To: US Department of Transportation Docket Operations West Building Ground Floor Room W12

- 140 1200 New Jersey Avenue SE. Washington, DC 20590



## Petition for Exemption (Maverick SLSA)

Sec. 11.81

A. Contact Information:

Indigenous Peop les Technology and Education Center, Inc. (Itec) 10575 SW 147th Circle, Dunnellon, Fl. 34432

Ph: 352

- 465

- 4545

Email: troy@itecusa.org

Petition Summary

This petition seeks an exemption from Title 14 Code of Federal Aviation Regulation (CFR) Part 21, § 21.190(c)(2) to permit an additional weight allowance for a powered parachute (PPC) light

- sport aircraft (LSA) intended for both flight operations and operation on public roadways

, similar to the weight allowance for L SA intended for operation on water. A roadable PPC has similar weight penalties to an LSA intended for operation on water due to the additional equipment required to make the vehicle roadworthy , and therefore a similar weight allowance seems appropriate.

Itec

, as the developer of the ASTM International consensus standards compliant special category light

- sport aircraft (SLSA) known as the “Maverick”

, is requesting an exemption from the current restriction of a maximum take

- off weight (MTOW) of 1,320 pound s (600 kilograms) for aircraft not intended for operation on water. The exemption is requested to allow the “Maverick” PPC LSA design to include structures, systems, and instruments necessary for it to safely operate in both the air and on the ground. In o rder to meet these design requirements and still maintain a suitable useful load for flight operations, the “Maverick” PPC LSA will require a MTOW of 1,430 pounds (650 kilograms), the same as an LSA intended for operation

on water.

If approved, this petit ion for exem ption will allow Itec to issue a statement of compliance (FAA Form 8130

- 15) for each Itec “Maverick” PPC LSA for operation at the same weight prescribed by 14 CFR Part 1, § 1.1 for LSA intended for operation

on water.

B. Petition for exemption fr om:

Title 14, Code of Federal Regulations (14 CFR) part 21, § 21.190(c)(2) (c) Manufacturer’s statement of compliance for light

- sport category aircraft. The manufacturer’s statement of compliance required in paragraph (b) (1) (iii) of thissection must

- (2) State that the aircraft meets the provisions of the identified consensus standard;

C. Extent of and reason for relief:

Relief from the reasonable LSA gross operating weight restrictions is needed solely and only to offset a relatively small portion of the additional weight required of any practical multi

- medium vehicle that can both drive and fly.

We are asking for a 110 lb (50 Kilo) exemption that would allow an increase in the

gross operating weight for a ‘flyable and driv able’ Maverick

, from the sta ndard LSA gross weight of 1320 lbs to 1430 lbs, the allowable weight for an amphibious LSA.

Every vehicle is a compromise. Some planes are extremely fast but require very long runways. Others are STOLish but give up cruise speed. Others with complex

wi ngs can take off short and fly fast but are extremely expensive. The Maverick was designed to capably meet the structural requirements of both air and ground operations while incorporating essential safety equipment for both air and ground operations.

There is a Federal Motor Vehicles Safety Standard (FMVSS) in the United States, which was established for major motor vehicle manufacturers. These standards are incredibly complex and would be virtually impossible for a low volume vehicle

manufacturer to meet.

States have developed numerous exemptions from the FMVSS to allow the development and sale of vehicles designed for specialty use s. The "Kit Car" exemption is one good example of such an exemption. In Florida and other states

there are other exe mptions including an exemption called "Assembled from Parts". This exemption allows parts from damaged vehicles to be used to rehabilitate repairable vehicles.

The Maverick was designed to be safe on public roads even at highway speeds. But

it was als o designed to be operable off road, and in the air with the capability of operating on water and snow as well. It would not only be prohibitively complex to attempt to meet all the FMVSS on a vehicle such as the Maverick; but it would also be exorbitantly expensive and extremely heavy.

Attempting to meet all FMVSS is beyond the realm of feasibility for a road capable Powered Parachute, privately funded, and manufactured in small quantities.

We have chosen to design this first practical multi

- medium Po wered Parachute to be ground licensed under allowed exemptions to the FMVSS . We anticipate that there will come a time when there will be a special vehicle safety standard for multi

medium vehicles. In the meantime our only realistic option is to license the Maverick for ground operations under State rules for motor vehicles instituted for innovative, low production vehicles that fit a specific need that is in the best interest of the public

to be allowed

.Even though the Maverick will not meet all the F MVSS, t he re are items that are required to make the vehicle roadable that result in added weight compared to a

traditional Powered Parachute . They include :

1. A completely independent ground drive system to an LSA Powered Parachute with full, safe roadable capabilities (including a

transmission with a differential and reversing capabilities, driving robust drive axles through a CVT drive

– (Add 120 to 140 lbs)

2. A robust, active suspension system

– (Add 25 lbs)

3. Automotive headlights, blinkers, stop lights, spe edometer, windshield clearing system

– (Add 6 to 10 lbs)

4. A heavy duty braking system on all wheels

– (Add 12 to 15 lbs)

5. Four large roadworthy wheels and tires (rather than the three small wheels standard on LSA flying only machines

– add 50 to 65 lbs)

6. And the structure necessary to make the fuselage capable of protecting the operator and occupants during a collision

– (Add 35 lbs)

These items add between 250 and 280 lbs to a roadable Powered Parachute , even if great care is given to cutting the weight of t hese extra systems while still adequately addressing safety concerns

. These additional systems and structures would easily top 400 lbs if great care were not exercised in keeping the weight to a

minimum

.

There is no question that an exemption greater than 110 lbs would allow us to

reduce the cost of some of the additional roadable equipment, systems and structure and would allow us to add other desirable but not absolutely necessary

features. The reason we ask only for 110 lbs is that we understand and sup port the reasons for limiting LSA gross operating weights and believe that we and other s attempting to produce multi

- medium LSA vehicles , should be extremely disciplined in the area of weight reduction

.

After great effort to design carefully and to limit weight in every reasonable way, we have produced a truly robust, capable and safe

– roadworthy Powered Parachute that weighs just under 1000 lbs. With weight allowance for a real pilot and passenger and a bit of baggage (350 lbs) and fuel for two and a ha lf hours of flight, plus reserves (14 gallons = 84 lbs) the absolute minimum gross weight necessary to make the Maverick practical without sacrificing safety, is 1430 lbs. To make this possible we absolutely need a minimum 110 to 150 lb gross weight exem ption.

We are asking for 110 lbs but would like to encourage consideration of a slightly higher exemption of 150 lbs.

The current ASTM consensus standards do not need to be changed in any way to allow production of the Maverick LSA Powered Parachute whi ch is also road capable and safe. All that is needed and all that is being requested is a Gross Weight exemption allowing a maximum takeoff weight of 1430 lbs, equal to the Maximum Gross Weight allowed for Amphibious Light Sport Aircraft.D. Public intere st and benefit:

1. The ‘Maverick’ can be flown safely by anyone with experience driving an

automatic transmission car and is willing to invest the time necessary to get

twelve hours of instruction required to acquire an FAA Sport Pilot License with a

Powered Parachute endorsement.

2. T he Maverick is a fully li censable roadworthy vehicle (also off

- road capable).

3. T he Maverick is capable of safe flight

.

4. The Maverick can be converted from driving mode to flying mode and back in just

a matter of a few minutes.

5. Th e Maverick is fuel efficient

, burning approximately 5 gph in the air and getting up to 30 + miles per gallon on the ground.

6. The Maverick has a parachute to lower it to the ground if something should go wrong in the air.

7. The Maverick uses regular automob ile fuel.

8. Any normal automobile mechanic with some special training could maintain the

Maverick.

9. The Maverick can maintain highway speeds, it can drive thru McDonald’s drive thru and it can park on the street.

10. The Maverick can land and take off in abou t two hundred feet (depending on take off weight).

11. Above all else, it can be operated safe ly both in driving and flying mode

– -

But there is one very important area in which this very capable, easy to operate and easy to maintain multi

- medium vehicle i s currently lacking. To include the structures and equipment necessary to be safe on the ground and to still be able to carry a reasonable load while flying, the Maverick needs a small but critical exemption from the current standard gross we ight limitati ons for standard LSA’s

.

The reason why granting our request for an additional 110 pound exemption from current Light Sport Aircraft, Gross Weight Limitation is in the public interest is that roadway congestion is not only a growing public nuisance, but th is congestion has

also become a significant factor in reducing American work productivity while increasing our dependency on foreign oil. Highway congestion also increases the danger of operating a motor vehicle on our highway system today.

The solution to congested roads is not likely to come from our public sector

be cause the cost of adding roadways in our most congested areas is beyond the ability of our debt ridden economy to support . G overnment entities have already

made all reasonable efforts from car

- pooling initiatives to multiple occupant lanesand sequenced traffic lights, limited access highways and novel concepts such as

traffic circles to alleviate congestion on our highways. Industries have already tried staggered work start times, work at home concepts, and new communities designed to allow people to live where they work and work where they live.

Public transportation works where it already exists but offers a solution to traffic congestion only in limited and very closely defined areas. The cost of subway systems, elevated trains or high speed rail s come with such a horrendously high price tag that they are also beyond the realm of practical implementation as are adding roadways or double decking major highways

.

The only viable solution left to reduce road congestion is the development of a free ‘skyway’. And the only significant impediment to developing a novel skyway transportation sys tem is designing an affordable, safe and user

- friendly vehicle or vehicles that can operate on the gr ound and in the air.

The only obstacle to the Maverick being the first practical vehicle with the capability of combining highway s and skyway s is the current weight restricti ons that were understandably established without consideration being given to the added structure needed for two independent drive systems and two control systems and the substantial added structure necessary to safely carry a single vehicle on the ground

as well as in the air.

Fortunately in the original LSA rule there was considerat ion given to the added weight necessary for aircraft designed and built to be able to land and takeoff on

water as well as land. Such a capability does req uire a stiffened airframe and requires a floating fuselage or pontoons

, which add weight . M uch less additional

structure is required to make an aircraft capable of landing and taking off on water

, however, than is required to produce an aircraft that requires two completely independent drive systems, and which requires two control systems (ground and ai r) and the safety equipment necessary to safely navigate two completely different

mediums.

A roadable Powered Parachute must have headlights, brake lights, blinkers, heavy brakes, large wheels with heavy tires, a transmission with a differential and a

re versing gear, windshield clearing mechanism

, and it must be able to protect the occupants in case of collisions with other vehicles in ground operation

Any dual medium ‘Flyable Car or Roadabl e Aircraft’ that has even a small potential for alleviating cong ested roads and public transport systems, and which the private sector in our country is willing to invest in developing, IS DEFINITELY IN THE

PUBLIC INTEREST AND WOULD BENEFIT THE PUBLIC AS A WHOLE.

There is wide and varied interest in the Maverick in re spo nse to articles and publicity

about this unique aircraft which have appeared in journals such as Popular Mechanics (who awarded the Maverick their prestigious "Breakthrough Award" in 2009), Christianity Today in September 2010, American Morning on CNN a nd on the

CNN website on October 27 2010, Sport Aviation in Nove mber 2010 and numerous

n ewspapers, radio stations and television programs around the country.This unsolicited interest in the Maverick has prompted a flurry of inquiries that reveal

the broa d application possibilities for the Maverick as soon as it is available to the public. Potential customers are interested in using the Maverick in many ways including the following uses:

o Border patrol

o Pipeline patrol

o Aerial surveillance

o Disaster evaluat ion (i.e. Hurricane Katrina damage assessment)

o Search and rescue

o Contamination inspection (i.e. oil slick identification and location in the Gulf)

o Wildlife counting

o Ranching; fence line flying and repair and livestock control and care

o Extreme sport use

o Tra nsportation beyond roads

o Aerial application of pesticides for disease control

o Transportation in congested areas

o Medical evacuation in frontier areas

o Medical, aerial caravans in areas of the world where medical

services are not available

o Delivery of critica l supplies where ground transportation is not

efficient or available

o Transportation for itinerant government workers in areas beyond

roads and beyond public transportation systems

o Fugitive pursuit

o Aerial traffic monitoring

o Use in conflict areas such as Ira q and Afghanistan where Improvised Explosive Devises are a constant threat (See US military DARPA specification for multi

- medium vehicle that can be used by average, non

- aviator ground troups )

o Aerial mapping of natural resources

o Geodetic Survey mapping

A common theme running through many inquiries is the search for an alternative to helicopter transportation, which is expensive and requires a highly trained pilot. There is a growing recognition that the Maverick can be flown safely by operators

who have a defined need but lack aviation experience and also lack the time necessary to master the skills needed for piloting typical fixed wing or rotary wing

aircraft.

E. Safety issues:

Granting of the weight exemption being sought here for the Maverick LSA Pow ered Parachute would not compromise safety. In this case, it is precisely for safety sake that the exemption is being sought.

The additional gross weight allowance made for “Amphibious LSA” is made, I

believe

, for a very similar reason. Every amp hibious LSA I have studied has a

sufficient useful load that it could function without the additional 110 pound grossweight allowance given automatically to amphibious LSA’s. But, it would do so only at the expense of giving up a second passenger or by compromisi ng safety. The same reality is even more applicable to a roadable Powered Parachute such as the

Maverick.

There is no question that landing on water requires more structure than landing on the ground does. Producing an aircraft that can land on both land and water requires

more structure than that required for landing on only water or ground. An amphibious aircraft requires floatation capacity and wheels

- and the wheels need to be retractable, which is not even allowed on other LSA’s.

In the same manne r of thinking, I believe the case is self evident that to build an LSA Powered Parachute that is structurally sound in flight and road legal , as well as road safe, with a useful load sufficient to allow practical operation as a two

- seater (without

which ca pability the Maverick would not be economically viable ) will require a weight exemption . The weight exemption is needed precisely to allow sufficient necessary additional structure to make it safe in both air and ground operations.

I would suggest that allowing a weight exemption for a road legal LSA Power ed

Parachute makes great sense from a safety standpoint. Powered Parachutes are by their very nature

- slower and inherently less prone to stall and spin accidents as

well as loss of control accidents from unintentional flight into I MC conditions than are other aircraft. These inherent safety characteristics of Powered Parachutes make the Maverick a prime candidate to explore multi

- medium operations and make it a safe candidate for operation by low tim e Sport Pilots

It makes sen se to limit LSA’s maximum stall speed from a safety standpoint . The lower the speed, the lower the mom entum and the l ower the likeli hood of injury to aircraft and occupants in case of an accident. It also makes obvious sense t o limit

the conditions in w hich LSA’s can be flown by Sport Pilots

, who by specific definition

are held to a lower minimum

- licensing standard than “Private” pilots are.

The reasons for limiting th e maximum gross weight of LSA’s are also

reasonable

. Less weight means less momentum

, just as slower flight speeds limit LSA momentum in the event of an unplanned or uncontrolled contact with the ground

. Allowing a slightly higher gross weight for the Maverick, however, does not

create excessive momentum because the speed of flight is significantly less than even the stall speed of other LSA’s.

In the case of the weight exemption being requested for the Maverick LSA Powered Parachute, the modest weight increase is specifically sought to allow an increase in

saf ety with no significant offsetting increase in momentum . The weight increase sought cannot possibly even cover the most modest additional mechanisms and systems required for safely operating Mavericks on the road.

Safety is the specific reason for the exe mption sought for the Maverick.

We understand from LSA documents that the LSA standard was written to encourage innovation in aviation and the development of aircraft that can be safely operated by pilots with limited licensing requirements.Granting a m odest exemptio n to the gross takeoff weight of the Maverick will definitely help give this innovative new multi

- medium aircraft a chance to succeed in the competitive marketplace, will help rejuvenate the flagging LSA Powered

Parachute category and will al low all of this to be accompli shed with a high degree of safety.

F. Petition Summary

This petition seeks an exemption from Title 14 Code of Federal Aviation Regulation (CFR) Part 21, § 21.190(c)(2) to permit an additional weight allowance for a powered parachute (PPC) light

- sport aircraft (LSA) intended for flight operations and operation on public roadways that is similar to the weight allowance for LSA intended for operation on water. A roadable PPC has similar weight penalties to an

LSA intended for o peration on water and therefore a similar weight allowance seems appropriate. Itec, as the developer of the ASTM International consensus standards compliant special category light

- sport aircraft (SLSA) known as the “Maverick” is requesting an exemption fro m the current restriction of a maximum take

- off weight (MTOW) of 1,320 pounds (600 kilograms) for aircraft not intended for operation on water. The exemption is requested to allow the “Maverick” PPC LSA design to include structures, systems, and instrument s necessary for it to safely operate in both the air and on the ground. In order to meet these design requirements and still maintain a suitable useful load for flight operations, the “Maverick” PPC LSA will require a MTOW of 1,430 pounds (650 kilograms), the same as an LSA intended for operation on water.

If approved, this petition for exemption will allow Itec to issue a statement of compliance (FAA Form 8130

- 15) for each Itec “Maverick” PPC LSA for operation at the same weight prescribed by 14 CFR Part 1, § 1.1 for LSA intended for operation

on water.

G. Additional supporting information:

The United States has been a world leader in aviation technology and manufacturing ever since one of the Wright Brothers packed the 'Wright Flyer' to England on a s hip and demonstrated to the European aviation community that the 'Wright Flyer' could not only fly, but it could also turn.

Roadable Aircraft or 'Flying Ca rs' as the public likes to think of them will become a reality because there is a growing need for such aircraft. The question is

, who will lead the way? Itec, a North American technology innovator

, has developed what could soon be the first practical LSA Powered Parachute with robust Roadable capabilities to go into production.

We have developed the machine and the Federal Aviation Administration has found it to be airworthy and to conform to ASTM standards. The Florida department of Motor Vehicles has licensed it to operate on the public roadway system.

There is one remaining obstacle that stands between the Ma verick and success. It is Itec’s desire to help put the USA out front in the development of a practical road capable aircraft: creating jobs by building it where it was 'born' and making itpractical as an LSA for use here in America

- Monit oring pipelines and borders, helping find people who need rescue, affordably monitoring traffic with the ability to land and lend a hand, and least but probably not last

- having a whole lot of fun doing all of the above . T he only need is a weight exempti on of 110 to 150 pounds necessary to allow the Maverick to operate both in the air and on the ground, safely,

while c arrying two reasonabl e sized people and a modest amount of fuel.

Can Sport Pilots safely operate a Maverick? It has been brought t o our attention that there is concern regarding the ability of Sport Pilots to master the dual skills necessary to fly a roadable aircraft with two full sets of controls. We also understand that there is legitimate concern regarding the capability of 'fli ght critical' surfaces and controls to stand up to the rigors of ground operations without debilitation of their airworthy structures.

The Maverick, it should be noted, is radically different from a roadable fixed wing

aircraft in that it uses a fundament ally different technology for flight. The Maverick is a powered parachute with robust ground capabilities

- not a roadable 'aircraft' as the term is generally used.

Consider the following:

A powered parachute uses a ram air parachute to generate lift fo r flight. The parachute can be folded, compressed, and stored in a dedicated compartment

- isolated from the stresses of ground driving.

In the Maverick, there is a dedicated storage compartment bordered by chromoly steel tubing and covered in a heavy canvas cover that protects it not only from vibration but also from possible impacts with other vehicles and ground obstructions. The chute storage compartment also protects the chute from the elements

- rain, snow, sun etc.

Powered parachute 'wings' hav ing no internal structure s which are susceptib le to ground operation vibrations. T he greatest danger to a Powered Parachute wing comes from the pollution of support lines with dirt when the wing is launched from the ground as is common in all powered para chutes but the Maverick. The Maverick uses a proprietary chute deployment system, which allows the chute to be deployed without use of the ground as a launching platform.

Powered parachutes also have no protruding empennage. On the Maverick, there

are n o flight critical structures that protrude from the machine beyond the boundaries of the fuselage and suspension. The two 'spreader bars' which do protrude from

each side of the Maverick are well within the wheel footprint of the vehicle. As an

additiona l safely feature, these ‘spreader bars’, where the wing attaches, are supported by two cables each

– either one of which is capable of carrying the entire weight of the aircraft. There are actually eight support structures that connect the wing to the fus elage. Half of those structures could fail without jeopardizing the flight integrity of the Maverick.

The Maverick parachute and its support lines are designed to be able to survive even a debilitating ground collision or loss of ground control resultin g in a rollover ofthe entire vehicle. The propeller is susceptible in such accidents but damage to the propeller is readily observable in even a cursory pre

- flight walk

- around.

Upon deployment of the parachute prior to flight, the entire chute 'wing' and all of its support lines are easily observable. There are no hidden structures that can be critically debilitated without the damage being apparent to visual inspection prior to flight.

With regard to concern of roadable aircraft potentially exceedin g the skill level of Sport Pilots, it should be noted that the Maverick, again, is a powered parachute having

, with little doubt , the lowest fatality rate record of any light sport aircraft category.

The Maverick takes the easy to fly characteristics of t ypical powered parachutes to an unprecedented level in two ways.

First, the Maverick incorporates an integrated Ground

- Air control system. This integrated control system uses normal car controls: a steering wheel and foot

accelerator for air control a s well as ground control.

Second, as in all powered parachutes, shoul d the Maverick encounter a thrust system failure while in flight, control of the Maverick is still available to the Maverick pilot and the aircraft floats to the ground at a descent rate that the suspension system and the safety features of the seats can largely absorb. The likelihood of damage to the Maverick and occupants is limited because of the relatively slow flight speed ( 30 to 35 knots cruise speed that can be further diminished to as little as 28 to 32 knots prior to contact with the ground ) and the inherent stability of the fuselage

, which acts as a pendulum, makes stall

- spin accidents unlikely in the extreme

.

Further, the Maverick structure completely surrounds the pilot with a robust Chromoly steel tube cage and the seats are designed to deform upon hard impact to further protect the pilot and passengers. The Maverick has been tested in the

extreme scena rio where power was totally shut down in flight after which the pilot

mad e no control inputs whatsoever. The Maverick descended to impact with the ground without injury to either the aircraft or the test pilot. Superficial damage was sustained to one wheel rim, which deformed slightly but was still useable and the right rear wheel deflated due to the slight rim deformation breaking the seal with the right rear tire.

As is generally understood, powered parachutes are so easy to fly that instruction has been generally given to students with the instructor on the ground and the new student flying the powered parachute 'solo'. This tradition is unprecedented in aviation history, I believe.

Add to this the fact that the Maverick uses the same primary controls for pitch and directional control in both air and ground operations. The Maverick has back up controls that use the feet for steering and it has a second throttle that is hand operated. Bot h of these backup controls are completely separate of each other and can be used independently or in conjunction with each other.I n fact, the Maverick is so safe that in the case of a pilots debilitatio n in flight, it

would be reasonabl e for a passenger to simply do nothing. Or, the passenger could fly the machine from the rear seat. The passenger has access to the steering lines

f rom the rear seat and can acce ss the hand throttle as well. As has been pointed
out, t he Maverick is extremely resistant to stalls and spins and the fuselage structure is extremely robust and capable of absorbing predictable loads from almost any

normal f orced landing scenario due to the slow flight speeds , the relatively slow descent rate, and the robust nature of the fuselage structure.

The possibility of ground stresses affecting flight structure is also minimized by the Maverick design in which the flight structures and the ground structures are largely independent of each other. The Maverick fuselage is not only capable of handling

all normal on

- road stresses, but it is also extremely capable off road which was a foundational design criteria of thi s vehicle designed for frontier use 'Beyond Roads'.

The stresses of flight being much lighter than those required for ground operation and segregated from ground structures

, flight structures are almost entirely on top of

the machine with redundant flex ible cables supporting the lower fuselage in flight.

By its nature, the Maverick Powered Parachute, in flight, is a pendulum suspended by support lines from a self inflating parachute wing supported by a totally noncritical wing deployment system prior to flight. In flight the chute d eployment system is part of the required structure and only serves to dampen oscillations of the fuselage. The oscillations are not dangerous, however, but do diminish the engine thrust efficiency when the fuselage swings

, p utting the propeller at an angle that is not perpendicular to the line of flight.

In the Maverick even weight and balance

, though it affects the angle at which the fuselage hangs, is not critical except to the efficiency of the propulsive effort. The

M averick design, as is common on most p owered p arachutes , flies with the pilot ahead of the center of mass and the engine behind the center of mass. Passengers and cargo are located directly under the center of lift so that increas ing or

decreasi n g the wei ght of passenger or cargo has a negligible effect on the angle at which the fuselage hangs and no effect on the stability of the aircraft other than the angle of the thrust vector.

In summary, Powered Parachutes have several non

- critical limiting factor s such as low cruise speed. They make up for this non

- critical limitation, however, by being simply the easiest to fly and safest aircraft category in existence today.

As mentioned, the Maverick, with its:

1. Robust chromoly fuselage structure that complet ely surrounds the pilot and passengers

2. A full chute deployment system

3. Integrated controls that are intuitive to car

- qualified pilots

is arguably the safest and easiest to fly powered parachute design.