New gyro ELSA petitions - need your comments submitted

gyrogreg

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Three new petitions for Experimental Light Sport Gyroplane exemptions have been submitted to the FAA:
- Magni Gyro, srl
- Sport Copter, Inc.
- AutoGyro GmbH (MT03)

If these petitions are granted by the FAA, it would then be possible for these gyro manufacturers to sell ready-to-fly (factory built) ELSA gyroplanes. The FAA has provided this option in order to get ASTM "compliant" gyroplanes flying in the U.S. - to verify that "compliant" gyroplanes will improve safety. This is an interim step toward possible SLSA gyroplanes in the U.S.

Last year we helped Xenon submit a similar petition. Several years ago, GBA (Sparrow Hawk) submitted the first such petition. The FAA has recently indicated they will now put priority on processing these requests.

It is very important now that the FAA receive (supportive) comments on these requests. Large numbers of comments are very helpful and the gyro community HAS made a difference with their response to other gyroplane issues in the past (i.e.: Sport Pilot NPRM, 51% rule changes, etc.)

Here is how to post your comment:

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

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

--- FAA-2009-0442

--- FAA-2009-0445

--- FAA-2009-0475

The first is for the Magni Gyro petition. The second is for the Sport Copter petition. The third docket number is for AutoGyro GMBH (MT03).

- 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.
 
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gyrogreg

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Additional information - FYI:

Additional information - FYI:

Once these exemptions are approved, it will be necessary for each of these gyro models to "comply" with the ASTM gyroplane standards - all three:

- Design and Performance Standard for Light Gyroplanes

- Quality Assurance Standard for Light Gyroplanes

- Continued Airworthiness Standard for Light Gyroplanes

Gyros sold under this exemption must also meet the U.S. definition of LSA - weight, speed, 2 occupants, etc.

We have recently re-activated an ASTM Gyroplane Subcommittee Task Team to consider changes to the D&P standard - some criteria in the original standard are difficult to meet or have been found to need adjustments. I hope to submit these changes for ASTM ballot soon. It is intended that these changes will make it possible of such gyroplane models to "comply" - while still maintaining, or improving safety of these gyros.

This is a separate but necessary activity to the FAA petitions. But, the FAA also has a say in the approval of any changes we may make in the standards.

If/when the petitions from individual manufacturers are approved, and if/when these models would "comply" to the ASTM standards for Light Sport Gyroplanes, those models would be able to be purchased ready-to-fly in the U.S.

- Thanks, Greg Gremminger
 

gyrogreg

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Review other's comments

Review other's comments

If you want to read the actual petitions or review other's posted comments, you can also do so on the second page by clicking on the blue highlighted Docket ID on the second posting - i.e.: click on FAA-2009-0442

- Then click on any of the document icons listed under "VIEWS". (You will need to click on each one you want to view. The first ones are the actual petitions.)

It may be helpful in presenting your thoughts, to review other comments.

Thanks, Greg Gremminger

Jim and Kelly Vanek, and Otmar Birkner, also thank you for whatever support you can give us.
 
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GyroRon

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How will this affect CFI's? and specifically sport pilot CFI's? I am trying to get my rating ( as soon as time allows ) but if I have to purchase a new gyro to offer training, I won't bother. Can't afford a new any of those...!
 

Mike Stone

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Ron...
Good question! What would that also do to the existing CFI's using their "experimental" craft under the Letters of Deviation? Would these letters then go away? (Greg...please comment).
 

gyrogreg

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How will this affect CFI's? and specifically sport pilot CFI's? I am trying to get my rating ( as soon as time allows ) but if I have to purchase a new gyro to offer training, I won't bother. Can't afford a new any of those...!

Good question Ron. Two parts:

First: Since these will be "Experimental" gyros, the Letter of Deviation Approval (LODA) allowances - that are currently how all gyroplanes instructors are providing training - will apply also to these ELSA gyroplanes. The LODAS are requested from and granted by your local FSDO. This will not affect you or any other gyroplane instructors for a long time - if ever.


Second: As you know, we have some concerns that when SLSA gyros might eventually be approved, the FAA might then require that all gyroplane flight instruction (for hire) would need to be done in SLSA (ASTM "compliant") gyroplanes - probably very expensive. I have received assurances that this requirement might not be made if it would mean fewer gyroplane instructors would be available because they could not afford SLSA, or ELSA trainer gyroplanes. We have other reasons it is not desireable to provide training only in ASTM "compliant" gyroplanes also - super stable gyros such as we hope ASTM "compliant" gyroplanes will be, do not make good training platforms for many of the "non-compliant" (less stable) experimental gyroplanes that would still be popular.

BUT, this ELSA process we are going through will be a long process. The intent is to get enough "compliant" gyros flying that large numbers and large numbers of flight hours would statistically show that "compliant" gyroplanes are safer. This requires a lot of "compliant" ELSA gyroplanes to be flying to be statistically valid to determine safety impact. This will take a long time to get those numbers of gyros out there. In the meantime, the FAA (and many of us) hope that large numbers of "compliant" gyros will influence more of the gyro community to be flying or modifying their gyros to be safer (Effective HS, etc.) When most gyros available to new pilots are actually safer, then training in "compliant" gyroplane trainers will be more appropriate to train most new gyro pilots.

Bottom line, this will not affect you - at least not for a long time, if ever.

- Thanks, Greg
 

All_In

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Way to go Greg!!! I'll write a comment.
 

chuter

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Greg,

Thanks for all the work you do to keep us flying, trained, and legal.

The same to all those on the ASTM Gyroplane Subcommittee Task Team.:usa2:
 

barnstorm2

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Thank you Greg! Will be including this in mailings and newsletters...

.
 

PW_Plack

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...As you know, we have some concerns that when SLSA gyros might eventually be approved, the FAA might then require that all gyroplane flight instruction (for hire) would need to be done in SLSA (ASTM "compliant") gyroplanes - probably very expensive...

Greg, first, thank you for your efforts in this area. If PRA is going to be a no-show on this issue, we're going to have to count on manufacturers and dealers like you to move this forward. How interesting that two of the three petitions are for machines which have LSA-like status in Europe.

The training cost concern, however, makes no sense to me. Currently, training in experimental gyroplanes is (sometimes significantly) more expensive than training in more costly fixed-wing LSA. If you intend to offer flight training as a business proposition, your costs will make you uncompetitive unless you (a) instruct enough hours to spread the costs, and (b) are willing to structure this as a business, like the fixed-wing guys. That means considering instruction in machines obtained through lease-back arrangements, new machine loans covered by insurance, depreciating the assets on business tax returns, etc.

I fully expect a brief jump in training costs if LSA happens for gyros, but only as long as the number of students interested in flying machines built by factories to known standards overwhelms the number of available gyroplane CFIs. I suspect many new gyro CFIs will come online rapidly, and they'll probably be helicopter instructors getting add-ons. There may be a rush to get enough new instructors certified.

If your interest in being a CFI is just to get other people to pay for your personal flying, you can't expect to be profitable. Full-time pros with good safety and pass-rate track records, however, will probably make decent money.
 
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GyroDoug

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Greg,

Thank you for the work you do in our behalf. I will pass on this information to everyone on my mailing list and hopefully we can generate a bunch of positive comments.

Gyro Doug
 

Russ Hobbs

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Thank you again Greg. Moving this direction will only increase participation in the sport, while hopefully adding a safety factor for those of us less mechanically inclined.

Russ
 

gyrogreg

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Greg, ----- If PRA is going to be a no-show on this issue, we're going to have to count on manufacturers and dealers like you to move this forward. -----

The PRA is an important element and contributor to this process. The PRA has recognized gyro community credibility with the FAA, EAA, etc. At the last PRA Board meeting at Bensen Days, the Board endorsed my working with the FAA and ASTM in their behalf. I have been asked by the PRA VP to handle the regulatory type issues for the PRA. When we see it to be valuable, we will speak specifically for the PRA. The PRA has provided an endorsement letter for these petitions for Exemption - which carries more weight with the FAA than you might think. Rick Marshall is the PRA representative on the ASTM committees.

To be fair, it is the manufacturer's responsibility to petition the FAA for these exemptions - the PRA cannot do that for them. I suppose I might be filling a multiple role - representing one manufacturer, getting other manufacturers involved, and the de-facto rep for the PRA in the eyes of the FAA and EAA and other aviation orgs. It is also the gyroplane producers who have the greatest stake in the ASTM standards as they are required to meet those standards to take advantage of any exemption granted to specific manufacturers. It is the manufacturer's responsibility to identify and request any proposed standards changes - that is what is happening.

So really, to expect the PRA to take the visible lead in these current petition and standards actions would be a little mis-placed, it can't speak for manufacturers who have the major responsibility and stake in these actions. But, you might say, I am doing this not only for myself as a manufacturer rep, but also as a back door way for the PRA to get things moving now. There is an advantage at this time to have multiple petitions before the FAA - gets them the priority - thus the reason the PRA part of me is pulling this together with several manufacturer's.

I still strongly encourage everyone's membership in the PRA. Ultimately and behind the scenes, it is the PRA that motivates all we are doing. If I and the FAA and others did not respect the PRA as the gyroplane representative organization, we would not not get nearly the attention we need to get some of these things done. Membership is what keeps the PRA alive. If the FAA were not counting on PRA involvement, who knows what they would decide to do instead! We would not accomplish nearly what we are able to accomplish if we were individual manufacturers speaking in many tongues. The PRA is really the gyroplane communities voice to the world. Long live the PRA - we need the PRa more than you might think!

- Greg
 

PW_Plack

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To be fair, it is the manufacturer's responsibility to petition the FAA for these exemptions - the PRA cannot do that for them...

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.
 

Russ Hobbs

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Greg and others, looking for input before I submit

FAA representatives

I am the owner of a 2-place Greon Brothers Sparrow hawk Gyroplane. It is a factory designed kit plane meeting the 51% rule for amateur built flying craft. I have reasonable mechanical skills and abilities, never the less this craft will require all my abilities to build a functionally safe machine.

For those of us with a lifelong desire to fly, the gyroplane offers the freedom to fly and enjoy the sport, but we are extremely limited by the necessity to build our own craft. Those of us with limited time and/or building experience often give up from the frustration and/or fear of flying an unproved design.

Finally, we have proven designs by well-established builders. These craft are factory built complying with industry standards, meeting known safety criteria.

I encourage you to look favorably on adopting the Magni Gyro, the Sport Copter and the Autogiro Gmbh (MT03) rotorcraft. These aircraft represent the future of the light sport gyroplane industry, providing the catalyst for even higher standards of excellence, in a highly additive sport.

My sincere appreciation for your consideration in this matter.
 
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alain

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Gents

For us, as one of the future providers of ready-to-fly gyro, this seems to be agreat step forward. My question is:

Do you believe that possible comments by pilots not residing in the US, not being US citizens, would help ?

If so, I'll try to attract some of them, but this being a national issue, I prefer to ask you before doing anything.

Thanks

Alain Lederer
[email protected]
www.phenix.aero
 

theschultz

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Plack has a point. PRA is an organization that can speak for the Gyroplane enthusiast's behalf. We have no LSAs I am aware of at all!
 

GyroRon

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Thanks Greg, I feel better about the rating now, and will proceed as planned!
 

gyrogreg

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Greg and others, looking for input before I submit

FAA representatives -----

Russ, Sounds fine, but don't leave out GBA (Sparrow Hawk) or Xenon. Approval of an exemption gives them the option too to build sell fully-built if they can meet the standards. The FAA is considering their petitions at the same time. - Greg
 

gyrogreg

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Gents

For us, as one of the future providers of ready-to-fly gyro, this seems to be agreat step forward. My question is:

Do you believe that possible comments by pilots not residing in the US, not being US citizens, would help ?

If so, I'll try to attract some of them, but this being a national issue, I prefer to ask you before doing anything.

Thanks

Alain Lederer
[email protected]
www.phenix.aero

Alain, the FAA will accept and consider comments from anywhere in th world - they are being asked to consider gyros from outside the U.S. If you could ad some perspective and experience in flying any of these models, it should certainly help. - Greg
 
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