Page 1 of 14

July 26 , 2012

To: U.S. Department of Transportation Docket Management Sy stem 400 7 th Street, S.W. Room PL 401 Washington, DC 20591

- 0001

PETI TI ON FOR EXEMPTI ON FROM FEDERAL AVIATION REGULATION 14CFR 103.1e(1) TO PERMI T MEMBERS OF THE AERO SP ORTS CONNECTI ON, TO CONDUCT FLIGHT ACTIVITIES IN GYROPLANE UL TRALIGHT VEHICLES THAT INC LUDE DEMONSTRATED NECESSARY SAFETY EQUI PMENT THAT IS OUTSIDE THE

CURRENT SCOPE OF PART 103.1(e)(1).

Petitioner: Aero Sports Connection , Inc. (ASC)

Jam es G . Stephenson 231 SW Bonanza Gln Lake City , FL 32025

- 2148 Phone 269

- 209

- 1466 Fax 386

- 269

- 0469 Ref 14CFR11.81(a)Page 2 of 14 **PETITION SUMMARY**

Petition for exemption from Federal Aviation Regulation 14CFR 103.1e(1) t o permit members of th e Aero Spo rts Connection (ASC) to conduct flight activities in gyroplane ultralight vehicles that include demonstrated necessary safet y equipment that is outside the current scope of 14CFR 103.1e(1), for the purpose of permitting ASC to create the Ultralight Vehicle Safet y Equipment research baseline per FAA Advisory Circular 103

- 7, paragraph 22

. Ref 14CFR11.81(b)

**REASON & BACKGROUND FOR PETITION** Ref 14CFR11.81(c,d) When 14CFR 103 was adapted in 1982, the typical ultralight vehicle consisted of a basic aircraft an d engine without brakes, self

- starters, improved suspension systems, or special equipment for disabled persons. Having grown out of the hang glider movement, ultralight vehicles were all extremely weight efficient and all secondary considerations of safe ty were sacrificed in consideration of reducing weight to ma ke flight possible. As the ultralight vehicle has matured and developed, basic designs and methods to achieve safe flight have additional margins for flight and ground safety that have resulted i n additional weight items that have become standard. A prime example was the introduction of the ballistic parachutes, which was accepted by both the FAA and the ultralight community as a critical safety of flight component. The ultralight community now feels the margin of ground safety could be raised to a higher standard by changing the wording of 14CFR 103.1(e)(1) to allow simple and proven safety devices like Gyro plane pre - rotator systems /starters and Gyro plane horizontal stabilizer systems. The addi tion of these systems could easily prevent serious hand propping and hand starting of rotor blades that leads to blade pre - rotating injuries and accidents

. Examples of fatalities and injuries directly related to these is sues are provided in appendix A

. These examples are not all inclusive yet show over 100 fatalities and 400 major injuries that could clearl y have been avoided under this simple exemption.

**REASON & BACKGROUND FOR PETITION** Ref 14CFR11.81(c,d) The second part of this exemption deals with future rulemaking action. ASC will use this exemption to conduct a two

- year study where accident data will be gathered on ultralight vehicles covered by this exempti on. ASC and the FAA will use data collected to establish an ultralight vehicle safety equipment baseline for po ssible rulemaking changes to 14CFR 103 or related documentation. Under the two

- year study pro gram ASC will: 1. Require all owners of ultralight vehicles operating under the terms of this exemption to submit an annual safety report to th e exemption holder. The annual safety report will consist of the following items: a. Owners name b. Ultralight vehicle make & model, and registration number (if applicable) c. Hours flown during the annual reporting period d. List of any accidents or incidents and their relation to the use of this additional safety equipment. e. List of injuries that resulted from these accidents and/or incidents 2. Consolidate annual safety reports by make and model of ultralight vehicle and forward them to the FAA, AFS

- 800 for their safe ty review.Page 3 of 14

3. Develop a listing of horizontal stabilizers which meet ASTM F2353

- 1 1 stability requirements thereby augmenting the knowledge base for both operators and manufacturers. See the horizontal stabilizer test requirements of Addendum 4. ASC firmly believe s that the use of these additional safet y devices will result in greater public safet y. We feel, by approving this petition, the FAA will be taking a step toward promoting safer ultralight vehicle flight and ground safet y. ASC is requesting this re search exemption be granted for a period of 2 ye ars.

**INTEREST OF THE PETITIONER** Ref 14CFR11.81(d,e) The Aero Sports Connection (ASC ) is 501(c) (4) non

-profit associations as granted by the Internal Revenue Service. ASC bring s together aviation enthu siasts, operators and ultralight vehicle owners who are dedicated to the continued safety and growth of aviation, the preservation of its history and a commitment to aviation’s future. ASC programs, activities and events are known throughout the world for supporting aviation safety and promoting personal enjoyment and responsibility within an aviation lifestyle. ASC has the goal of promoting aeronautical educational experiences by providing its me mbers and the general public with access to the world of flight. As such, ASC feel s that the granting of this exemption will provide the possibility of future growth in all general aviation related activities by promoting safety in this national recreational activity. The motives of this exemption request is to improve safety and seek, through research, a reduction of burden on the citizens, a reduction in government involvement and expenditures, as well as assurance of public safety. This proposal meets those goals. The proposed research project serves the purpose of encouraging flight proficiency and safety, while promoting additional flight activity and the resultant positive economic impact that such increased activity has on all segments of sport and general aviation. This economic impact includes incre ased commerce for manufacturers of aircraft and parts, as well as service providers.

**SAFETY ISSUES** Ref 14CFR11.81(e) The safety of its member pilots and the general public is a fundamental concern of ASC

. Implementing this exemption will result in an immediate increase the safety of the community and the pilots. The petitioner recognize s that the FAA’s fundamental concern is the general public safety. This exemption will provide a greater level of safety then the current FAR 103 rules. To ensure a high level of safety during this research project, ASC will: 1. Require reporting on all incidents and accidents at each yearly renewal

. (failure to report will be failure to renew.) 2. Require all ultralight operators, under the terms of the exemption, to be members of the exemption holding organization. 3. All horizontal Stabilizes installed under this exemption must meet either accepted design criteria or be tested for appropriate stability results as defined in Addendum 4. Operators using the exemption fo r horizontal stabilizers must report to the exemption holders as shown in Addendum 4.Page 4 of 14 **PUBLIC INTEREST ISSUES** Ref 14CFR11.81(d,e)

The database created by this exemption will be sufficient to develop a baseline of research information for the FAA to make a reasonable decision on allowing future ultralight vehicle safety equipment. The resulting safety benefits of the requested changes are expected to be immediate reductions in personal injury and property damage. This exemption process allows for a ful l and appropriate assessment of the potential improvements to ultralight vehicle safety, and provides a means of documenting those that are justified. Example s provided in Appendix A show some of the safety issues that must be addressed. Key among these issues has been propeller incursions resulting form having to hand prop or stand ing on the seat to spin up the rotor blades by pushing them by hand

. Can you justify forcing a pilot to stand on the seat with the engine running just 3 feet away and trying t o spin up the blades to roughly 60

– 90 RPM’s ? In addition, Pilot Induced Oscillations (PIO) have been a horrible plague from the early days. These issue s have been made worse by the instructor limitations imposed by the FAA Rotorcraft Directorate. By not allowing Special Light Sport Aircraft (SLSA) that are gyroplanes, the Directorate has prevented possible instruction for most of the gyroplane community. Therefore, training o r operating around a running engine/propeller or standing on the pilot seat while the engine is running to hand spin up the blades without pre

- rotors, is not available. The Directorate decision further impacts the community in that Ultralight Gyroplanes have no where to g o to add these safety devices. There are no SLSA gyro plane s, therefore there are no Experimental Light Sport Aircraft (ELSA) gyros . In fixed wing , an owner might go Experimental Am ateur Built (AB) however the gyroplane is unique in that you buy the rotor, the engine, the prop, the wheels, the seat and there is little else to consider. This make s it very difficult to build 51% even from the check list of Order 8130 .2 G. An owner knows how to be sa fer, but can not do so legally. Each owner operating an ultralight vehicle under the terms of this exemption will present their copies of this exemption and the Technical Standards Committee Finding Sheet to the FAA, for inspection upon request. The FAA, and ASC reserve the right to terminate any program participant who fails to comply with the terms of this exe mpt ion. Failure to submit annual reports to the exemption holder is cause for termination from the program. Upon termination, the individual would be required to comply with the FAR 103 ultralight vehicle weight limitations. After completion of this 2

- year study, or after appropriate extensions, ASC would recommend to the FAA appropriate recommendations based on the study results.

**DESCRIPTION OF THE RELIEF SOUGHT** Ref 14CFR11.81(f) ASC is seeking a 2

- ye ar exemption for the purpose of conducting research o n the viability of allowing additional ultralight vehicle safet y equipment that is currentl y be yond the scope of 14CFR 103.1(e)(1). This exemption would allow ASC to approve and allow ultralight vehicle manufacturers and current ultralight vehicle owners to have g yro plane pre - rotator /starter sy stems , g yro plane horizontal stabilizer sy stems

. **SUMMARY** Ref 14CFR11.81(f)Page 5 of 14

Petition for exemption from Federal Aviation Regulation 14CFR 103.1e(1) to permit members of the Aero Sports Connection (ASC) to conduct fl ight activities in gy roplane ultralight vehicles that include demonstrated necessary safety equipment that is outside the current scope of part 103.1e(1). ASC is not seeking use of this exemption outside the United States. Ref 14CFR11.81(h) ASC further request s that consideration be given to non

- publication of the summary of this petition based on 14CFR 11. 38(b) and 14CFR 11.87 which recognizes the time critical nature of this request and the similarity to changes made for floatation devices under the training exemptions.

Sincerel y, 

## James Stephenson /s// James Stephenson Aero Sports Connection, Inc.

Enclosures: Addendum 1 Technical Standards Addendum 2 Technical Standards Committee Membership Standards Addendum 3 Technical Standards Committee Finding Sheet Addendum 4 Requirements on Horizontal Stabilizer Design or Test Appendix A Safety

I ssues Examples for Ultralight Gy roplanesPage 6 of 14 Addendum 1 **TECHNICAL STANDARDS** ASC, requests this exemption from FAR 103.1(e)(1) to allow me mbers the ability to conduct FAR 103 ultralight vehicle operations in safer vehicles. As part of this exemption, ASC will establish Technical Standards Committees as described in FAA Advisory Circular (AC) 103

- 7, paragraph 22 through 24. These committee s will:

1. Make acceptable findings based on individual gyroplanes. The aircraft must be weighed without the pre

- rotator/starter and horizontal stabilizer installed and in that configuration they must be less than 254 lb empty weight. 2. The equipment is th en re - installed and the final aircraft weight recorded. 3. The finding must be signed by the committee and submitted to the exemption holder with photographs both at the time of empty weighing without pre

rotator/starter

/stabilizer and after installation. 4. Upo n finding of compliance, the exemption holder will issue a copy of the finding form and this exemption to the operator of each ultralight vehicle covered by this exemption. The operator must have in his/her possession a copy of the compliance finding and this exemption when flying. The Ultralight Technical Standards Committee will use the following Technical Standards Committee Finding sheet to make all the above determinations. Minimum standards for Technical Standards Committee member management are as defined in the attached addendum. These standards include requirements for committee member qualification, training, review and control. Critical review processes are also defined.Page 7 of 14 Addendum 2 **Technical Standards Committee Membership Standar ds** 
The following represents the minimum standards for Technical Standards Committee membership. The key

areas of concern are: qualification, training, review and correction. Qualification: Each exemption holder shall have written procedures in force a ssuring the following minimum qualifications for membership as a technical standards committee member: 1) Minimum age of 21 ye ars 2) Able to read, speak and understand English 3) Membership in good standing in the exemption holders organization 4) Current and valid Pi lot, Certified Flight Instructor or A&P Training Each exemption holder shall have written procedures outlining vehicle evaluation and assessment. Each technical committee member shall become familiar with the written procedures. Review Each exemption holder shall have written procedures in force that perform office reviews of each technical committee decision and evaluate the continued appropriate operation of each technical committee member. An y inconsistencies of operation are to be reviewed under the “correction procedures”. No committee member may serve on a committee reviewing an ultralight while concerns are under review under the “correction procedures”. Correction Procedures Each exemption holder shall have written procedures in force to rev iew and evaluate any inconsistencies in operation or written complaints against technical standards committee members. This procedure shall have as a minimum: 1) A complaint reporting s ystem requiring a written and signed complaint to initiate a peer review. (An office complaint will result from inconsistencies documented on technical committee decision reviews.) 2) A notification in writing to the technical committee member both removing the member from service and informing the member of the allegation and in itiation of investigation. 3) The collection of data on the matter including witness and documentation evidence. 4) A written request to the technical committee member presenting all of the evidence and asking for a response on all matters involved. Failure to respond shall be sufficient cause for permanent removal of the member from the technical committee s ys tem.Page 8 of 14

5) A peer review b y three respected members of the community who are to remain anony mous. These members must decide if the case is to be dropped, if th e member is to be removed from service, or if additional investigation is needed. In an y case, where it is found that an aircraft review has been mishandled, and for which a member is removed from service, all other aircraft for which that member has serv ed as a technical committee member shall be required to submit for re

- review in order to remain under the exemption. 6) Other sanctions may

be imposed by

the exemption holder on technical committee members who are found to have failed in their duty. Appeal p rocedures shall allow for a one

- time return for review. This appeal may onl y be initiated by

formal written request from the sanctioned technical committee member. A second and separate peer review committee shall perform this review. Findings of the se cond committee are final. Id entification Exemption holders who follow procedures meeting the above requirements may select and recognize technical standards committee members. These members are to be identified in such a way that their authorit y t o si t on a technical committee is shown in writing and verifiable b y phone through the exemption holder’s database.Page 9 of 14 Addendum 3 

### Technical Standards Committee Finding Sheet (Instructions: Complete all blanks, insert N/A in blanks not applicable to this part icular review, check off or enter the appropriate data in the applicable blanks) Issued to: ________________________________ Ultralight Make/Model: ___________________ Address: _________________________________ Serial Number: _________________________

_________________________________ Registration Number: _____________________

_________________________________ Pilot Registration Number: ________________ Engine Make/Model: _______________________ Propeller Make/Model: ____________________ Gyro plane make and model __________ Rotor Blade Make/Model: _________________

**- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **-** Total Empty Weight (Pre

- rotator/starter and horizontal stabilizer removed) __________________

- Exclusion for parachute system weight (24 lbs)......................______________

( ) hand

- deployed ( ) ballistically deployed ( ) installed and operational

- Fuel on board at weighing (6 lbs per gallon)........................_______________ TO TAL WEIGHT ALLOWANCES

_______________ NET EMPTY WEIGHT (minus weight allowances and fuel) (less than 254)

___________ Photo of empty weight configuration attached. ( ) Photo of aircraft after re

- installation of Pre

- rotator/started and horizontal stabilizer. ( )Total weight _____ Accepted design of horizontal stabilizer ________________, or Tests plans and expected time of results. (Se e addendum 4) ________________ (sign by owner) Fuel tank evaluation (maximum 5 gallons) _____________________ gallons Based on the vehicle review, this committee finds the specified vehicle, as equipped, to be compliant with FAR 103 and its exemp tions as authorized under exemption # ________________ To any official reviewer: Verification of compliance must be on record with the noted exemption holder. Please call the listed exemption holder for formal verification: Exemption # _________, Aero Sp orts Connection 269

- 781

- 4021

**- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **- -**  **-** Issued by: Ultralight Technical Standards Committee:

__________________

_______ _________________________ ________________________ Signature Signature Signature Address __________________ Address __________________ Address __________________ City/St/ Zip City/St/ Zip City/St/ Zip Phone _____________________ Phone _____________________ Phone _____________________

_________________________ _________________________ ________________________ Printed name & Organization Printed name & Organization Printed name & Organization DATE OF ISSUANCE OF THIS DOCUMENT : ________________

_ The exemption and this document may be renewed. Such renewal must be appropriately documented.Page 10 of 14

Addendum 4 

### Requirements on Horizontal Stabilizer Design or Test
Please note that the technical committee my release the report once the owner has committed to completing the test program. There are only two ways this exemption may be used for adding a horizontal stabilizer. That is the horizontal stabilizer must be either one of the accepted configurations as listed in section 1. This group will grow as additional configurations are verified and reported to the exemption holder. Or the horizontal stabilizer must be tested. Section 2 shows the tests necessary to show that a different configuration is acceptable. These tests are designed to provide the safest possible test approach to verifying acceptable stab ility. In either case, the operator and technical committee must provide either the accepted design used or the new configuration and the plan to test. Note, manufacturers may test their designs and have them added to the accept list. This will make it easier for new owners. Section 1 Accepted configuration: A) Gyro Bee, low stabilizer, b elow prop blast, between x a nd y sq feet area. B)
Section 2 Testing a design for stability. The following stabilit y data is based on ASTM F2353

- 11, additional data on reference labels and methods can be found in the standard. See www.Astm.or g . 4.5 Stability : 4.5.1 General : 4.5.1.1 The gy

roplane stability

characteristics must satisfy all of the stability

criteria of 4.5. 4.5.1.2 The gy

roplane must be able to be flown without undue piloting skill, alertness, or strength in an y normal maneuv er for a period of time as long as that expected in normal operation. 4.5.1.3 There must be no tendency for the gy

roplane to increase rapidl y the turn rate, stick fixed, during a turn with normal accelerations of up to 1.5 g at all allowable power settings

. 4.5.2 Static Longitudinal Stability : 4.5.2.1 Static Longitudinal Power Stability : (1 ) At the cyclic stick position established in level flight at MPRS(minimum power required airspeed ) at MPRS power, a change in power from MPRS power to full power shall not result in a change in a stead y state trimmed airspeed of more than 10 % from MPRS. (2 ) At the cyclic stick position established in level flight at MPRS at MPRS power, a change in power from MPRS power to idle power shall not result in a change in a ste ady state trimmed airspeed of more than 10 % from MPRS. (3 ) At the cyclic stick position established in level flight at MPRS at MPRS power, a change in power from MPRS power to engine off shall not result in a change in a steady state trimmed airspeed of m ore than 20 % from MPRS. 4.5.3 Static Longitudinal Airspeed Stability : 4.5.3.1 The longitudinal control must be such that, with constant engine power, an aft force and movement of the cyclic control is necessary to achieve an airspeed less than any availab le trim airspeed.Page 11 of 14

4.5.3.2 The longitudinal control must be such that, with constant engine power, a forward force and movement of the control is necessary to achieve an airspeed greater than any available trim airspeed. 4.5.3.3 The control force gradient must not reverse during any progressive application of control movement at airspeeds greater than V MI N up to VNE

. 4.5.3.4 Conditions

— Static longitudinal airspeed stability must be met at the following power and trimmed airspeed conditions: (1 ) Stead y altitu de at MPRS, (2 ) Full power at the lesser of VH or of VNE , (3 ) Engine idle at MPRS, and (4 ) Engine idle at 80 % VNE

. 4.5.4 Static Longitudinal Maneuvering (G

- Load) Stability : 4.5.4.1 The pitch control forces during turns or load factor maneuvers greater tha n 1.0 g must be such that an increase in load factor is associated with an increase in aft pilot control force, and a decrease in load factor is associated with a decrease in aft pilot control force. 4.5.4.2 Conditions

— Static longitudinal maneuvering stabi lity must be met at the following power and trimmed airspeed conditions: (1 ) Stead y altitude at MPRS, (2 ) Full power at the lesser of VH or of VNE , (3 ) Engine idle at MPRS, and (4 ) Engine idle at 80 % VNE

. 4.5.5 Lateral and Directional Stability : 4.5.5.1 F ollowing an initial y aw disturbance, with the y aw controls fixed or free and other controls held fixed, the gyroplane shall tend to correct automatically for disturbance in yaw within three cycles. 4.5.5.2 The directional and lateral stability should be su fficient to prevent dangerous flight conditions following abrupt pedal displacements. 4.5.5.3 Positive directional (y aw) static stability shall be demonstrated by the requirement for increasing rudder pedal force and displacement with increasing sideslip. 4.5.5.4 No lateral or directional oscillations with periods less than 5 s shall be exhibited with primary cyclic controls fixed, and with primary cy clic controls free. 4.5.5.5 Conditions

—Lateral and directional stability must be met at the following power and trimmed airspeed conditions: (1 ) Stead y altitude at MPRS, (2 ) Full power at the lesser of VH or of VNE , (3 ) Engine idle at MPRS, and (4 ) Engine idle at 80 % VNE

. 4.5.6 Dynamic Longitudinal Stability : 4.5.6.1 The gy

roplane under smooth air conditions mu st exhibit no dangerous behavior at an y speed between MPRS and VNE with primary cyclic controls fixed, and with primary cyclic controls free. 4.5.6.2 No longitudinal oscillations with periods less than 5 s shall be exhibited with primary cyclic controls fi xed, and with primary cyclic controls free. 4.5.6.3 Any

excitable longitudinal oscillations with periods longer than 5 s do not diverge with primary cyclic controls fixed, and with primary cy clic controls free. 4.5.6.4 Conditions

—Dy

namic stability

must be met at the following power and trimmed airspeed conditions: (1 ) Stead y altitude at MPRS, (2 ) Full power at the lesser of VH or of VNE ,Page 12 of 14

(3 ) Engine idle at MPRS, and (4 ) Engine idle at 80 % VNE

. Each of the above requirements must be verified by test and r eported to ASC. Designs completing this verification will be added to the accept ed design group for future use by new applicants.Page 13 of 14

Appendix A to Gy

ro plane Exemption Request A survey was completed to try

to quantify

the issues of this request. Although ultralights are very difficult to survey , our contacts and national coverage has helped gather data. This data covers 153 respondents which represents somewhere between 4% and 10% of the currentl y hard to measure communit y. Of those respondents, 44 repo rted having known of accidents. Of the reported accidents, there were 10 deaths which conservative estimating would be 100 deaths for the whole community . Being ultralights, many of these would not be reported or would not be identifiable as ultralight g yroplanes. Pilot Induced Oscillation (PI O) has long been a major issue. The results of the survey affirm that with 5 PI O related deaths. Prerotator accidents where not as high in deaths but were higher in count at 6 accidents. The survey s recommendati on emphasize these concerns ranking Horizontal Stabilizer as a 4.83 out of 6 for overall concern. Adequate Prerotator ranked 4.50 out of 6. Wheel Brakes ranked 3.27 out of 6. Rotor Brake Sy stem ranked 2.93 out of 6. Electric S tart ranked 2.82 out of 6. Small Four Stroke Engine ranked 2.66 out of 6. See the chart below.



## Sur **vey Reco**  **mmen da**  **ti ons** 

0 0. 5 1 1. 5 2 2. 5 3 3. 5 4 4. 5 5 **Ho ri**  **zo nt**  **al St**  **ab ilize**  **r Ad**  **eq ua**  **te p**  **re rota**  **to r**  **Wh eel**  **B re**  **ak s**  **Ro to**  **r Bl**  **ad e**  **Bre ak**  **Sy st** **em El**  **ec tri**  **c St**  **ar t**  **Sma ll F**  **our St**  **roke En**  **gi ne** 

**Ra nkng**  **/6 .0** Page 14 of 14

Savings Assessment Conservatively

based on the respondents of this survey , it is estimated that there are more than 1500 potential operators needing this relief. Based on A SC’s earlier demonstrated ability with the training exemption 6080, it is estimated that we should be able to service at least half of the community , while we will never reach every one, just as Sport Pilot hasn’t. The operating cost of the exemption will be held down and born b y the users. ASC has extensive experience to this area, at one time handling 2700 active two place instructors with an office of one staff person. Cost to the FAA will only be that of coordination, review and monitoring, with most of the monitoring and reporting on ASCs shoulders. Estimated FAA costs of $20,000. Exemption Savings Using the figures f

rom the Sport Pilot cost trades, Deaths saved represented a $27M savings. Given we can onl y reach half of the communit y and even wi th changes there will be some deaths, the total of 100 deaths may be reduced by

25 saving $657M of community impact. Clearly this exemption request should be approved. The real work is being handled by the community . New testing of efficacy of horizonta l stabilizers will be done. Lives will be saved. Jim Stephenson President/CEO ASC Inc.