1401 Lawrence St., Suite 2300, Denver, CO, 80202  303.572.9300

polsinelli.com

Atlanta Chicago Dallas Denver Kansas City Los Angeles Nashville New York Phoenix San Francisco

St. Louis Washington, DC Wilmington

Polsinelli PC, Polsinelli LLP in California

55740879.4

March 6, 2017 Emanuel Anton

720-931-1192

eanton@polsinelli.com

SUBMITTED ELECTRONICALLY TO FEDERAL DOCKET MANAGEMENT SYSTEM

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE

Washington, DC 20590

Re: SkyRunner, LLC – Petition for Exemption Pursuant to 14 C.F.R. Part 11

Dear Sir or Madam:

On behalf of our client, SkyRunner, LLC, a Louisiana limited liability company (“Company” or 

“Petitioner”), manufacturer of the SkyRunner MK 3.2 model powered parachute aircraft (“MK 

3.2”), designed and equipped to operate as a powered parachute aircraft (“PPC”) that can take 

off and land on rough and short fields, we hereby apply for an exemption pursuant to 14 C.F.R. 

Part 11 from the below listed Federal Aviation Administration Regulations (“FARs”) to allow 

operation of the MK 3.2 in compliance with all FARs except those stated herein. 

More specifically, the Company seeks relief to allow the MK 3.2 to be designed, operated, and 

maintained under the regulations and standards that are applicable to aircraft issued a special 

airworthiness certificate in the light-sport category (“SLSA”) while incorporating equipment 

that collectively exceeds the maximum takeoff weight (“MTOW”) under the definition of “lightsport aircraft” set forth in 14 C.F.R. § 1.1 by 420 lbs. above the 1,320 lb. MTOW limitation for 

aircraft not intended for operation on water, resulting in a total MTOW of 1,740 lbs.

Importantly, granting this exemption will not adversely affect safety. In fact, granting this 

exemption will not only provide a level of safety at least equal to that provided by the rule from 

which the Company seeks the exemption, but will provide a much greater level of safety. 

Considering this significantly improved level of safety, the significant public interest and benefit 

to be derived from the safety and utility of the MK 3.2, and the satisfaction of all of 

requirements of a petition for exemption pursuant to 14 C.F.R. § 11.81, the Company 

respectfully requests the FAA grant the requested exemption as soon as possible.
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In order to help facilitate and expedite FAA review, the extent of relief requested has been 

broken down into three categories: (1) aircraft certification; (2) pilot licensing and privileges; 

and (3) aircraft maintenance. The Company has finite resources and aircraft certification is a 

threshold matter to the Company marketing and selling the MK 3.2 as part of an economically 

viable business plan; therefore, to the extent that the branch responsible for aircraft 

certification comes to a decision before the other branches, we respectfully request that the 

FAA grant a partial exemption as to aircraft certification while the FAA proceeds to make a 

determination on the other two categories of relief requested. 

The Company previously obtained an exemption for the MK 3.2 granting a weight allowance of 

110 pounds above the 1,320 pound (600 kilogram) MTOW limitation for safety equipment 

necessary to license, register, and operate the aircraft on public roads (Exemption No. 15422). 

While that exemption was predicated on its dual-use as a roadworthy vehicle, the MK 3.2 was 

designed primarily for a different use altogether. The MK 3.2’s design is uniquely configured for 

taking off and landing on rough and short fields, as opposed to being classified as a dualpurpose roadworthy vehicle as the MK 3.2 was classified in the previous exemption. Therefore, 

contemporaneously with the grant of a partial exemption as to certification, the Company also 

respectfully requests that Exemption No. 15422 be superseded.

Thank you for your consideration.

Sincerely,

Emanuel Anton

Lead Counsel for SkyRunner, LLC

Polsinelli PC

1401 Lawrence Street, Suite 2300

Denver, CO 80202

Phone: 720-931-1192

Email: eanton@polsinelli.com 
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TABLE OF CONTENTS

TABLE OF CONTENTS.....................................................................................................................................3

SUMMARY OF CONTENTS.............................................................................................................................4

I. CONTACT INFORMATION..........................................................................................................................4

II. SPECIFIC C.F.R. SECTIONS FOR EXEMPTION.............................................................................................4

III. EXTENT OF RELIEF REQUESTED...............................................................................................................5

IV. REASONS FOR SEEKING RELIEF ...............................................................................................................9

V. EQUIVALENT AND GREATER LEVEL OF SAFETY......................................................................................13

VI. PUBLIC INTEREST...................................................................................................................................20

VII. ADDITIONAL INFORMATION TO SUPPORT REQUEST ..........................................................................20

VIII. FEDERAL REGISTRY SUMMARY ...........................................................................................................22

CONCLUSION...............................................................................................................................................23

Exhibit A: Picture of SkyRunner MK 3.2’s Easy-to-Operate Design

Exhibit B: Test Results

Exhibit C: Video Test Results (Submitted via hard copy)
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SUMMARY OF CONTENTS

In satisfaction of 14 C.F.R. § 11.81, the Company submits the following: (I) contact information, 

(II) the specific sections of 14 C.F.R. from which the Company seeks an exemption, (III) the 

extent of relief the Company seeks, (IV) the reason the Company seeks the relief, (V) the 

reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which the 

Company seeks the exemption, (VI) the reasons why granting the Company’s request would be 

in the public interest, (VII) additional information, views or arguments to support the 

Company’s request, and (VIII) a summary that can be published in the Federal Register, stating 

(1) the rule from which the Company seeks the exemption, and (2) a brief description of the 

nature of the exemption the Company seeks. Each will be addressed in turn. 

I. CONTACT INFORMATION

Contact information for SkyRunner, LLC is as follows:

SkyRunner, LLC

Attn: Stewart Hamel

2929 Baird Road, Building # 50

Shreveport, LA 71118

Phone: 318-219-6722

Email: stewart@flyskyrunner.com

The FAA is authorized to contact the Company’s legal counsel, whose contact information is as 

follows:

Polsinelli PC

Attn: Emanuel Anton

1401 Lawrence Street, Suite 2300

Denver, CO 80202

Phone: 720-931-1192

Email: eanton@polsinelli.com 

II. SPECIFIC C.F.R. SECTIONS FOR EXEMPTION

The proposed regulatory exemptions could be replaced by revising the definition of “light-sport 

aircraft” under 14 C.F.R. 1.1 to allow for an MTOW of 1,740 pounds, but as the FAA has indicated 

this is not feasible, an exemption from the regulations identified herein will serve the same 

purpose. Accordingly, the Company seeks an exemption from the following regulations: 14 C.F.R.

§§ 21.181(a)(3)(i), 21.190(a), 21.191(i)(3), 43.3(c), 43.7(g), 61.89(c), 61.303(a), 61.315(a), 61.321, 

61.325, 61.327(a), 61.411(g), 61.415, 61.419, 61.429(b), and 65.107(b) and (c). 
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III. EXTENT OF RELIEF REQUESTED

Understanding different branches of the FAA are responsible for certain sections of 14 C.F.R., 

the extent of relief requested is organized below into three categories to help facilitate and 

expedite FAA review: (1) aircraft certification; (2) pilot licensing and privileges (which includes 

certification and privileges of sport pilots, students seeking a sport pilot certificate, and flight 

instructors with a sport pilot rating); and (3) aircraft maintenance (which includes certification 

and privileges of holders of sport pilot certificates and repairman certificates (light-sport 

aircraft) with a maintenance rating or an inspection rating). 

As stated above, the Company has finite resources and aircraft certification is of paramount 

importance to the Company’s ability to market and sell the MK 3.2 as part of an economically 

viable business plan; therefore, to the extent relief related to aircraft certification is favorably 

decided before the other exemption categories have been determined, we respectfully request 

that the FAA grant a partial exemption as to aircraft certification while the FAA proceeds to 

make a determination on the other two categories of relief requested. 

The extent of the relief the Company requests from these regulations is provided directly 

below.

Aircraft Certification

14 C.F.R. § 21.181(a)(3)(i) – Duration and 14 C.F.R. § 21.190(a)– Issue of Special 

Airworthiness Certificate for a Light-Sport Category Aircraft

Petitioner seeks an exemption from 14 C.F.R. § 21.181(a)(3)(i) and 14 C.F.R. § 21.190(a) 

to the extent necessary to allow the MK 3.2 having an MTOW of 1,740 pounds to be 

eligible for issuance of a special airworthiness certificate in the light-sport category.

While independent bases substantiating the Company’s requested relief from these 

rules are provided herein, the FAA has granted similar relief to 14 C.F.R. §§

21.181(a)(3)(i) and 21.190(a) under Exemption Nos. 10829 and 16648. 

14 C.F.R. § 21.191(i)(3) – Experimental Certificates: General

Petitioner seeks an exemption from 14 C.F.R. § 21.191(i)(3) to the extent necessary to 

allow MK 3.2 aircraft that have previously been issued a special airworthiness certificate 

in the light-sport category under § 21.190 to be eligible for issuance of an experimental 

light-sport aircraft (“ELSA”) airworthiness certificate under 14 C.F.R. § 21.191(i)(3). 
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While independent bases substantiating the Company’s requested relief from these 

rules are provided herein, the FAA has granted similar relief to 14 C.F.R. 21.191(i)(3)

under Exemption No. 15422.

Pilot Licensing and Privileges

14 C.F.R. §§ 61.89(c), 61.303(a), and 61.315(a) – Privileges of Sport Pilots and Students

Seeking Sport Pilot Certificate

Petitioner seeks an exemption from 14 C.F.R. §§ 61.89(c), 61.303(a), and 61.315(a) on 

behalf of persons exercising the privileges of a sport pilot certificate or student pilots 

seeking a sport pilot certificate to permit those persons to operate the MK 3.2 and to 

permit flight time obtained in the MK 3.2 to be considered flight time obtained in a light 

sport aircraft. 

While independent bases substantiating the Company’s requested relief from these 

rules are provided herein, the FAA has granted similar relief to 14 C.F.R. §§ 61.89(c), 

61.303(a), and 61.315(a) under Exemption Nos. 10829 and 16648.

14 C.F.R. §§ 61.321, 61.325, and 61.327(a) – Additional Privileges of Sport Pilots

Petitioner seeks an exemption from 14 C.F.R. §§ 61.321 on behalf of persons holding a 

sport pilot certificate who seek to obtain privileges to operate the MK 3.2 to receive the 

logbook endorsements, successfully complete the proficiency check, and complete the 

application specified in 14 C.F.R. § 61.321. 

Petitioner seeks an exemption from 14 C.F.R. §§ 61.325 on behalf of persons holding a 

sport pilot certificate who seek to obtain privileges to operate the MK 3.2 at an airport 

within, or in airspace within, Class B, C, and D airspace, or in other airspace with an 

airport having an operational control tower to receive and log the ground and flight 

training and obtain the endorsement specified in 14 C.F.R. § 61.325. 

Petitioner seeks an exemption from 14 C.F.R. §§ 61.327(a) on behalf of persons holding 

a sport pilot certificate who seek to obtain privileges to operate the MK 3.2 to receive 

and log the ground and flight training and obtain the endorsement specified in 14 C.F.R. 

§ 61.327(a). 

Under similar grants of exemption (Exemption Nos. 10829 and 16648), the FAA 

determined that an exemption from 14 C.F.R. §§ 61.321, 61.325, and 61.327(a) was not 

necessary; instead, the FAA included compliance with the provisions of these sections 

for certain persons as conditions and limitations of a grant of exemption. This course of 
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action is an accepted alternative to granting an exemption related to these specific 

sections. 

14 C.F.R. §§ 61.411(g), 61.415, and 61.429(b) – Privileges of Flight Instructor with Sport 

Pilot Rating

Petitioner seeks an exemption from 14 C.F.R. §§ 61.411(g), 61.415, and 61.429(b) on 

behalf of persons exercising the privileges of a flight instructor certificate with a sport 

pilot rating to permit those persons to provide flight training in the MK 3.2. 

While independent bases substantiating the Company’s requested relief from these 

rules are provided herein, the FAA has granted similar relief to 14 C.F.R. §§ 61.411(g), 

61.415, and 61.429(b) under Exemption Nos. 10829 and 16648.

14 C.F.R. § 61.419 – Additional Privileges of Flight Instructors

Petitioner seeks an exemption from 14 C.F.R. § 61.419 on behalf of persons holding a 

flight instructor certificate with a sport pilot rating who seek to obtain privileges to 

provide training in and for the MK 3.2 to receive the logbook endorsements, successfully 

complete the proficiency check, and complete the application specified in 14 C.F.R. § 

61.419. 

Under similar grants of exemption (Exemption Nos. 10829 and 16648), the FAA 

determined that an exemption from 14 C.F.R. § 61.419 was not necessary. To the 

extent an exemption is not necessary to provide the relief requested herein, the 

Company withdraws its request for exemption from 14 C.F.R. § 61.419.

Aircraft Maintenance

14 C.F.R. §§ 43.3(c), 43.7(g), and 65.107(b) and (c) – Maintenance, Preventive 

Maintenance, Rebuilding, and Alteration

Petitioner seeks an exemption from 14 C.F.R. §§ 43.3(c), 43.7(g), and 61.107(b) and (c)

on behalf of holders of sport pilot certificates and repairman certificates (light-sport 

aircraft) with a maintenance rating or an inspection rating to permit those person to 

perform maintenance and preventive maintenance on the MK 3.2 as authorized within 

those sections.

While independent bases substantiating the Company’s requested relief from these 

rules are provided herein, the FAA has granted similar relief to 14 C.F.R. § 43.3(c), 

43.7(g), and 65.107(b) and (c) under Exemption Nos. 10829 and 16648. 
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Proposed Conditions and Limitations

The Company understands that grants of exemption may be subject to certain conditions and 

limitations. Based upon a review of historical limitations that have been assigned to SLSA 

products that have been granted similar exemptions, the Company suggests the following 

limitations be assigned to the MK 3.2 under the provisions of the requested exemption.

1. This grant of exemption applies only to the SkyRunner PPC model number MK 3.2.

2. SkyRunner must maintain a current record of all owners of SkyRunner MK 3.2 

certificated under the provisions of this exemption. The record must be made available 

to the FAA upon request.

3. SkyRunner may issue a Manufacturer's Statement of Compliance (FAA Form 8130¬15) 

for each SkyRunner MK 3.2 with an MTOW of not more than 1,740 pounds (790

kilograms) provided the aircraft meets the provisions of the identified consensus 

standards.

4. When operating the SkyRunner MK 3.2, the operator must adhere to all applicable 

general operating rules and flight rules for aircraft in 14 C.F.R. Part 91.

5. Each person operating a SkyRunner MK 3.2 certificated under the provisions of this 

exemption must operate the aircraft in accordance with the assigned operating 

limitations that form a part of the Special Airworthiness Certificate.

To the extent that exemptions to 14 C.F.R. §§ 61.321, 61.325, 61.327(a), and 61.419 are not 

granted, we respectfully request the following conditions and limitations related to those 

regulations be included: 

6. Any person who holds a sport pilot certificate and seeks to obtain privileges to operate 

the SkyRunner MK 3.2 aircraft must receive the logbook endorsements, successfully 

complete the proficiency check and complete the application specified in 14 C.F.R. § 

61.321.

7. Any person who holds a sport pilot certificate and seeks privileges to operate the 

SkyRunner MK 3.2 aircraft at an airport within, or in airspace within, Class B, C, and D 

airspace, or in other airspace with an airport having an operational control tower must 

receive and log the ground and flight training and obtain the endorsement specified in 

14 C.F.R. § 61.325.
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8. Any person who holds a sport pilot certificate and seeks to operate the SkyRunner MK 

3.2 aircraft must receive and log the ground and flight training and obtain the 

endorsement specified in 14 C.F.R. § 61.327(a).

9. Any person who holds a flight instructor certificate with a sport pilot rating and seeks to 

obtain privileges to provide training in and for the SkyRunner MK 3.2 must receive the 

logbook endorsements, successfully complete the proficiency check, and complete the 

application specified in 14 C.F.R. § 61.419. 

Importantly, this petition for exemption is distinguishable from and not predicated on 

“roadability” laws or standards, which apply to the ITEC Maverick (Exemption No. 10299) and 

the Terrafugia Transition (Exemption No. 16648). Accordingly, the Company respectfully 

requests that any conditions and limitations related to such “roadability” laws or standards not 

be included in a grant of exemption.

IV. REASONS FOR SEEKING RELIEF

The reason the Company seeks relief is to allow the MK 3.2 to be designed, operated, and 

maintained under the regulations and standards applicable to SLSA and ELSA while 

incorporating equipment that collectively exceeds the maximum takeoff weight under the 

definition of “light-sport aircraft” pursuant to 14 C.F.R. 1.1, thereby enabling a level of safety 

over and above that considered for typical LSA under the Certification of Aircraft and Airmen 

for the Operation of Light-Sport Aircraft Notice for Proposed Rulemaking (the “LSA Proposed 

Rule”) and Certification of Aircraft and Airmen for the Operation of Light-Sport Aircraft Final 

Rule (the “LSA Final Rule”).

To begin, the MK 3.2 contains characteristics of a typical PPC. The complete aircraft consists of 

a cart, which includes two seats and an aircraft engine; a wing, which must be inflated and 

pressurized by ram air prior to each takeoff; and a propeller, which provides thrust during

takeoff and continuing through all flight operations. The MK 3.2 design differs from a typical 

PPC as it is uniquely developed to take off and land on rough and short fields. 

The MK 3.2 was designed and configured to expand typical PPC zone of operations. The ideal 

departure area for a typical PPC is an open grassy area clear of debris and obstacles with a 

groomed, even surface. Furthermore, PPC’s usually avoid taking off from both (i) rough fields 

which could potentially have holes, mud, rocks, dips in terrain, high grass, soft sand, snow, and 

other objects, and (ii) concrete and asphalt surfaces, as the structural integrity of the wing and 

suspension lines may be compromised during takeoffs and landings if the wing catches on the 

runway surface. The MK 3.2 was developed and configured to bring to market an aircraft 

capable of safely taking off and landing on these types of surfaces. 

The MK 3.2’s expansion of a typical PPC’s zone of operations was likely not contemplated when 

the LSA Final Rule was passed, as PPC technology has outpaced regulation in recent years. In 
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fact, it was not until the FAA received comments to the LSA Proposed Rule that it became 

aware that design innovation and new use of existing technologies expanded a PPC’s zone of 

operations to include water operations, leading the FAA to revise the Final Rule to include both 

PPC-land and PPC-sea class ratings.

1

 Similarly, and understandably, the FAA likely did not 

consider PPC designed and equipped to take off and land on rough and short fields, because no 

such technology existed. The MK 3.2 fills that void with a patent pending design that 

represents the next significant technological advance in powered parachute aviation. 

The unique design of the aircraft allows for rough and short-field takeoffs and landings and 

provides additional safety features over typical PPC aircraft. Due to the design and safety 

requirements of an aircraft with very distinctive needs, the MK 3.2 inherently has a higher 

weight. Additional systems and equipment are necessary to provide both increased 

functionality and enhanced safety. For example, the MK 3.2 is fitted with anti-FOD guards and 

heavy-duty devices for increasing foreign object debris (“FOD”) resistance, allowing the MK 3.2 

to depart from areas that are otherwise not safe for operation of typical PPC’s. The additional 

systems and equipment and their associated weights, along with the other items that complete 

the total MTOW, are provided below: 

Feature Estimated Weight (in pounds)

A complete assisted ground roll system with independent 

power unit and transmission with differential and robust 

drive axles

288 lbs.

Chassis system including all components such as seats, 

instrumentation cluster, body panels, and safety 

harnesses

490 lbs.

Robust, active suspension 72 lbs.

Four wheel braking system 30 lbs.

Four robust wheels and off-road tires 152 lbs.

Rotax 914 UL engine 168 lbs.

Propeller and hub 10 lbs.

Wing 10 lbs.

Total Empty Weight: 1,220 lbs.

Two passengers (assuming each passenger weighs 189 

lbs.2)

378 lbs.

Two eight gallon fuel tanks, totaling sixteen gallons 128 lbs.

 

1

See LSA Final Rule, 67 Fed. Reg. 44772-01 (July 27, 2004), Section V.5.B. Part 61 – Section-by-Section Discussion, 

Section 61.5 Certificate and Rating Issued Under This Part. 

2

The standard average passenger weights used by the FAA for operators without an approved carry-on bag 

program are: (1) 189 lbs. for an average passenger during the winter, and (2) 184 lbs. for an average passenger 

during the summer. See Advisory Circular, Aircraft Weight and Balance Control, 120-27E, Section 205. 
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Baggage 14 lbs.

Total MTOW: 1,740 lbs.

The Company emphasizes that it has always and will continue to take great effort to design 

carefully and to limit weight in every reasonable way, staying extremely disciplined in the area 

of weight reduction without sacrificing safety. In fact, the Company’s main work over the last 

several years has been in executing an obsessive weight-savings program, cutting weight 

wherever possible. This has resulted in, for example, the removal of fiberglass and aluminum 

body panels in favor of carbon fiber and the shaving of weight off the tubular chassis. 

The increased weight is due to the MK 3.2’s unique and distinguishable PPC design and 

operational features not found on typical PPC’s. The FAA has previously granted exemptions to 

certificate and operate SLSA with unique functionality (see the Terrafugia Transition under 

Exemption No.’s 10072 and 16648 and the ITEC Maverick under Exemption No. 10299) and 

aircraft with innovative safety features (see the Icon Model A5 under Exemption No. 10829). In 

all instances, the aircraft exceeded the MTOW specified in 14 C.F.R. § 1.1 due to the 

incorporation of either a distinguishable design or innovative operational safety features. This 

petition clearly requests similar relief.

The unique design features a Rotax 914 UL aircraft engine (the “Aircraft Engine”), and a

complete assisted ground roll system with an optional independent power unit and a 

transmission with differential and robust drive axles, which collectively act as an assisted power 

source during the takeoff ground roll (the “Assisted Ground Roll System”) to help kite the wing 

more quickly. The use of the Assisted Ground Roll System produces a much higher level of 

safety by increasing acceleration and decreasing the distance necessary during ground roll for 

kiting the wing, leading to a number of operational safety features further outlined below.

In addition, the MK 3.2 is constructed from Chromoly seamless air-hardening heat-treated steel 

tubing bonded with carbon fiber composite to provide high levels of durability and 

performance. This lightweight, high-strength hybrid space frame protects passengers over the 

toughest of terrains and through the roughest of takeoffs and landings.

Furthermore, while typical PPC ground steering is conducted with a steering bar connected to 

the nosewheel that moves left and right and some PPC’s have a tiller device for ground 

steering, the MK 3.2 has a completely independent ground drive system that provides for 

increased positive control of the aircraft, which is particularly helpful during takeoffs, landings, 

and taxiing. 

Also, a typical PPC only has a rudimentary suspension system, whereas the MK 3.2’s robust, 

active suspension decreases wear and tear on all systems during takeoffs and landings, 

decreases the risk of hard landings and bouncing during touchdowns, and assists with landing 

rolls particularly during rough-field landings.
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While optional equipment on some PPC’s, the MK 3.2 distinguishable braking system is 

intended to provide increased runway incursion prevention and general safety. The MK 3.2’s

four wheel braking system assists during takeoffs by helping maintain positive control and 

acceleration, and assists in both rough-field and short-field landings. 

Moreover, while most PPC’s have three wheels or a tri-cycle gear configuration, the MK 3.2’s 

design configuration features four robust wheels and offers a selection of tires to accommodate 

variable, demanding terrain. From all-terrain to aggressive off-road tires, the options are 

uniquely suited for enhanced performance on ground surfaces and enhanced safety during 

rough field takeoffs and landings. 

Finally, while some PPC only have one seat, the MK 3.2 has two seats as the aircraft would not 

be economically viable with only one seat.

Notably, the Company has reviewed the applicable ASTM standards for SLSA to ensure that 

there is no need to change them in order to accommodate the additional weight allowance to 

account for the additional systems and equipment, which ensures that the incremental weight 

allowance will not invalidate the assumptions that have gone into the ASTM Standards.

All of the added equipment and use of the Assisted Ground Roll System undoubtedly provide 

dramatic safety improvements and increased utility. These benefits cannot be realized if the 

aircraft are not put into the hands of those who can benefit from them most – sport pilots. If 

there is concern that the MK 3.2 potentially exceeds the skill level of sport pilots, it should be 

noted that despite the addition of added equipment and the use of the Assisted Ground Roll 

System, the MK 3.2 still remains a simple-to-operate design. Importantly, the Assisted Ground 

Roll System is only used during the takeoff ground roll and never used in flight. Further, the use 

and maintenance of the Assisted Ground Roll System will be clearly defined in the Pilot 

Operating Manual and Aircraft Maintenance Manual. 

From a flight operations perspective, the MK 3.2’s intuitive flight system makes the MK 3.2 one 

of the easiest and safest forms of flight to master. In flight, the MK 3.2 has only two flight 

controls – left and right steering via handheld toggles and throttle handle to climb or descend. 

On the ground, the MK 3.2 is driven with a conventional steering wheel and gas and brake 

pedals. See Exhibit A for a visual of the MK 3.2’s easy-to-operate configuration. Notably, there 

is no retractable gear, no airbrakes/ spoilers, no variable pitch propeller, no mixture control, no 

carburetor heat, no cowl flaps, and no wing flaps. Due to the reduced control set, the MK 3.2 is 

even simpler to operate than many other LSA. 

Furthermore, in accordance with the FAA’s objectives in the LSA Proposed Rule, allowing pilots 

to obtain logbook endorsements authorizing privileges, rather than obtaining ratings through 

flight tests with FAA personnel or designated examiners, would make the sport pilot certificate 

more affordable than a recreational pilot or a private pilot certificate.3 It also helps the FAA 

 

3

See LSA Proposed Rule, 67 Fed. Reg. 5368-01 (Feb. 5, 2002), E. What are the proposed changes to 14 CFR Part 
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meet another of its stated objectives by helping to reduce the number of FAA aviation safety 

inspectors and FAA designated examiners needed to support airman certification.4 For these 

reasons, the Company is also seeking that this exemption allows sport pilots, students seeking 

sport pilot certificates, and flight instructors with a sport pilot rating to train in and operate 

these aircraft. 

Finally, in order to ensure the MK 3.2 can be kept in an airworthy condition in the cost-effective 

manner envisioned by the regulations governing SLSA products, the Company is seeking an 

exemption to ensure that the MK 3.2 can be maintained in the same manner as other SLSA. 

Furthermore, the incorporation of unique, more robust features do not add complexity to the 

maintenance and inspection aspects of the aircraft for repairmen or sport pilots beyond that of 

other aircraft issued a special airworthiness certificate in the light-sport category. This point is 

further bolstered by the fact that both the Terrafugia Transition and the Icon Model A5, both of 

which have an inherently more complex design than the MK 3.2, each received an exemption 

from 14 C.F.R. § 43.3(c), 43.7(g), and 65.107(b) and (c) (under Exemption No.’s 10829 and 

16648 respectively) to allow holders of sport pilot certificates and repairman certificates (lightsport aircraft) with a maintenance rating or an inspection rating to perform maintenance and 

preventive maintenance on those respective aircraft.

Through no fault of the agency, the fact that the MK 3.2 does not meet the typical definition of 

a light-sport aircraft has hindered the Company’s ability to deliver airworthy models suitable to 

meet market demand for PPC aircraft with greater level of safety, creating an economic 

hardship for continued manufacturing.5 Therefore, the Company must request an exemption 

to permit the MK 3.2 to be certificated, operated, and maintained under the regulations 

applicable to LSA at a higher MTOW.

Granting this exemption will definitely help give this innovative and uniquely functional LSA a 

chance to succeed in the competitive marketplace and will allow this to be accomplished with a 

much greater level of safety than that of typical PPC’s. 

V. EQUIVALENT AND GREATER LEVEL OF SAFETY

As a threshold matter, PPC's are often considered to be safer than fixed-wing aircraft because 

of their inherent stability, limited response to control inputs, and stall resistance. In fact, 

according to the FAA’s Continued Operational Safety (“COS”) Report, which tracks all known 

accidents and incidents involving SLSA from the time the LSA Final Rule was passed in July 2004 

through September 2015, not one fatal accident in the SLSA class involved a PPC and only 4 out 

of 501 non-fatal accidents/ incidents in the SLSA class involved a PPC. 

 

61?, Sport Pilot Certificate. 

4

Id. 

5

This is particularly so given the MK 3.2 is privately funded with finite resources.
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With this impeccable safety record of PPC’s in mind, it’s important to understand that in the 

realm of powered parachute flight, additional weight under the wing improves the aircraft’s 

high resistance to stall. So, from this perspective, the additional systems and equipment adding 

more weight to the MK 3.2 inherently make the aircraft safer during flight.

The overall design configuration also makes the MK 3.2 safer during the ground roll and takeoff 

process. It is estimated that 85% of accidents occur during the takeoff process, 10% transpire 

during landings, and 5% happen in flight.6 Most PPC incidents occur during the takeoff, because 

unlike most other types of aircraft, a PPC needs to create the airfoil before flight can be 

attempted, and this critical process happens during the takeoff roll.7 Therefore, while the 

safety of a PPC is vital during all phases of flight, safety is of paramount importance during the 

takeoff process. 

The MK 3.2’s unique and proprietary design was developed with this understanding at the 

forefront, and the MK 3.2’s unique design and configuration specifically addresses the most 

important factors for takeoff performance, which the FAA’s PPC Flying Handbook addresses in 

relevant part: 

The important factors of takeoff performance are as follows: (1) the takeoff 

speed, (2) the rate of acceleration during the takeoff roll, and (3) the takeoff roll 

distance, [which] is a function of both acceleration and speed. The minimum 

takeoff distance is of primary interest in the operation of any PPC because it 

defines the runway requirements. The minimum takeoff distance is obtained by 

taking off on a length of runway that allows sufficient margin to inflate the wing, 

perform the LOC procedure, and then satisfactory room to initiate a lift-off and 

climb. The power-plant thrust is the principal force providing the acceleration 

and – for minimum takeoff distance – the output thrust should be at the 

maximum after the wing is inflated and successful LOC procedure performed... In 

addition to the important factors of proper procedures, many other variables 

affect the takeoff performance of a PPC. Any item that alters the takeoff speed 

or acceleration rate during the takeoff roll will affect the takeoff distance. The 

most important variable to affect the takeoff performance is how fast the pilot 

can get the wing overhead, centered, and ready to take the load of the cart.

8

As stated above, the unique design of the MK 3.2 features an Aircraft Engine that is supported 

by an Assisted Ground Roll System. The use of the Assisted Ground Roll System produces a 

 

6

See PPC Flying Handbook, 12-2. 

7

See PPC Flying Handbook, 7-1. 

8

See PPC Flying Handbook, 7-8 (emphasis added). 
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much higher level of safety because it addresses the primary takeoff performance factors noted 

above – (1) the minimum takeoff distance is decreased, and (2) the wing gets overhead, 

centered, and ready to take the load of the cart much faster. The Company conducted time 

and distance testing to show the significant positive difference that the use of an Assisted 

Ground Roll System has during the ground roll. See Exhibit B for those testing results. See 

Exhibit C for a video that shows the appreciable difference that the use of an Assisted Ground 

Roll System will have. In summary, those testing results are as follows:

Time Test Results Using only Aircraft Engine Using Aircraft Engine Aided 

by Assisted Ground Roll 

System

How much time does it take from 

beginning of ground roll until the 

wing is inflated overhead?

6 seconds 4 seconds

Net Difference: 2 seconds

How much time does it take from 

beginning of ground roll until 

wheels up?

26 seconds 17 seconds

Net Difference: 9 seconds

Notably, the Assisted Ground Roll System increases timing performance from the beginning of 

ground roll to kiting of the wing by 33.33% and increases timing performance from beginning of 

ground roll to wheels up by 34.62%. 

Distance Test Results Using only Aircraft Engine Using Aircraft Engine Aided by 

Assisted Ground Roll System

How much distance is covered 

from beginning of ground roll 

until the wing is inflated 

overhead?

28 feet 20 feet

Net Difference: 8 feet

How much distance is covered

from beginning of takeoff 

ground roll until wheels up only 

the Aircraft Engine?

800 feet 600 feet

Net Difference: 200 feet

Remarkably, the Assisted Ground Roll System increases distance performance from the 

beginning of ground roll to kiting of the wing by 28.57% and increases distance performance 

from beginning of ground roll to wheels up by 25%. 

As one can clearly see, the use of an Assisted Ground Roll System produces a much higher level 
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of safety because a shorter ground roll, and therefore less runway length, is required to lift off. 

The wing is inflated overhead by a full two seconds faster, decreasing the minimum takeoff 

distance by a significant margin of 200 feet.

The above features, in combination with the entire design configuration, leads to a number of 

significant, as follows: 

1. Increases safety during soft and rough-field takeoffs

The ideal departure area for a PPC is an open grassy area clear of debris and obstacles with a 

groomed, even surface.9 However, the MK 3.2 was developed as an aircraft capable of taking 

off and landing on rough and short fields, which could potentially have holes, mud, rocks, dips 

in terrain, high grass, soft sand, snow, and other objects. 

The Company is cognizant that any surface that is not hard and smooth will increase the ground 

roll during takeoff, due mainly to the inability of the tires to smoothly roll along the surface, 

thereby reducing the PPC’s acceleration down the runway.10 Even more, tires can sink into soft, 

grassy, or muddy runways.11 The MK 3.2’s robust active suspension and off-road, terrain 

appropriate wheels and tires are specifically designed to account for these risk factors.

Further, takeoffs from soft and rough fields require the use of operational techniques for 

getting the aircraft airborne as quickly as possible to (1) eliminate the drag caused by 

obstructions, (2) avoid damaging landing gear, and (3) avoid possibility of wing becoming 

snagged during takeoff. To minimize the hazards associated with takeoffs from soft or rough 

fields, support of the aircraft’s weight must be transferred as rapidly as possible from the 

wheels to the wings as the takeoff ground roll proceeds. 

The MK 3.2 accounts for these potential hazards with its unique configuration, particularly with 

the aircraft’s use of the Assisted Ground Roll System which increases acceleration and results in 

a much faster kiting of the wing.

2. Increases safety during soft and rough-field landings

Similar to the soft and rough-field concerns during takeoff, obstructions, such as holes, muddy 

spots, rocks, dips in terrain, high grass, and other objects can also cause damage to the aircraft 

during landings.12 The MK 3.2’s robust active suspension, robust wheels and tires, and four 

wheel braking system helps cushion the impact then slow the aircraft as quickly as possible, 

 

9

See PPC Flying Handbook, 5-2. 

10 See PPC Flying Handbook, 7-8. 

11 Id.

12 See PPC Flying Handbook, 5-2. 
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greatly enhancing the safety of all of the occupants in the aircraft and decreasing the risk of 

damage to the aircraft.

3. Increases safety by increasing positive control on the ground

Operating an aircraft on rough and short fields inherently necessitates enhanced positive 

control of the aircraft on the ground, particularly during takeoffs, landings, and taxiing. For 

example, the primary requirements for safe taxiing are positive control of the aircraft at all 

times, the ability to recognize potential hazards in time to avoid them, and the ability to stop or 

turn where and when desired.13 

Accordingly, one of the most important design criteria of the MK 3.2 which led to adding the 

ground drive system was to improve performance of positive control of the aircraft on the 

ground, which in turn significantly enhances safety. 

4. Increases safety by decreasing risk of damage to the wing

Obstructions such as holes, muddy spots, rocks, dips in terrain, high grass, and other objects 

can all cause the wing to snag during takeoff.14 Rough-field takeoffs can lead to tears in the 

fabric, torn or loose stitching, abrasions... and debris in the wing cells, such as stones, sticks and 

bugs.

15

 Further, rough field takeoffs can degrade the fabric of the wing, thereby greatly 

reducing the overall flight performance of the wing. And if the PPC wing becomes too porous, 

more groundspeed may be needed to pressurize the wing, takeoff distance may increase, more 

RPM may be required to hold altitude, and fuel consumption may increase.16

According to the Company’s test results, the use of the Assisted Ground Roll System significantly 

decreases the distance covered from beginning of takeoff ground roll until the wing is kited by 

about 28.57%, thereby ensuring a 28.57% greater likelihood of avoiding damage to the wing.

5. Increases safety by decreasing risk of damage caused by faulty lines

Longer ground-roll and/or slower ground speed can lead to line-overs, end cell closures, 

pressure knots, line twists or wing oscillations.17 Therefore, not only will there be a 28.57% 

greater likelihood of avoiding damage to the wing, there will also be a 28.57% greater chance of 

avoiding risks associated with the lines and cables that drag on the ground during the ground 

 

13 See PPC Flying Handbook, 5-11.

14 See PPC Flying Handbook, 5-2.

15 See PPC Flying Handbook, 5-13. 

16 See PPC Flying Handbook, 3-5 and 3-6. 

17 See PPC Flying Handbook, 7-4, 5-15 and 5-16.
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roll. 

6. Increases safety in the event of a roll-over

Unlike most other types of aircraft, the fact that a PPC needs a parachute to take flight presents 

unique risks. If the wing falls toward one side of the aircraft during either takeoff or landing, 

this potentially exposes the PPC to a rollover which presents considerable risk of damage to all 

occupants inside the aircraft. 

The MK 3.2’s increased MTOW leads to a significantly reduced risk of rolling over. Further, the 

MK 3.2’s lightweight, high-strength hybrid space frame and panels are designed to provide 

more strength and protection to all passengers in the event a roll-over actually occurs.

7. Increases safety by decreasing wear and tear on all systems during takeoffs and landings

When a PPC contacts the ground during landings, its vertical speed is instantly reduced to 

zero.18 Unless provisions are made to slow this vertical speed and cushion the impact of 

touchdown, the force of contact with the ground may be so great it could cause structural 

damage to the PPC.19 When the descent stops, the lift will be zero, leaving the landing gear 

alone to carry both the PPC’s weight and inertia force.20

One main purpose of MK 3.2’s robust tires and shock absorbing landing gears is to cushion the 

impact and supply the force needed to counteract the force of the PPC’s inertia and weight

during landings. Because this equipment was inherently designed to absorb more punishment, 

these systems also decrease wear and tear during takeoffs. 

8. Increases safety by enabling a softer landing and thereby decreasing the risk of hard 

landings and bouncing during touchdowns

The goal for touchdown is to be precise, without float, but at the same time soft enough to 

prevent getting stuck in a soft surface, while understanding that a hard landing could lead the 

aircraft to get stuck on rough fields. Similar to directly above, MK 3.2’s tires and shock 

absorbing landing gears are designed to cushion impact and decrease the risk of hard landings 

and bouncing during touchdowns, significantly increasing the aircraft’s performance during 

landings. 

9. Increases safety during short-field takeoffs

 

18 See PPC Flying Handbook, 11-13. 

19 Id. 

20 Id. 
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To depart from a short field safely, pilots must exercise positive and precise control of aircraft 

during the takeoff ground roll so that takeoff performance results in the shortest ground roll 

possible. Furthermore, operating an aircraft on short and rough fields, many of which can be 

found in mountainous terrain, must account for the environmental effects of such terrain, 

including a potentially higher temperature, humidity, and the actual altitude of the field. The 

higher the temperature, humidity, and actual altitude of the field, the greater the role density 

altitude plays in in determining how much runway the PPC needs to get off the ground with the 

load on board, and how much climb performance the wing will have once airborne.21 In 

particular, an increase in a higher density altitude than at sea level can produce a fourfold 

effect on takeoff performance: (1) greater takeoff speed, (2) decreased thrust and reduced net 

accelerating force, (3) reduced rate of climb, and (4) increased runway required.22

The MK 3.2 was developed and configured by accounting for these variables with a 

configuration that provides an increased acceleration rate, thereby significantly reducing the 

runway requirements and enabling the Company to bring to market a much safer aircraft.

10. Increases safety by increasing performance during after-landing ground rolls, and 

particularly during short-field landings

Many accidents have occurred as a result of pilots abandoning their vigilance and positive 

control after getting a PPC on the ground. Other incidents have occurred where the wind has 

caught a still inflated wing and rolled the PPC over. As stated above, the MK 3.2’s higher weight 

decreasing the risk of rolling over. Further, the MK 3.2’s design and configuration, specifically 

the independent ground drive system, significantly increases positive control of the aircraft on 

the ground. And even more, the MK 3.2’s four wheel braking system allows the aircraft to 

come to a stop in the shortest amount of distance. 

11. Increases safety during paved surface takeoffs

Typically, concrete and asphalt surfaces should be avoided, as well as lit runways, as the 

structural integrity of the wing and suspension lines may be compromised during takeoffs and

landings if the wing catches on the runway surface or surrounding lighting.23 Pavement or 

areas of the ground not covered with grass on the takeoff runway will make it necessary to get 

the wing off the ground with as little ground drag as possible to avoid tearing or jeopardizing 

the integrity of the wing fabric and/or lines.24 So, in addition to the increased performance on 

 

21 See PPC Flying Handbook, 5-3. 

22 See PPC Flying Handbook, 7-9. 

23 See PPC Flying Handbook, 5-2.

24 See PPC Flying Handbook, 7-2. 
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soft and rough fields, the MK 3.2’s capability to deliver a shorter ground roll also allows it to 

more effectively operate on paved surfaces. 

As shown herein, the MK 3.2’s unique design and configuration provides a number of additional 

safety benefits over typical PPC. As an aircraft designed to be operated soft and rough fields, it 

is critical that the design of the aircraft account for specific risk factors and safety concerns. 

The MK 3.2’s patent pending technology does just that. Accordingly, the FAA’s grant of this 

exemption is in the public’s benefit and best interest not only for the aircraft’s enhanced 

functionality, but, more importantly, for the aircraft’s significantly greater safety.

VI. PUBLIC INTEREST

Granting the Company’s exemption furthers the public interest on numerous levels. These 

diverse benefits will: (1) enhance general aviation (“GA”) utility and safety, (2) strengthen 

broader support for improved LSA designs, (3) spur the flagging PPC manufacturing industry, 

which has decreased steadily since 2010 by number of manufacturers, (4) inspire innovation 

while keeping the regulatory system from stifling ingenuity, (5) establish a key first step in the 

advancement of the value of personal aviation to the people of the United States by addressing 

the largest barriers to the more widespread use of GA for transportation, (6) provide economic 

benefit to the United States, (7) foster science, technology, engineering and mathematics 

(STEM) education and inspiration, and (8) allow the U.S. to lead the way into the future of 

transportation. 

Accordingly, granting this exemption is in accord with the original spirit of the light-sport 

rulemaking and serves safety, the GA industry, and the public good. 

VII. ADDITIONAL INFORMATION TO SUPPORT REQUEST

The development and production of the MK 3.2 is in furtherance of the objectives identified by 

the Aircraft Certification Service (AIR) Strategic Plan for Light-Sport Aircraft, which sets forth 

AIR’s SLSA strategic vision for the continued support of the SLSA segment of the general 

aviation community and the continued safe integration of SLSA operations. This document 

reflects the objectives and goals of Aircraft Certification Service AIR: 2018 and outlines tactical 

methods for achieving these objectives with safety as a first priority. 

The Small Airplane Directorate (ACE-100) and the Design, Manufacturing and Airworthiness 

Division (AIR-100) identified the following objectives to accomplish the SLSA strategic vision: 

(1) safety, with a focus on providing a safer alternative to experimental amateur-built aircraft or 

ultralight vehicles; (2) industry accountability, in furtherance of enabling a successful, industryled, self-declarative system of compliance to applicable regulations and industry-developed and 

maintained consensus standards with the efficient use of FAA resources; (3) industry growth, 

with a focus on creating a clear path for companies starting in experimental aircraft to 
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potentially transition into producing light-sport, primary category, and ultimately part 23 

designs and production certification; (4) international leadership and harmonization, with a 

focus on providing and supporting a model of SLSA oversight that results in the international 

acceptance of the model and specifically the use of one set of international consensus 

standards for the design, manufacturing and quality, continued airworthiness, maintenance and 

operations, etc., of aircraft intended for personal recreational flying and flight training; (5) 

innovation, with a focus on facilitating innovation in recreational aviation, including the 

development of safety enhancing, energy efficient and environmentally responsible products; 

and (6) regulatory future, in furtherance of providing an appropriate regulatory structure to 

allow SLSA to maintain FAA safety goals, accommodate innovation, and continue international 

leadership and harmonization. The development and production of the MK 3.2 is clearly in 

furtherance of every single one of these objectives.

Furthermore, the Strategic Plan sets forth a vision of a partnership between industry and the 

FAA where each play a vital role to achieving the SLSA strategic plan objectives. The Company 

welcomes that partnership, as the Company has developed many relationships within the FAA 

in furtherance of the Company’s “compliance culture.” The Company looks forward to 

continuing those relationships.

Moreover, the development and production of the MK 3.2 is in accord with the purpose and 

spirit of the LSA Final Rule. The LSA Final Rule sets forth its purpose, as follows: (1) improve 

safety, (2) provide an economical means for manufacturers to obtain FAA certification of lightsport aircraft, (3) provide an economical means for pilots to obtain a certificate to fly those 

aircraft, (4) provide the public with safe access to general aviation without creating a significant 

financial barrier, and (5) create more eligible pilots to meet the needs of future airline and 

military demand.25 Accordingly, fostering the development of the MK 3.2 as a uniquely 

designed LSA is in accordance with these purposes and the spirit of the LSA Rule. 

Finally, after a complete review of the sport pilot regulations, it is clear that the FAA is utilizing

MTOW limitation to ensure that SLSA products, and particularly fixed-wing aircraft, do not grow 

in size in an unbounded fashion. The Company believes FAA acceptance of this limited and 

specific request for exemption related to a PPC does not provide an unbounded path for SLSA 

growth but rather a thoughtful approach to safety that is in the best interest of the public.

 

25 See Proposed Rule, 67 Fed. Reg. 5368-01 (Feb. 5, 2002), B. The FAA’s Reason for This Proposal. 
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VIII. FEDERAL REGISTRY SUMMARY

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

SkyRunner, LLC seeks an exemption from the following regulations: 14 C.F.R. §§ 

21.181(a)(3)(i), 21.190(a), 21.191(i)(3), 43.3(c), 43.7(g), 61.89(c), 61.303(a), 

61.315(a), 61.321, 61.325, 61.327(a), 61.411(g), 61.415, 61.419, 61.429(b), and 

65.107(b) and (c). 

The SkyRunner MK 3.2 is a first of its kind light-sport aircraft that is designed to 

take off and land on rough, soft, and short fields. While the ideal departure area 

for a typical powered parachute (“PPC”) is an open grassy area clear of debris 

and obstacles with a groomed, even surface, the MK 3.2 contains additional 

equipment and systems to allow it to be able to take off on variable terrain. The 

SkyRunner MK 3.2’s unique design allows for rough and short-field takeoffs and 

landings and provides additional safety features over typical PPC aircraft. Due to 

the design and safety requirements of an aircraft with very distinctive needs, the 

MK 3.2 inherently has a higher weight, as additional systems and equipment are 

necessary to provide both increased functionality and enhanced safety. 

For example, whereas a typical PPC only has a rudimentary suspension system, 

the MK 3.2 has a robust, active suspension, which decreases wear and tear on all 

systems during takeoffs and landings, decreases the risk of hard landings and 

bouncing during touchdowns, and assists with landing rolls particularly during 

rough-field landings. 

Further, the unique design incorporates the use of an assisted ground roll system 

to be used during the ground roll. The potential safety benefits from the use of 

the assisted ground roll system during ground roll are extraordinary. This vastly 

improves the aircraft’s ability to kite the wing and substantially reduce the 

ground roll, leading to a much greater level of safety. 

These benefits require exemptions from the Federal Aviation Regulations which

did not previously contemplate the inclusion of such an innovative design. 

Therefore, SkyRunner seeks relief to allow the SkyRunner MK 3.2 to be designed, 

operated, and maintained under the regulations and standards that are 

applicable to Special Light-Sport Aircraft (SLSA) and Experimental Light-Sport 

Aircraft (ELSA) while incorporating certain components at a weight above the 

current “light-sport aircraft” definition, thereby enabling a level of safety over 

and above that fully considered when the regulations for SLSA were created. 

Granting the Company’s exemption furthers the public interest on numerous 

levels. These diverse benefits will: (1) enhance general aviation (“GA”) utility 
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and safety, (2) strengthen broader support for improved LSA designs, (3) spur 

the flagging PPC manufacturing industry, which has decreased steadily since 

2010 by number of manufacturers, (4) inspire innovation while keeping the 

regulatory system from stifling ingenuity, (5) establish a key first step in the 

advancement of the value of personal aviation to the people of the United States 

by addressing the largest barriers to the more widespread use of GA for 

transportation, (6) provide economic benefit to the United States, (7) foster 

science, technology, engineering and mathematics (STEM) education and 

inspiration, and (8) allow the U.S. to lead the way into the future of 

transportation. 

As such, the Company respectfully requests the FAA grant this exemption as 

soon as possible. 

CONCLUSION

As shown above, each of the relevant statutory criteria factors to obtain a grant of exemption

are satisfied. Importantly, granting this exemption will not just provide an equivalent level of 

safety, but an increased level of safety. Accordingly, the Company respectfully requests the FAA 

grant the requested exemption as soon as possible. Furthermore, as stated above, to the 

extent that the branch responsible for aircraft certification comes to a decision before the other 

branches, we respectfully request that the FAA grant a partial exemption as to aircraft 

certification as the FAA proceeds to make a determination on the other two categories of relief 

requested. Upon the grant of a partial exemption as to certification, the Company also 

respectfully requests that its prior exemption applicable to the MK 3.2 (Exemption No. 15422) 

be superseded. 

Please feel free to reach out to the Company or its legal counsel with any questions, comments 

or concerns. We look forward to partnering and working with the FAA to make the SkyRunner

MK 3.2 a reality.

Sincerely,

Emanuel Anton

Encls: Exhibit A: Picture of SkyRunner MK 3.2’s Easy-to-Operate Design

Exhibit B: Test Results

Exhibit C: Video Test Results (Submitted via hard copy)