New gyro ELSA petitions - need your comments submitted

To a point, but what manufacturer of fixed-wing LSA has had to petition the FAA to allow his entire category and class a fair hearing? To the extent that individual exemptions are even necessary, that's a valid role for PRA.

Regardless, I wish you success. I think this is hugely important.

Paul, Originally the FAA disallowed gyroplanes completely in the SP/LSA NPRM. It was by quick and effective action by the PRA (Gary Goldsberry, etc.) at that early date that changed the minds of the NPRM Project Manager. It was an unfortunate internal political discontinuity within the FAA (with the Rotorcraft Directorate that did not support SP/LSA at all) that prevented SLSA. The RD had a veto on the aircraft portion (SLSA) of the new rules. It was the PRA involvement at that time that got the "good guys" in Washington to do all that they could do without the RD approval - SP and LSA for gyros. Also, the road to SLSA was set out in the rule - this is the road we are now persuing. Until we had manufacturers willing to meet the ASTM standard, there was nothing the PRA could really do with the FAA - a path was at least set, in many ways because of the PRA involvement. That path requires individual exemptions as detailed in the rule.

The RD hard line against SLSA gyroplanes came from the internal arguing within the gyro community about stability, HSs, etc. That arguing, and some screwy aerodynamics lobbied on them (by an un-named but prominent producer at the time) convinced the RD that the gyro community could never agree on a "consensus standard". The way the community appeared to the RD at the time was total disarray and very faulty understanding of what it takes to fly gyros safely. The PRA stepped up and assisted and promoted the ASTM standard that we DID achieve. It was a hard road to climb, but, I believe the highly visible work on the ASTM standard, especially all the stability discussions, raised the awareness of the community and did help reduce PIO and buntover accidents since then. There is ready acceptance of reasonable prop thrustlines and HSs as a result.

The RD has lately been making noises that they "like what they are seeing". This may be a reason they have now decided to put some priority on these exemption requests. Unfortunately, most of what they are liking is not American born. But, we are getting there - look at the new Sport Copter II. We need American stats now on "compliant" gyroplanes to possibly correct all the bad PR gyros have had - especially with the RD.

And the RD is not dumb! Their simple and patronizing remark to us back at a meeting in early 2000 with them - trying to convince the RD we knew what we were doing was: "We know what is wrong with gyros - there's not enough back here for what's up here!" - pointing to a beautiful picture of an RAF! That remark came after one of our prominent gyro proponents tried to explain in faulty physics that gyros were unsafe because they had high thrustlines. After about 30 seconds at the chalk board, the RD Engineer asked that person to "Please sit down - we know what is wrong -----"!)

It was very difficult to dig out of the hole the gyro community had been digging for itself! The arguing did not help! The PRA is showing full support for what the manufactureres and ASTM committee is now doing - but it is in the manufacturer's ball park right now.

Right now it is in the gyro communities ball park too - tons of comments to the fAA will likley move things along! Post your comments on regulations.gov.

- Greg
 
Greg,

I think the fact that much of what they like is coming out of Europe argues for LSA in the US. The newer European designers had a chance to form a viable business, because their regs provide for an LSA-type category in which to register factory-built aircraft. Here in the US, it would have been hard to even make the payments on new molds.
 
Greg,

I think the fact that much of what they like is coming out of Europe argues for LSA in the US. The newer European designers had a chance to form a viable business, because their regs provide for an LSA-type category in which to register factory-built aircraft. Here in the US, it would have been hard to even make the payments on new molds.

Paul, true in many countries, but not in all. Britain is a real bear of a regulatory problem - prevents moving beyond the "gyrocopter" mode. Probably the condition in other countries where they don't have "experimental" rules as free as ours, prevented a lot of experimenting down the wrong roads. In the U.S., IMHO, the freedom to kill yourself is great for amateur adventure, but has lead to too many wrong directions. But, I would not want to give up that freedom - just want to help people know better how to apply it.
 
Fair enough, but why not both? LSA for fixed-wings created neither regulatory hurdles nor market obstacles to EAB fixed-wings. It just provided a choice for the majority of fliers who don't care to be builders.

If LSA gyros come to pass, the question asked of kitmakers by prospective customers will eventually be, "does it meet ASTM standards?" Kitmakers will lose sales if the answer is "no," destroy their own reputations if they fraudulently answer "yes," and the standards will gain market support.

For people who swear by unsafe designs, EAB leaves the wild, wild west wide open.
 
To the FAA'
Leave it to the Feds to complicate something simple. If fixed wing aircraft experimentals are included in the sport pilot category then all experimental aircraft should be included, including helicopters, and gyroplanes. There once was the unrecognized basic flight instructor who would traing untralight pilots. Hummm, that category still exists. What are we talking about in CFI training from Sport Pilot to Recreational pilot? Five hours or so. I already have a commercial rotorcraft certificate, but for the many pilots who have yet to fulfil their dreams, the sport pilot certificate should also include rotorcraft of all types, nice and simple.
 
John, the FAA wanted LSA limited to simple aircraft systems. I'm guessing there were two reasons, one being the lowered training minimums for pilots, the other being the less-rigid ASTM self-certification processes.

Fixed-wing LSAs are not allowed to have in-flight adjustable propeller pitch, so that's where the line was drawn.

Gyroplanes were included in principle because they do not have collective pitch control, and are similar in simplicity to LSA fixed-wings.

The Recreational certificate is still available and, as you note, is similar in training requirements to Sport Pilot. Ironically, a Recreational Rotorcraft/Gyroplane pilot might consider Sport Pilot to be an upgrade, since SP does not require additional endorsements for distant airports.
 
John, the FAA wanted LSA limited to simple aircraft systems. ---

Paul, excellent response to John. When we first showed some gyroplanes to Sue Gardner, the FAA's NPRM Project Manager, she commented: "This has fewer moving parts than my airplane." It is the simplicity of the gyro that changed the mind of the FAA (DC) project to include gyroplanes under the SP part of the rules. Ubnfortunately, the RD (having the jurisdiction for the gyroplane aircraft, but not for the gyroplane pilots) had other biases and vetoed SLSA for gyros. The (DC based) NPRM project though, in large part also from the comments it received from the gyrop community, managed to provide some accomodations in the rule to eventually get gyroplanes approved for SLSA. Part of that was this Exemption process. Another part was the Part 61 provision that allowed gyroplane instructors (and others with special needs) to apply for and get a LODA (Letter of Deviation authority) to train in EXPERIMENTAL gyroplanes. Note, other instructors in other aircraft types - airplanes, Trikes, PPC, etc. - must discontinue training in their "experimental" (ELSA, EAB, etc.) aircaft in January of 2010.

Although we can't just go out and buy a new ready-to-fly SLSA gyroplane right now, there may be some other advantages to not being granted SLSA gyroplanes immediately. One may be that it may raise some prices for the aircraft to have to make the changes that might be necessary to "comply" with the consensus standards. The prices for other SLSA aircraft have certainly not come down as a result of being able to sell ready-to-fly SLSA airplanes.

Another issue may be the types of aircraft that gyro people like to fly. The gyro movement is still very much a small and sporty and minimal aircraft culture. If we would be thinking we would like to buy one of these "gyrocopters" directly from the factory, ready to fly SLSA, that just won't happen soon. The producers of these current kits may simply not be big enough to handle the compliance, quality assurance, record keeping, continued airworthiness processes, etc. that comes along with SLSA rules. A small company with limited resources might have a tough time scaling up people and investments to meet those requirements. That means those minimal aircraft will likely remain as 51% kits or scratch built for some while.

Luckily there are some current gyroplane producers with enough resources to, hopefully, meet those requirements - required if they want to use the ELSA exemtions awarded to them. Unfortunately, those producers are generally of the higher end variety of gyroplanes right now. But, I see this as the "jump start" to grow the industry where we might eventually be able to have reasonably priced basic "gyrocopter" gyroplanes - that might also prove to add safety to the sport. With more demonstrated safety and utility and performance from gyroplanes, the prejudices against gyrocopters might continue to diminish where these producers, and other "gyrocopter" producers could start really competing for the SLSA dollars out there.

Right now, it appears to me, these more expensive gyroplanes are attracting a lot of airplane pilots - IMHO because they are seeing where they aren't risking life and limb, because even these larger and heavier 2-seat gyroplanes offer more fun than the equivalent airplane, and because these SLSA equivalent gyroplanes are much less expensive than a lot of the SLSA airplanes on the market! If we can get some ELSA gyrplanes avaialble, ready-to-fly, I could see gyroplanes finally meriting their true potential as the safest, simplest, and most fun sport aircraft available.

- I need to get of my soap box now, its a pretty day, got to fly somewhere! Get your comments posted - Greg
 
...Another issue may be the types of aircraft that gyro people like to fly. The gyro movement is still very much a small and sporty and minimal aircraft culture...

Only because that's what's been available! If all paint was red, all homeowners would appear to prefer red houses...

...Right now, it appears to me, these more expensive gyroplanes are attracting a lot of airplane pilots...

Exactly! Which suggests higher-end machines would draw in people who are NOT interested in sporty, minimal aircraft.

It was very educational standing near the AirGyro booth at Oshkosh in 2007, seeing the reactions of people to the Sport Copter II. The jaws of the fixed-wing guys hung open when they saw that machine.

We won't grow the sport until it offers gyroplanes which look more like "real aircraft" to the general aviation masses. It doesn't mean the existing machines have to disappear. Experimental Amateur Built will still be available.
 
I agree w/PW Plack. I ultimately want a fully enclosed (engine and all) for myself. It appears, to the untrained and unfamiliar eye, as a legitemate aircraft. The only that thnig that the gyro community is missing is relatively inexpensive factory produced aircraft. With that, there is nothing to stop us from....... nothing less than WORLD DOMINATION!!! Muhahahahahahahahhahaha!

Dave
 
World domination huh? I have sick thoughts of arming my RAF, rockets, machine gun fire, and of course a bomb or two to drop. It would be so much fun!!!!!!
 
Thanks, but more posts please

Thanks, but more posts please

I have just reviewed the petitions and have seen the comments a lot of you have posted so far. The gyroplane community should certainly thank you for your support.

If you have not yet posted a comment, I hope you will do so please. I'm not sure how much it would help, but please consider posting a comment on all of these petitions. The FAA will probably be considering all of these petitions at the same time and might relate all comments to the whole group - that is what I am hoping. But, for most impact, it would probably be good to comment on all the existing petitions.

Here is a reminder of how to post your comments:

- Go to http://www.regulations.gov

- Enter one of these three Docket numbers in the search line, then click GO:

--- FAA-2009-0442 (Magni Gyro)

--- FAA-2009-0445 (Sport Copter)

--- FAA-2009-0475 (Auto Gyro (MTO)

On the second page that opens up, near the top of the page, click on "Send a comment or Submission".

- Fill in your information - at least your name.

- Fill in your comment in the lower box

- If you want to submit a file, be sure to click "Add Attachment" after you browse for your file.

Repeat the above process for all three petitions.

FYI: I am working with Raphael Celier right now for him to re-submit the petition for Xenon gyros. When Raphael gets his petition posted, I will inform you on how to post comments on his Xenon petition also.

Thanks for your support. Tell your friends. The comment period remains open for only a short time, and we are asking the FAA to expedite consideration of granting these ELSA exemptions. We need the FAA to see as many comments as possible during their consideration.

- Thanks, Greg
 
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Comments on older petitions - also please

Comments on older petitions - also please

Earlier petitions were made by Groen Brothers (Sparrow Hawk) and Future Flight (Rob Dubin - Xenon). Groen Brothers has indicated to the FAA they definitely still want considertion of their ELSA petition for Sparrow Hawk.

Both of these petitions had earlier comments posted, but it might be helpful at this time to post additional new comments, especially if you had not done so earlier. The earlier petitions have been moved to new Docket numbers below and the previous comments on the Sparrow Hawk poetition are apparently no longer posted!)

(Raphael is now re-submitting the Xenon petition, so I am not sure if posting comments on the earlier Xenon petition would be as helpful as posting on the new Xenon petition when Raphael gets it in - but, more comments would probably not hurt!)


--- FAA-2006-23778 (Groen Brothers - Sparow Hawk)
--- FAA-2007-0007 (Future Flight - Rob Dubin, Xenon)

Thanks, Greg
 
Hello Greg,

I tried to post a comment on the Magni and I am not able to view it. I am leaving now; I will try again tonight with your help. I don't want to double post.

Thank you, Vance
 
Greg,

CAn you or someone post a 'boiler plate' text that we can easily modify and use for our comments? I think this will boost the number of comments.

.
 
Hello Greg,

I tried to post a comment on the Magni and I am not able to view it. I am leaving now; I will try again tonight with your help. I don't want to double post.

Thank you, Vance

If it will help, here are links directly to the three petitions:

--- Magni Gyro petition

--- Sport Copter Petition

--- Auto Gyro Petition - MT03)

--- Sparrow Hawk - GBA petition

--- Future Flight old Xenon petition

On this listing, you can click on any of the file icons on the right to see those specific comments, the original petitions, etc.

On the far right, click on any of the yellow "bubbles" to place a comment - doesn't matter which bubble you click on, your comment will just be added to the list.

- Thanks, Greg

Note that the Title of the petition from Auto Gyro (MT03) noted on the regulations.gov site is erroneously declared as "Sport Copter". This was an original erro in posting this petition, but it has been cleared up with the FAA reviewers. The proper letter for the MT03 petition is posted on their regulations.gov link properly though. - Greg
 
Am I buggering something up or is this showing up as Sportcopter also?

--- FAA-2009-0475 (Auto Gyro (MTO)

FAA-2009-0475-0001 Sport Copter - Exemption/Rulemaking 05/15/2009 OTHER
FAA-2009-0445-0001 Sport Copter - Exemption/Rulemaking 05/06/2009 OTHER

.
 
Greg,

CAn you or someone post a 'boiler plate' text that we can easily modify and use for our comments? I think this will boost the number of comments.

.

Tim, any comments, even short and sweet, such as "I support this petition", will help.

Here are some words I like:

"Granting these exemptions to make ASTM compliant gyroplanes available ready-to-fly in the U.S. will encourage safer designs, will improve acceptance of improved design principles, and will allow the full safety and utility potential that gyroplanes in other parts of the world are now achieving."

Here are some segments derived out of some other's comments:

"I support the FAA in granting ELSA to (Insert Manufacturer's name here) for this machine. It is a factory built beauty that has a tremendous safety record. It is well engineered and is built to exacting standards. The gyro community would be well served by more ELSA certifications such as this being granted by the FAA."

"This is an excellent idea. The (Insert gyro model name here) is a very well built and stable machine and by having it factory built will make it even safer. This is what the gyro community needs, well built safe gyro's."

"I have been active in the gyroplane community for 35 years. The new generation of stable gyroplanes has brought us into an era that I used to dream about. I have closely followed gyroplane accident statistics. I have seen a marked improvement in gyroplane safety with the certification and implementation of these stable gyroplanes during the Ultralight "transition phase". I hope to see the regulations changed or exempted to allow ELSA factory produced gyroplanes."


"In Europe, since the end of the 80s, although there has been a rapid increase in the number of pilots (and instructors) and flying hours, the accident rate for gyroplanes has been significantly reduced. All manufacture-built gyroplanes have long proven their security, actually an improvement over the past when only self-built gyros were allowed."

"Companies like Magni have been there since the end of the 70s, and Magni is the worldwide largest selling gyroplane in the world. Followed by Ela, MT, and a few others."

"By allowing factory-built gyros in the US market, you would not only increase the overall security, by at last getting all these unstable designs of the 60s out of the field, but as well boost this market in the USA."

- Greg
 
Am I buggering something up or is this showing up as Sportcopter also?

--- FAA-2009-0475 (Auto Gyro (MTO)

FAA-2009-0475-0001 Sport Copter - Exemption/Rulemaking 05/15/2009 OTHER
FAA-2009-0445-0001 Sport Copter - Exemption/Rulemaking 05/06/2009 OTHER

.

Tim, you are in the right place. The Auto Gyro petition (0475) was erroneously titled as "Sport Copter" initially - The Germans copied my template a little too closely - maybe a little translation confusion! The actual -0475 petition is for Auto Gyro and this has been cleared up with the FAA and in one of the first comments on this petition.

Your comment on -0475 will be for Auto Gyro. Comments on -0445 will be for Sport Copter. If you keep the comments generic about the value of granting these petitions, that would eliminate any confusions, but the FAA is aware of the mix-up and would be expecting some confusion. The number of overall comments is what counts - even if the wrong gyro might be mentioned.

- Thanks, Greg
 
Hi Greg,
Is the petition only for specific models within a manufacture, or will it benefit to mention,
for example: Magni M-14,16,22,24-Orion and Auto Gyro MT-03, MTO-Sport & Calidus.
Because of the variety of models from each manufacture?

Thanks Mike,
 
Mike,

As I understand it, the Exemptions, if/when granted, would be to the manufacturer. To then sell an ELSA ready-to-fly under the exemption, the manufacturer would have to show that that particular model complies with the ASTM standards. There would be no restrictions on how many models from that manufacturer could be sold as exempted ELSA - they would just have to verify "compliance" with the standards for each model they want to sell as ELSA. The petitiions are not requesting specific model exemptions - they are requesting the exemptions for the manufacturer - as the FAA so directed them to do.

- Thanks, Greg
 
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