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-launching or self-sustaining capability, they maintain essentially the same operating 

parameters as conventional piston-powered motorgliders, the operation of which requires 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 publication 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 (APA), 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 

operation 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 skills, 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 distinct differences are generally 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 offers 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 period expired substantially increases 

the training burden on pilots who fly, or intend to fly these aircraft.