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 SP ELSA)

Sec. 11.81

A. Contact Information:

Indigenous Peoples 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 Re gulation s (CFR) Part 21, § 21.191(i) Operating a light

- sport aircraft that: (2)

- Has been assembled

– (i) F rom a n aircraft kit for which the applicant can provide the information required by § 21.193(e) ; and (ii) I n accordance with manufacturer’s assembly inst ructions that meet an applicable consensus standard ; or (3)

- Has been previously issued a special airworthiness certificate in the light

sport category under § 21.190.

The exemption sought is for operation of experimental light

- sport aircraft (ELSA) w ith additional weight allowance for a powered parachute (PPC) intended for both flight operations and ope ration on public roadways, which is similar to the weight

allowance for light

- sport aircraft (LSA) intended for operation on water.

A similar exempti on

- Exemption No. 10299, Docket No. FAA

- 2010

- 1221 has been granted to ITEC for the special category light

- sport aircraft ( SLSA ) version of the

Maverick PPC Model No. Maverick SP, serial numbers MS9001

- MS9999. This petition seeks the same exemption from a maximum takeoff weight (MTOW) of 1,320 pounds (600 kilograms) to allow an additional 110 pounds, the same as an LSA intended for operation on water , for applicability to ELSA Maverick SP PPC’s

.

A roadable PPC has similar weight penalties to an LSA int ended for operation 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

ex emption from the current restriction of a maximum take

- off weight (MTOW) of1,320 pounds (600 kilograms) for aircraft not intended for operation on water. The exemption is requested to allow the “Maverick SP ” PPC ELSA design to include structures, systems, and instruments necessary for it to safely operate both in the air and on the ground just as has been granted for the SLSA version of the ITEC

Maverick SP model

. In order to meet these design requirements and still maintain a

suitable useful load for fli ght operations, the Maverick SP PPC ELSA 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 : (1) ITEC to issue a statement of compliance (FAA Form 8 130

- 15) for each ITEC

Maverick SP PPC E LSA “kit” in accordance with § 21.193(e), for operation at the same weight prescribed by 14 CFR Part 1, § 1.1 for LSA intended for operation

on water. (2) A ny ITEC Maverick SP PPC SLSA to be converted to ELSA in acco rdance with § 21.191(i)(3)

When this petitioner, originally requested an Exemption for the ITEC Maverick (FAA Regulatory Docket No. FAA

- 2010

- 1221), we had the understanding that that request would also include any Maverick SP PPC ELSA. That not being the case, and through no fault of the Agency, the petitioners ability to deliver ELSA models to the marketplace has been delayed, creating a economic hardship for continued manufacturing. The petitioner, therefore requests expeditious handling of this petiti on.

B. Petition for exemption from:

14 CFR part 21, § 21.191 (i) Operating light

- sport aircraft. Operating a light

- sport aircraft that

- (2) Has been assembled

- (i) From an aircraft kit for which the applicant can provide the information required by §21. 193 (e); and (ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard; or (3) Has been previously issued a special airworthiness certificate in the light

- sport category under §21.190

.

C. Extent of and reason fo r relief:

Relief from the reasonable ELSA 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 askin g for a 110 lb (50 Kg) exemption that would allow an increase in the gross operating weight for a ‘flyable and drivable’ Maverick SP ELSA, from the standard ELSA gross weight of 1320 lbs, to 1430 lbs, the allowable weight for an

LSA intended for use on wat er. It should be noted that ELSA intended for use on water receive an increase in weight in spite of the incontrovertible fact that operating an aircraft from water is a more complex undertaking than operating a light sportaircraft from land and in spite of the fact that an accident on water includes dangers not associated with operations from land bases where the conditions of the landing surface are more stable. It is evident that any additional skill required of a pilot of an

ELSA intended for use on water is only associated to a very insignificant extent with the increase in weight and is primarily due to the added complexity and pilot skill necessary to operate any aircraft to and from water. Landing and taking off from water requires additional cont rols, special skills and very well developed understanding of wind direction, wave height and glassy water conditions and as well as obstructions in the water including but not limited to floating debris, swimmers and rapidly moving and highly maneuverabl e boats.

Every vehicle is a compromise. Some planes are extremely fast but require very

l ong runways. Others have STOL benefits, but give up cruise speed. Others with complex wings can take off short and fly fast but are extremely expensive. The

Maver ick SP SLSA 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. This reality is just as true for the Maverick SP ELSA

as it is for th e Maverick SP SLSA.

Ther e 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 v ehicle

manufacturer to meet.

States have developed numerous exemptions from the FMVSS to allow the development and sale of vehicles designed for specialty uses. The "Kit Car" exemption is one good example of such an exemption. In Florida and other sta tes there are other exemptions including an exemption called "Assembled from Parts". This exemption allows parts from damaged vehicles to be used to rehabilitate repairable vehicles.

The Maverick SP was designed to be safe on public roads even at highw ay speeds. But it was also 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 SP ; but it would also be exorbitantly expensive and extremely heavy.

Attempting to meet all FMVSS is beyond the realm of feasibility for a road capab le Powered Parachute, privately

- funded, and manufactured in small quantities.

We have chosen to design this fi rst practical multi

- medium Powered 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 r ealistic option is to license the Maverick

SP 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.

The approximate weight necessary to build a Powered Parachute that includes: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

ro bust 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, speedometer, windshield clearing system

– (Add 6 to 10 lbs)

4. A heavy duty braking system on all wheel s

– (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 dur ing a collision

– (Add 35 lbs) will add between 250 and 280 lbs to a roadable Powered Parachute if great care is given to cutting the weight of these extra systems and if safety concerns are addressed with severe emphasis given to reducing weight to a bare

minimum. 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 a dditional 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 support the reasons for limiting LSA gross operating weights a nd believe that we and others 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 ro bust, 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 half hours of flight, plus reserves (14 gallons = 84 lbs) the absolute minimum gross weight necessary to

make the Maverick SP practical without sacrificing safety, is 1430 lbs. To make this possible we absolutely need a minimum 110 to 150 lb gross weight exemption.

We are asking for 110 lbs but would like to enco urage 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 SP LSA Powered Parachute which 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 interest and benefit:

1. The Maverick SP can be flown safely by anyone with experience driving an automatic transmission car and is willing to invest the time necessary to gettwelve hours of instruction required to acquire an FAA Sport Pilot License with a

Powered Parachute endorsement.

2. The Maverick SP is a fully licensable roadworthy vehicle (also off

- road capable).

3. The Maverick SP is capable of safe flight.

4. The Maverick SP can be converted from driving mode to flying mode and back in just a matter of a few minutes.

5. The Maverick SP is fuel efficient, burning a pproximately 5 gph in the air and getting up to 30 + miles per gallon on the ground.

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

7. The Maverick SP uses regular automobile fuel.

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

Maverick SP

.

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

10. The Maverick SP can land and take off in about two hundred feet (depe nding on take off weight).

11. Above all else, it can be operated safely 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 is 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 SP needs a small but critical exemption from the current standard gross weight limitations 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 this congestion has

als o 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 i s not likely to come from our public sector

because the cost of adding roadways in our most congested areas is beyond the ability of our debt ridden economy to support. Government entities have already

made all reasonable efforts from car

- pooling initiati ves to multiple occupant lanes and sequenced traffic lights, limited access highways and novel concepts such as traffic circles to alleviate congestion on our highways. Industries have already triedstaggered work start times, work at home concepts, and n ew 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 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 system, is designing an affordable, safe and user

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

The only obstacle to the Maverick SP being the first practical vehicle with the capability of combining highways and skyways is the current weight restrictions 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 consideration 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 require a stiffened airframe and requires a floating fuselage or pontoons, which add weight. Much less additional

stru cture 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 air)

and the safet y 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 reversing gear, wi ndshield 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 Roadable Aircraft’ that has even a small potential for alleviating congested roads and p ublic 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 SP in response to arti cles 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 and on the

CNN webb site on October 27 2010, Sport Aviation in November 2010, and numerous newspapers, radio stations and television programs around the country.This unsolicited interest in the Maverick SP has prompted a flurry of inquiries that reveal the broad applic ation possibilities for the Maverick SP as soon as it is available to the public. Potential customers are interested in using the Maverick SP in many ways including the following uses:

o Border patrol

o Pipeline patrol

o Aerial surveillance

o Disaster evaluatio n (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 Trans portation 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 critical 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 Iraq 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 co mmon 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 SP 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 SP E LSA Powered 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 amphibiou s LSA I have studied has asufficient useful load that it could function without the additional 110 pound gross weight allowance given automatically to amphibious LSA’s. But, it would do so only at the expense of giving up a second passenger or by compromi sing safety. The same reality is even more applicable to a roadable Powered Parachute such as the

Maverick SP

.

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 manner 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

wh ich capability the Maverick SP 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.

We also woul d suggest that allowing a weight exemption for a road legal LSA Powered 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 co ntrol accidents from unintentional flight into IMC conditions than are other aircraft. These inherent safety characteristics of Powered

Parachutes make the Maverick SP a prime candidate to explore multi

- medium operations and make it a safe candidate for o peration by low time Sport Pilots

It makes sense to limit LSA’s maximum stall speed from a safety standpoint. The lower the speed, the lower the momentum and the lesser the likelihood of injury to aircraft and occupants in case of an accident. It also m akes obvious sense to limit the conditions in which 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 the maximum gross weight of LSA’s, is 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 SP , however, does

not create exces sive 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 SP E LSA Powered Parachute, the modest weight increase is specifically sought to allow an increase in safety 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 sp ecific reason for the exemption sought for the Maverick SP ELSA

.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 lice nsing requirements.

Granting a modest exemption to the gross takeoff weight of the Maverick SP will definitely help give this innovative new multi

- medium aircraft a chance to

succeed in the competitive marketplace, will help rejuvenate the flagging LSA

Po wered Parachute industry and will allow all of this to be accomplished with a high degree of safety.

It is understandable that there is a tendency to attribute an additional level of risk to Experimental aircraft. The Experimental category allows own ers of experimental aircraft to make improvements to their aircraft. It should be noted, however, that any and all modifications to any experimental aircraft are strictly controlled by the FAA under long established guidelines. These guidelines, refined over the years, insure that changes and improvements to any Ma verick SP ELSA would either be insignificant with respect to the general safety and integrity of the Maverick SP (which would nevertheless require proper documentation) or that the change, if

si gnificant, would require not only documentation but would also require a review and inspection by the FAA and would allow for the issuance of appropriate additional operating limitations.

The requirements for modification of a 1430 lb MTOW Maverick SP E LSA would be the same as they are for 1430 lb ELSA intended for use on water. The protections that safeguard all modifications to the 1430 lb ELSA intended for use on water are the same protections that would safeguard modifications

to Maverick SP ELSA.

There is a close similarity between the additional structural demands of an aircraft

intended for use on water and the additional demands of an aircraft intended for use on public roads. Operations of both types of aircraft subject the respective aircraft to punishments resulting from operating on incompressible water and land that are not experienced by either when operating in compressible air. There are three significant advantages of a Maverick SP ELSA operating on public roads over a typical ELSA int ended for use on water, that should be noted:

1. Most aircraft intended for use on water were modified for operation on water, not specifically designed for the additional punishment involved in landing and taking off

on water. The Maverick SP was speci fically designed for operation on public roads as well as for flight.

2. In the case of aircraft "intended for use on water", the relatively fragile structures designed to carry loads in the ai r are neither stowed nor braced while being subjected to j arring operations on incompressible water. The Maverick SP

, however, was designed so that all flight structures are carefully stowed when the

Maverick SP is being used on roads. The wing and all its associated flight

necessary structures are protected ag ainst jarring, abrasion , and impacts from other vehicles and obstructions when not flying.

3. Non

- Roadable ELSA aircraft used on land generally have only rudimentary

shock absor p tion undercarriages. When the vast majority of these aircraft are

modified for use on water which is as inco m pressible as asphalt, concrete andgrass

- over

- dirt runways and which can produce jarring waves in even modest

breezes

- when they are converted for use on water, most of the modifications

remove what limited shock absorpt ive structures were designed into the original

structure. The Maverick SP , by comparison, has a sophisticated and extremely capable suspension system which goes far beyond any reasonable requirement it would generally be called to meet in landing on a typ ical runway.

Not only is the Maverick SP more specifically designed for use in its 'second medium' than are most Light Sport Aircraft modified for use on water but the Maverick SP controls for air and road operation are so integrated that there is only a very minor difference in operating a Maverick SP on roads and in the air. The steering wheel is used for directional control on both the highway and the skyway.

The standard automobile

- type accelerator is used to control engine power on the ground and in the air. The brake is the only ground control that has no air function.

In most Light Sport Aircraft intended for use on water the propeller creates thrust whenever the engine is running. On the water, the aircraft cannot park away from

obstacles. It must pull right into the beach or right alongside a dock or up to a buoy. There are no brakes. The engine must be shut down before the destination is reached. If the engine is shut down too late, the fragile flotation structure can easily be damage d. Shut down the engine too soon and you may be drifting away from the intended parking spot with the wind and current affecting the fragile aircraft in simultaneously different manners while the boat captain

- pilot tries to figure out whether to get back in and start the engine or paddle etc.

Operating an aircraft on water requires the use of water rudders which must be retracted prior to most takeoffs. A sea

- plane rating even requires an understanding of 'sailing' to back up down

- wind in which case th e controls work opposite to the standard forward response.

Full utilization of the Maverick SP does require the operator to know how to drive a typical automatic transmission vehicle when on public roads. This is a skill, however, which all but a very rare exception of operator would already know how to do proficiently and one that already requires a driver to undergo significant amount of training far beyond the limited hours required to obtain a sea

- plane rating.

In summary, when given proper rea l

- life consideration it seems reasonable to conclude that flying a Maverick SP roadable powered parachute requires significantly less skill than required to fly most types of single medium light sport aircraft. Operating the Maverick SP in its second medi um requires less additional skill and certainly less exotic skill than does operating fixed wing aircraft intended for use on water in their second medium. And, the risks involved in a projected typical emergency in a Maverick SP, where there is an engine failure or fuel exhaustion, would be much smaller than would the risks of a similar projected emergency in a fixed wing, weight shift or auto

- gyro aircraft where the speeds would normally be greater and where the operator would be required to make very sp ecific control inputs and to make critical and precisely timed decisions to avoid life threatening results. In inadvertent flight into IMC the Powered Parachute is the only aircraft that a novice pilot could be expected to survive. And, in a category of aircraft that doesnot require a specific, periodic aviation physical exam, the powered parachute is the only type of aircraft that can be expected to land itself without input from an incapacitated pilot.

For the same reasons that typical mechanical fail ures and operator errors can be expected to cause less drastic results in a Maverick SP ELSA, it is reasonable to project that allowing an owner

- operator to make modifications to a Maverick SP ELSA, within the well defined limits established by the FAA, wo uld also be less critical than in most other experimental light sport aircraft. Allowing an owner

operator of a Maverick SP to make modifications would certainly be less critical than allowing an owner

- operator of an ELSA intended for use on water to do s o.

Owner

- operators of experimental aircraft have a history of contributing to the maturity of many aircraft design concepts and related technologies; a number of

which are now incorporated into or have developed into popular certified aircraft.

The FAA has a successful history of channeling and controlling such modifications. It can be reasonably expected that the contributions and refinements of innovative owners and operators of Maverick SP ELSA's will significantly contribute to the

refinement and s afety of the Maverick SP and similar innovative multi

- medium aircraft in the future, without undo risk, if they are allowed to do so. It is also predictable that the desire to make small improvements to future designs such as the Maverick SP, if not given a reasonable opportunity to be exercised in a legal manner supervised by the FAA under the ELSA and E

- AB classifications ; may lead

to frustration of owner

- operators, resulting in either the demise of this and other

novel aircraft or the unauthorized modif ication by end users who are unwilling to wait for the manufacturers to authorize reasonable changes.

F. Petition Summary

This petition seeks an exemption from Title 14 Code of Federal Regulations (CFR) Part 21, § 21.191(i) Operating a light

- sport aircr aft that: (2)

- Has been assembled

– (iii) From an aircraft kit for which the applicant can provide the information required by § 21.193(e); and (iv) In accordance with manufacturer’s assembly instructions that meet an applicable consensus standard; or (3)

- Has been previously issued a special airworthiness certificate in the light

sport category under § 21.190.

The exemption sought is for operation of experimental light

- sport aircraft (ELSA) with additional weight allowance for a powered parachute (PPC) inten ded for both flight operations and operation on public roadways, that is similar to the weight allowance for light

- sport aircraft (LSA) intended for operation on water.

A similar exemption

- Exemption No. 10299, Docket No. FAA

- 2010

- 1221 has been granted to ITEC for the special category light

- sport aircraft (SLSA) version of theMaverick PPC Model No. Maverick SP, serial numbers MS9001

- MS9999. This petition seeks the same exemption from a maximum takeoff weight (MTOW) of 1,320 pounds (600 kilograms) to allow an additional 110 pounds, the same as an LSA intended for operation on water, for applicability to ELSA Maverick SP PPC’s.

A roadable PPC has similar weight penalties to an LSA intended for operation on water, and therefore a similar weight allowan ce 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 (M TOW) of 1,320 pounds (600 kilograms) for aircraft not intended for operation on water. The exemption is requested to allow the “Maverick SP” PPC ELSA design to include structures, systems, and instruments necessary for it to safely operate both in the air and on the ground just as has been granted for the SLSA version of the ITEC Maverick SP model. In order to meet these design requirements and still maintain a suitable useful load for flight operations, the Maverick SP PPC ELSA will require a MTOW of 1,43 0 pounds (650 kilograms), the same as an LSA intended for operation

on water.

If approved, this petition for exemption will allow: (1) ITEC to issue a statement of compliance (FAA Form 8130

- 15) for each ITEC

Maverick SP PPC ELSA “kit” in accordance with § 21.193(e), for operation at the same weight prescribed by 14 CFR Part 1, § 1.1 for LSA intended for operation

on water. (2) Any ITEC Maverick SP PPC SLSA to be converted to ELSA in accordance with § 21.191(i)(3)

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 ship and demonstrated to the European aviation community that the 'Wright Flyer' could not only fly, but it could also turn.

Roadable Aircraft or 'Flying Cars' 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 i nnovator has developed what

now is 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 A STM standards. The Florida department of Motor Vehicles has licensed it to operate on the public roadway system.

There is one half of a remaining obstacle that stands between the Maverick SP 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 it practical as an ELSA as well as an SLSA for use here in America

-Monitoring 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. The only need is a weight exemption of 110 pounds for the Maverick SP ELSA as well as for the Mav erick SP SLSA (already approved for a weight exemption of 1430 lbs) necessary to allow the

Maverick SP to operate safely both in the air and on the ground, while carrying two reasonably sized people and a modest amount of fuel.

Can Sport Pilots saf ely operate a Maverick SP ? It has been brought to 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. This is not the case with the Mave rick SP . We also understand that there is legitimate concern regarding the capability of 'flight critical' surfaces and controls to stand up to the rigors of ground operations without debilitation of their airworthy structures. This is not the case with the Maverick SP which stores all of its flight critical structures in a protected compartment when in ground operation.

The Maverick SP , it should be noted, is radically different from a roadable fixed wing aircraft in that it uses a fundamentally differe nt technology for flight. The Maverick

SP is a powered parachute with robust ground capabilities

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

Please Consider the following:

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

- isolated from the stresses of ground driving.

In the Maverick SP , there is a dedicated storage compartment bordered by chromoly steel tubing and covered in a heav y 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' h aving no internal structures which are susceptible to ground operation vibrations. The 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 pa rachutes but the Maverick SP . The

Maverick SP 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 SP

, there are no 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 SP are well within the wheel footprint of the

vehicle. A s an additional safely feature, these ‘spreader bars’, where the wing attaches, are supported by two cables

– either one of which is capable of carrying the entire weight of the aircraft. There are actually eight support structures thatconnect the wing t o the fuselage. Half of those structures could fail without jeopardizing the flight integrity of the Maverick SP

.

The Maverick SP parachute and its support lines are designed to be able to survive even a debilitating ground collision or loss of ground c ontrol resulting in a rollover of the 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 entir e 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 poten tially exceeding the skill level of Sport Pilots, it should be noted that the Maverick SP , again, is a powered parachute having, with little doubt, the lowest fatality rate record of any light sport aircraft category.

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

First, the Maverick SP incorporates an integrated Ground

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

acce lerator for air control as well as ground control.

Second, as in all powered parachutes, should the Maverick SP encounter a thrust system failure while in flight, control of the Maverick SP is still available to the

Maverick SP pilot and the aircraft floa ts 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 SP 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, stall

- spin accidents unlikely in the extreme.

Further, the Maverick SP structure com pletely 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 SP has been tested in the extreme scenario where power was totally shut down in flight after which the pilot made no control inputs whatsoever. The Maverick SP 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 bu t 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 wit h 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 SP uses the same primary controls for pitch

and directional control in both air and ground operations. The Maverick SP has back up controls that use the feet for steering and it has a second throttle that is hand operated. Both of these backup controls are completely separate of each other and can be used indepen dently or in conjunction with each other.

In fact, the Maverick SP is so safe, that in the case of a pilots debilitation in flight, it would be reasonable 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 from the rear seat and can access the hand throttle as well. As has been pointed out, the Maverick SP is extremely resistant to stalls and spins and the fuselage structure is extremely robust and capable of absorbing predictable loads from almost any normal forced 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 SP design in which the flight structures and the ground structures are largely independent of each other. The Maverick SP fuselage is not only capable of handling all normal on road stresses, but is also extremely capable off road which was a foundational design criteria of this 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 flexible cables supporting the lower fuselage in flight).

By its nature, the Maverick SP Powered Parachute, in flight, is a pendulum suspended by support lines from a self inflating parachute wing suppo rted by a totally non

- critical wing deployment system prior to flight. In flight, the chute deployment system is part of the required structure and only serves to dampen oscillations of the fuselage. The oscillations are not dangerous, however, but do

di minish the engine thrust efficiency when the fuselage swings, putting the propeller at an angle that is not perpendicular to the line of flight.

In the Maverick SP , even weight and balance

- though it affects the angle at which the fuselage hangs, is no t critical except to the efficiency of the propulsive effort.

The Maverick SP design, as is common on most Powered Parachutes, flies with the pilot ahead of the center of mass and the engine behind the center of mass. Passengers and cargo are located dir ectly under the center of lift so that increasing

or decreasing the weight 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 factors 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 SP , with its:1. Robust chromoly fuselage structure that completely 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.

It is our opinion that public demand and the increasing congestion on our public roadways will inevitably result in the development of a highway in the sky system. The great limiting factor to making this dream a reality is certainly not the availability of the 'skyway'. Nor is it the lack of instruments capable of defining such a highway in the sky system. Nor, is it the lack of affordable auto pilot equipment capable of flying Maverick SP’ s. The great limitation is the lack of ex istence of a practical vehicle with both ground and air capabilities.

We suggest that a Powered Parachute with simultaneous capabilities for operating on public roads is the ideal vehicle with which to carefully investigate this new and promising world of multi

- medium vehicles.

Realistic development of a practical powered parachute ELSA with full ground capabilities and sufficient structure to make it safe in both air and ground operations, does require a weight exemption if it is to have a useful lo ad sufficient to carry two

'real life' souls. This weight exemption is even more necessary in the Maverick SP ELSA than in the Maverick SP SLSA, (Our initial request for exemption was intended as a request for the exemption for all Maverick Model SP's, in cluding the SLSA and especially the ELSA) because there is more demand for the ELSA than for the SLSA. We do not petition that you increase the Maverick SP’ s gross weight to account for all of the additional structure required for safe ground operation. We do ask that you allow a minimum exemption to increase the Maverick SP gross takeoff weight by 110 to 150 pounds. We believe that such an exemption, making it possible for the public to put Maverick SP ELSA as well as SLSA Powered Parachutes into practi cal use in the near future, at affordable costs; and to take a first step toward a possible solution to our congested highway system is definitely in the interest of the public as a whole, whether they personally use a Maverick SP for transportation or mer ely benefit from the information gleaned from Maverick SP operators and the development of a transportation system that ceases to be single medium centric for the benefit of all of us who live in this great land which has been

a leader in aviation technolo gy from the beginning of manned flight.

Let’s keep America the leader in aviation innovation.

END