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. Loui s 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 “light

sport 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 seek s the exem ption, 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 requiremen ts 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.US Department of Transportation

March 6 , 2017 Page 2

55740879.4 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 th e 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.

T he 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, regis t er, and operate the aircraft on public roads (Exemption No. 15422). While that exemption was predic ated 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 dual

purpo se 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.comUS Department of Transportation

March 6 , 2017 Page 3

55740879.4 TABLE OF CONTENTS

TABLE OF CONTENTS

................................ ................................ ................................ ................................ ..... 3

SUMMARY OF CONTENTS

................................ ................................ ................................ ............................. 4

I. CONTAC T 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 )US Department of Transportation

March 6 , 2017 Page 4

55740879.4 SUMMARY OF CONTENTS

In satisfaction o f 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 seek s 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 (VII I ) a summary that can be published in the Federal Register, stating (1) the rule from which the Company seek s the exemption, and (2) a brief description of the nature of the exemption the Company seek s

. 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 f or 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, t he Company seeks an exempt ion 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).US Department of Transportation

March 6 , 2017 Page 5

55740879.4 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

certi fication 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 rep airman 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 par tial 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 Certif ication

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 exte nt necessary to allow the MK 3.2 having an MTOW of 1,7 4 0 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 pro vided herein, t he FAA has granted similar relief to 14 C.F.R. § § 21.181(a)(3)(i) and 21.190(a) under Exemption No s

. 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 e xperimental light

- sport aircraft (“ ELSA ”) airworthiness certificate under 14 C.F.R. § 21.191(i)(3).US Department of Transportation

March 6 , 2017 Page 6

55740879.4 While independent bases substantiating the Company’s requested relief from these rules are provided herein, t he 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 Pilot s and Student s 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, t he FAA has granted similar relief to 14 C.F.R. § § 61.89(c)

, 61.303(a), and 61.315(a) under Exemption No s

. 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 ex emption from 14 C.F.R. §§ 61.325 on behalf of p ersons holding a sport pilot certificate who seek to obtain priv ileges 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 fro m 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 si milar 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 perso ns as conditions and limitations of a grant of exemption. This course ofUS Department of Transportation

March 6 , 2017 Page 7

55740879.4 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 tra ining in the MK 3.2

.

While independent bases substantiating the Company’s requested relief from these rules are provided herein, t he FAA has granted similar relief to 14 C.F.R. §§ 61.411(g), 61.415, and 61.429(b) under Exemption No s

. 10829 and 16648

.

14 C.F.R. § 61.419

– Additional Privileges of Flight Instructors

Petitioner see ks 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 repairma n 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, t he FAA has granted similar relief to 14 C.F.R. § 43.3(c), 43.7(g), and 65.107(b) and (c) under Exemption No s

. 10829 and 16648.US Department of Transportation

March 6 , 2017 Page 8

55740879.4 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 t he 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 1,74 0 p ounds (790 kilograms) provided the aircraft meets the provisions of the identified consensus
standards.

4. When operatin g 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 certificat e 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 c ertificate 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 f light training and obtain the endorsement specified in
14 C.F.R. § 61.325.US Department of Transportation

March 6 , 2017 Page 9

55740879.4 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 spe cified 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
request s that any conditions and limitations related to such “roadability” laws or standards not be included in a grant of exemption.

IV. REASON S 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 w eight 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 Notic e 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 t wo 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. T he 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, P PC’s usually avoid taking off from both (i) rough fields which could potentially have holes, mud, rocks, dips in te rrain, high grass, soft sand, snow, and other objects, and (ii) concrete and asphalt surfaces , a s 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 passe d , as PPC technology has outpaced regulation in recent years . InUS Department of Transportation

March 6 , 2017 Page 10

55740879.4 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 fi elds, 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.

T he 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 i nherently has a higher weight. Additional systems and equipm ent are necessary to provide both increased functionality and enhanced safety. For example, the MK 3.2 is fitted with anti

- FOD guards and
h eavy

- 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.US Department of Transportation

March 6 , 2017 Page 11

55740879.4 Baggage 14 lbs.
Total MTOW: 1,740 lbs.

T he 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 sac rificing safety. In fact, the Company’s main work over the last several years has been in execu ting 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 w eight 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 featu res (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 clea rly 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 accel eration 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 passenger s over the toughes t 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 le ft and right and some PPC’s have a tiller device for ground steering , t he 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, w hereas 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.US Department of Transportation

March 6 , 2017 Page 12

55740879.4 While optional equipment on some PP C ’ s, the MK 3.2 distinguishable braking system is intended to provide increased runway incursio n 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 o f tires to accommodate
variable , demanding terrain . F rom 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 stand ards 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 assumption s 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 cl early 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 e asy

- to

- operate configuration. Notably, there is no retractable gear, no airbrakes/ sp o ilers, 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 Pro posed Rule, 67 Fed. Reg. 5368

- 01 (Feb. 5, 2002), E. What are the proposed changes to 14 CFR PartUS Department of Transportation

March 6 , 2017 Page 13

55740879.4 meet another of its stated objectives by helping to reduce the number of FAA aviation safety

ins pectors 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 rat ing to train in and operate
these aircraft.

Finally, i n 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 tha t 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

ot her 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 (light

sport aircraft) with a maintenance ra ting 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 t he 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 wil l 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

a ccidents 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.US Department of Transportation

March 6 , 2017 Page 14

55740879.4 With this impeccable safety record of PPC’s in mind, it’s important to understand that i n the realm of powered parachute flight, additional weight under the wing improves the aircraft’s high resistance to stall . So, from this perspective, the add itional 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 accident s 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 th is critical process happens during the takeoff roll. 7 Therefore, while the safety of a PPC is vital during a ll 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 mi nimum 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 t he 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 infla ted 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 a ffect 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 Ai rcraft 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).US Department of Transportation

March 6 , 2017 Page 15

55740879.4 much higher level of safety because it addresses the primary takeoff performance factors noted
above

– (1) the minimum takeoff distanc e 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 d uring 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, th e use of an Assisted Ground Roll System produces a much higher levelUS Department of Transportation

March 6 , 2017 Page 16

55740879.4 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, de creasing 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 depart ure 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, r ocks, dips in terrain, high grass, soft sand, snow, and other objects.

T he 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 th e 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 rapid ly 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, p articularly with
the aircraft’s use of the Assisted Ground Roll System which increases accel eration 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.US Department of Transportation

March 6 , 2017 Page 17

55740879.4 greatly enhancing t he 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 abi lity 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 performan ce 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 l oose stitching, abrasions... and debris in the wing cells, such as stones, sticks and bug s

. 15 Further, r ough field takeoffs can degrade the fabric of the wing, thereby greatly reducing the overall flight performance of the wing. And i f 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, t he 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, l ine 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 durin g 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.US Department of Transportation

March 6 , 2017 Page 18

55740879.4 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

tou chdown, the force of contact with the ground may be so great it could cau se 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 ge ars 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 flo at, 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 landing s

.

9. Increases safety during short

- field takeo

ffs

18 See PPC Flying Handbook, 11

- 13.

19 Id.

20 Id.US Department of Transportation

March 6 , 2017 Page 19

55740879.4 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 an d 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 requir ed. 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 saf er 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 shortes t 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 avoi d 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 H andbook, 7

- 9.

23 See PPC Flying Handbook, 5

- 2.

24 See PPC Flying Handbook, 7

- 2.US Department of Transportation

March 6 , 2017 Page 20

55740879.4 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 s urfaces.

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 accoun t 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, m ore 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 manu facturing 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 i nspiration, 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.

VI I. 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 th e 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, industry

led, self

- declarative system o f 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 toUS Department of Transportation

March 6 , 2017 Page 21

55740879.4 potentia lly 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 recreati onal 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 furth erance 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 Co mpany welcomes that partnership, as t he Company has developed many relationships within the FAA
in furtherance of the Company’s “compliance culture

. ” T he Company look s forward to continuing those relationships.

Moreover

, the development and production of the MK 3.2 is in accord with the pu rpose and spirit of the LSA Final Rule. T he LSA Final Rule sets forth its purpose , as follows: (1) improve safety, (2) provide an economical means for manufacturers to obtain FAA certification of light

sport 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 the se purpose s 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 un bounded 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.US Department of Transportation

March 6 , 2017 Page 22

55740879.4 VIII. FED E RAL 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) , 61.4 11(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 f or 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 a dditiona l 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 a ll 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, t he unique design incorporates the use of an assisted ground ro ll system to be used during the ground roll. The potential safety benefit s 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 substa ntially reduce the

gro und 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 comp onents 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 n umerous levels. These diverse benefits will: (1) enhance general aviation (“GA”) utilityUS Department of Transportation

March 6 , 2017 Page 23

55740879.4 and safety, (2 ) strengthen broader supp ort for improved LSA designs, (3 ) spur the flagging PPC manufacturing industry, which has decreased steadily since

201 0 by num ber of manufacturers, (4 ) inspire innovation while keeping the regulatory sy stem 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 barri ers 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) e ducation 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, granti ng 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 )