### Petition for exemption **from compliance with 14 CFR 61.58**  **for turbo**  **- jet powered glider N3JJ** 

09/05 /2012 **Contact:** Robert Carlton 604 Newport Ct. SE Albuquerque, NM 87123 Mobile: 505 - 239 - 5967 bob@desertaerospace.com Petition for relief I am seeking relief from the recently published regulation under 14 CFR 61.58, as it may pertain to the operation of our turbo -jet powered Comp - Let TST - 14 glider . Reason for seeking relief There are currently only a few turbo -jet powered gliders that are affected by FAR 61.58. Aside from their turbo -jet self - launch ing or self - sustaining capability, they maintain essentially the same operating parameters as conventional piston - powered motorgliders, the operation of which require s only an endorsement from an authorized instructor. FAR 61.58 was originally written with the words “ an airplane that is ...turbojet - powered” (italics ours) . This wording was continued throughout the NPRM process. The word “aircraft” replaced the word “airplane” only upon publicat ion in the text of the Congressional Record (although the paraphrased chart still used the word “airplane”). It is probable that the addition of the word “aircraft” was inadvertent, and may actually be in violation of the Administrative Procedures Act (AP A), as the public did not have an opportunity to comment on the rule as it pertained to aircraft that are not “airplanes” (such as gliders). It seems obvious that the intent of this rule is to ensure competency of pilots of turbo -jet airplanes, the operat ion of which requires specific skills not normally required for piston - powered airplanes. Turbo -jet airplanes typically fly higher, farther and faster than their piston - powered counterparts. They require specific navigation skills, system operation skill s, an understanding of high altitude operations, energy management skills on landing, etc. Turbo -jet powered gliders operate at essentially the same flight parameters as their piston - powered counterparts. In fact, the only disti nct differences are genera lly somewhat superior climb performance, simpler operation , higher reliability and less volatile fuel. The turbo -jet engine is typically only used for self - launching (without a tow plane) or to prevent off - field landings while cross - country soaring. All of these actually improve the safety of these aircraft without requiring any skills that would necessitate an annual proficiency check. They do not operate at significantly higher speeds, higher weight or higher altitude than piston - powered motorgliders . Landings are normally conducted with the engine shut down and retracted.Extent of relief

I am seeking relief from FAR 61.58 as it pertains to the operation of our experimental turbo -jet powered Comp - Let TST - 14 glider (N3JJ). Benefit to the public This petition will benefit the public as a whole by reducing the training burden on pilots of our turbo -jet powered glider , which offer s substantial safety enhancements and has demonstrated an excellent safety record . Equivalent level of safety This exemption will provide an equivalent level of safety by encouraging development of low workload, reliable self - launch and self - sustain capabilities for gliders , thereby increasing the safety of motorglider operations. Summary It is obvious that the original intent of FAR 61.58 was to enhance the currency training for complex turbo -jet powered airplanes. The inclusion of gliders in this rule by the arbitrary (and possibly illegal) substitution of the word ‘aircraft’ for ‘airplane’ after the comment p eriod expired substantially increases the training burden on pilots who fly, or intend to fly these aircraft.