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July 26, 2012

To: U.S. Department of Transportation

Docket Management System

400 7th Street, S.W. Room PL 401

Washington, DC 20591-0001

PETITION FOR EXEMPTION

FROM FEDERAL AVIATION REGULATION 14CFR 103.1e(1) 

TO PERMIT MEMBERS OF THE AERO SPORTS CONNECTION, TO CONDUCT FLIGHT 

ACTIVITIES IN GYROPLANE ULTRALIGHT VEHICLES THAT INCLUDE 

DEMONSTRATED NECESSARY SAFETY EQUIPMENT THAT IS OUTSIDE THE 

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

Petitioner: Aero Sports Connection, Inc. (ASC)

James G. Stephenson

231 SW Bonanza Gln

Lake City, FL 32025-2148

Phone 269-209-1466

Fax 386-269-0469

Ref 14CFR11.81(a)
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PETITION SUMMARY

Petition for exemption from Federal Aviation Regulation 14CFR 103.1e(1) to permit members of the 

Aero Sports Connection (ASC) to conduct flight activities in gyroplane ultralight vehicles that 

include demonstrated necessary safety equipment that is outside the current scope of 14CFR

103.1e(1), for the purpose of permitting ASC to create the Ultralight Vehicle Safety 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 

and 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 safety were sacrificed in consideration of reducing weight to 

make 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 in 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 

Gyroplane pre-rotator systems/starters and Gyroplane horizontal stabilizer systems. The addition 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 issues are provided in 

appendix A. These examples are not all inclusive yet show over 100 fatalities and 400 major 

injuries that could clearly 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 exemption. ASC and the FAA will use data collected to establish an ultralight vehicle 

safety equipment baseline for possible rulemaking changes to 14CFR 103 or related documentation.

Under the two-year study program ASC will:

1. Require all owners of ultralight vehicles operating under the terms of this exemption to 

submit an annual safety report to the 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 safety review. 
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3. Develop a listing of horizontal stabilizers which meet ASTM F2353-11 stability requirements 

thereby augmenting the knowledge base for both operators and manufacturers. See the 

horizontal stabilizer test requirements of Addendum 4.

ASC firmly believes that the use of these additional safety devices will result in greater 

public safety. We feel, by approving this petition, the FAA will be taking a step toward 

promoting safer ultralight vehicle flight and ground safety. ASC is requesting this research 

exemption be granted for a period of 2 years. 

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 brings together aviation enthusiasts, 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 

members and the general public with access to the world of flight. 

As such, ASC feels 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 increased 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 recognizes 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 for horizontal stabilizers must report to the exemption holders as shown 

in Addendum 4.
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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 full and appropriate 

assessment of the potential improvements to ultralight vehicle safety, and provides a means of 

documenting those that are justified.

Examples 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 standing 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 to 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 issues 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 or 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 go to add these safety devices. There are no SLSA gyroplanes, therefore there are no 

Experimental Light Sport Aircraft (ELSA) gyros. In fixed wing, an owner might go Experimental 

Amateur 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 makes it very difficult to build 51% even from 

the check list of Order 8130.2 G. An owner knows how to be safer, 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 exemption. 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-year exemption for the purpose of conducting research on the 

viability of allowing additional ultralight vehicle safety equipment that is currently beyond 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 gyroplane pre-rotator/starter

systems, gyroplane horizontal stabilizer systems .

SUMMARY Ref 14CFR11.81(f)
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Petition for exemption from Federal Aviation Regulation 14CFR 103.1e(1) to permit members of 

the Aero Sports Connection (ASC) to conduct flight activities in gyroplane 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 requests that consideration be given to non-publication of the summary of 

this petition based on 14CFR11.38(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.

Sincerely,

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 Issues Examples for Ultralight Gyroplanes
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Addendum 1

TECHNICAL STANDARDS

ASC, requests this exemption from FAR 103.1(e)(1) to allow members 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 committees 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 then 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 prerotator/starter/stabilizer and after installation.

4. Upon 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. 
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Addendum 2

Technical Standards Committee Membership Standards

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 assuring the following minimum 

qualifications for membership as a technical standards committee member:

1) Minimum age of 21 years

2) Able to read, speak and understand English

3) Membership in good standing in the exemption holders organization

4) Current and valid Pilot, 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. Any 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 review 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 system 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 initiation 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 system.
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5) A peer review by three respected members of the community who are to remain 

anonymous. These members must decide if the case is to be dropped, if the member is to 

be removed from service, or if additional investigation is needed. In any 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 served 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 procedures shall allow for a one-time return for review. This appeal may only 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 second committee 

are final. 

Identification

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 authority to sit on a technical committee is shown in writing and verifiable by 

phone through the exemption holder’s database.
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Addendum 3

Technical Standards Committee Finding Sheet

(Instructions: Complete all blanks, insert N/A in blanks not applicable to this particular 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: ____________________

Gyroplane 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)........................_______________

TOTAL 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. (See 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 exemptions 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 Sports 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.
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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 stability. 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) GyroBee, low stabilizer, below prop blast, between x and y sq feet area.

B)

Section 2 Testing a design for stability. 

The following stability data is based on ASTM F2353-11, additional data on reference labels and 

methods can be found in the standard. See www.Astm.org . 

4.5 Stability:

4.5.1 General:

4.5.1.1 The gyroplane stability characteristics must satisfy all of the stability criteria of 4.5.

4.5.1.2 The gyroplane must be able to be flown without undue piloting skill, alertness, or 

strength in any normal maneuver for a period of time as long as that expected in normal 

operation.

4.5.1.3 There must be no tendency for the gyroplane to increase rapidly 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 steady 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 steady 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 more 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 available trim 

airspeed.
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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 VMIN up to VNE.

4.5.3.4 Conditions—Static longitudinal airspeed stability must be met at the following power and 

trimmed airspeed conditions:

(1) Steady 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.

4.5.4 Static Longitudinal Maneuvering (G-Load) Stability:

4.5.4.1 The pitch control forces during turns or load factor maneuvers greater than 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 stability must be met at the following 

power and trimmed airspeed conditions:

(1) Steady 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 Following an initial yaw disturbance, with the yaw 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 sufficient to prevent dangerous flight 

conditions following abrupt pedal displacements.

4.5.5.3 Positive directional (yaw) 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 cyclic controls free.

4.5.5.5 Conditions—Lateral and directional stability must be met at the following power and 

trimmed airspeed conditions:

(1) Steady 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 gyroplane under smooth air conditions must exhibit no dangerous behavior at any 

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 fixed, 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 cyclic controls free.

4.5.6.4 Conditions—Dynamic stability must be met at the following power and trimmed airspeed 

conditions:

(1) Steady altitude at MPRS,

(2) Full power at the lesser of VH or of VNE,
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(3) Engine idle at MPRS, and

(4) Engine idle at 80 % VNE.

Each of the above requirements must be verified by test and reported to ASC. Designs 

completing this verification will be added to the accepted design group for future use by new 

applicants.
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Appendix A to Gyroplane 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 currently hard 

to measure community. Of those respondents, 44 reported 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 gyroplanes.

Pilot Induced Oscillation (PIO) has long been a major issue. The results of the survey affirm that 

with 5 PIO related deaths. 

Prerotator accidents where not as high in deaths but were higher in count at 6 accidents.

The surveys recommendation 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 System ranked 2.93 out of 6. Electric Start ranked 2.82 out of 6. 

Small Four Stroke Engine ranked 2.66 out of 6. See the chart below.

Survey Recommendations

0 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5

Horizontal Stabilizer

Adequate prerotator

Wheel Breaks

Rotor Blade Break

System

Electric Start

Small Four Stroke

Engine

Rankng /6.0
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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 ASC’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 everyone, just as Sport Pilot hasn’t.

The operating cost of the exemption will be held down and born by 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 from the Sport Pilot cost trades, Deaths saved represented a $27M savings. 

Given we can only reach half of the community and even with 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 horizontal stabilizers will be done. Lives will be saved. 

Jim Stephenson

President/CEO

ASC Inc.