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 Regulations (CFR) 

Part 21, § 21.191(i) 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 lightsport 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) intended for both flight 

operations and operation on public roadways, which 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 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 intended 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 

exemption from the current restriction of a maximum take-off weight (MTOW) 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 1,430 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 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)

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 

petition.

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 for 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 asking 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 water. 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 sport 
aircraft 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 controls, 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 maneuverable boats.

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

long 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 

Maverick 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 the Maverick SP SLSA. 

There 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 vehicle 

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 states 

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 highway 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 capable 

Powered Parachute, privately-funded, and manufactured in small quantities. 

We have chosen to design this first 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 multimedium vehicles. In the meantime our only realistic 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 

robust 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 wheels – (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 during 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 additional 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 and 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 robust, 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 encourage 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 get 
twelve 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 approximately 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 (depending 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 

also 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 is 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 initiatives 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 tried 
staggered work start times, work at home concepts, and new 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 

structure 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 safety 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, windshield 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 public 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 articles 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 application 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 evaluation (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 Transportation 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 common 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 ELSA 

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 amphibious LSA I have studied has a 
sufficient 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 compromising 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 

which 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 would 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 control 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 operation 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 makes 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 excessive 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 ELSA 

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 specific 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 licensing 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 

Powered 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 owners 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 Maverick 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 

significant, 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 ELSA 

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 intended 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 specifically 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 air are neither stowed nor braced while being 

subjected to jarring 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 flightnecessary structures are protected against 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 absorption undercarriages. When the vast majority of these aircraft are 

modified for use on water which is as incompressible as asphalt, concrete and 
grass-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 absorptive 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 typical 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 damaged. 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 the 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 real-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 medium 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 specific 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 does 
not 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 failures 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, would also be less 

critical than in most other experimental light sport aircraft. Allowing an owneroperator 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 so. 

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 safety 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 modification 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 aircraft 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 lightsport 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) intended 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 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 intended 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 

exemption from the current restriction of a maximum take-off weight (MTOW) 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 1,430 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 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 innovator 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 ASTM 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 Maverick 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 safely 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 Maverick 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 different 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 heavy 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' having 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 parachutes 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. As 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 that 
connect the wing to 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 control 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 entire 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 potentially 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 

accelerator 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 floats 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 completely 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 but 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 with 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 independently 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 supported 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 

diminish 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 not 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 directly 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 existence 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 load 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, including 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 practical 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 merely 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 technology from the beginning of manned flight.

Let’s keep America the leader in aviation innovation.

END