified by the regulations, with such 

restrictions as: unpressurized, no retractable landing gear, no in-flight adjustable 

propellers, etc. In addition to these regulatory-based definitions, the Maverick SP was 
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designed in every element, to be uncomplicated. It was designed to be maintained and 

operated by indigenous peoples that lack any formal flight education or mechanical 

training. As to the model-specific transition from a powered-parachute to the Maverick, 

the transition is a minimal ground session before the initial flight, following a complete 

Maverick orientation. The petitioner has overseen this transition by individuals ranging 

from an expertise PPC instructor and an individual with no flight experience other than 

his training to a PPC certificate. Both individuals conducted safe, solo first flights and 

are continuing the aircraft’s Phase One flight test protocol.

The petitioner asserts that not permitting operation by these sport pilot qualifiedindividuals is difficult and unduly expensive for operators of a recreational vehicle to 

fulfill.

There are currently only two active and qualified FAA examiners in the United States 

who are authorized to conduct Private Pilot Powered-Parachute flight exams. One of 

them resides in Illinois and the other in Texas and Nevada. The unjustified (from a 

safety standpoint) requirement for an individual to attain private pilot credentials more 

than doubles the cost of initial flight training, since there are more than twice the number 

of flight hours required, compared to sport pilot requirements. Additionally, an individual 

must travel to one of these examiners, adding even more to the substantial and 

unjustified expense before operating the weight-exempted Maverick SP. If the examiner 

demands that an individual take their instruction from that individual, the costs rises even 

more with housing and meals as well as lost-wages costs. There is simply no 

justification for imposing these additional personal financial burdens on these taxpayers.

The petitioner asserts that not permitting operation by these sport pilot qualifiedindividuals substantially reduces the marketability of this innovative, multimodal aircraft.

Based on the aforementioned financial burden and logistical difficulty in obtaining a PPC

private pilot certificate, it is likely that a product line that has been determined by the 

FAA to require more restrictive pilot training than all other powered parachutes and 

aircraft in the LSA category will result in the Maverick SP roadable powered parachute 

becoming stigmatized in the marketplace. In fact, the manufacturer has already 

experienced the reversal of one Maverick order due to this added burden. This is of 

grave concern to a new manufacturer attempting to recover 8 years of development 

costs.
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RELIEF AND PETITION

Based on the above, the petitioner respectfully requests that the FAA grant an 

exemption to all appropriate provisions of 14 CFR Part 61 Subparts J and Subpart K 

thereby permitting holders of a valid sport pilot certificate and/or an instructor certificate 

with sport pilot rating to operate an I-TEC/Beyond Roads LLC Maverick SP roadable 

powered-parachute that has been certificated with a maximum take-off weight of not 

more than 1,430 pounds and has been issued an FAA airworthiness certificate under 

FAA Exemption Numbers 10299 or 10450. The requested Exemption would not alter 

any other provisions, privileges and requirements in 14 CFR Part 61 Subparts J or 

Subpart K.

This Exemption would be granted to I-TEC, the manufacturer of the Maverick SP 

roadable powered-parachute. The operator of a Maverick SP roadable poweredparachute, if operating under the provisions of this granted Exemption, would be 

required to carry a copy of the approved Exemption on board the aircraft at all times.

I-TEC stand ready to provide any additional information, descriptions, briefings or any 

reasonable documentation necessary to support the granting of this petition.

Respectfully submitted,

Stephen F. Saint, CEO

I-TEC 

10575 SW 147th Circle

Dunnellon, FL 34432

FINAL FILED FAR 61 Petition 2012 05 10 .doc - Filed online @ www.regulations.gov on May 10, 2012 @ 12:20PM ET