Help with FAA glider exemption petiton

On Tuesday, October 16, 2012 12:49:21 PM UTC-7, (unknown) wrote:
Hello fellow soaring pilots,



I'm asking for your help in receiving an exemption to new FAA regulations that require a yearly FAA checkride to fly a jet sailplane.





Here's the story:

In 2011, FAA issued new regulations regarding training for pilots of turbojet powered aircraft. These new regulations require pilots of all turbine powered, single pilot aircraft to pass a yearly proficiency check. This new regulation affects my two seat turbine powered glider. In order to stay current , each person who flies it must pass a check ride administered by an FAA examiner once a year. This checkride is the equivalent of a type rating re-currency checkride.



This regulation was obviosly aimed at the new crop of very light jets (VLJs), such as the Eclipse 500 and Cessna Mustang, to ensure that pilots maintain competency with their complex systems. This is probably a valid concern. However, the requirement to take an annual FAA check ride should not extend to a glider, which only uses the turbine engine for takeoff or self-retrieve and operates at essentially the same weight, speeds and altitudes as its piston- or non-powered counterparts.



I believe this inclusion was inadvertent. This belief is supported by the fact that the rule began with the words 'turbine powered airplanes', thus excluding gliders. It wasn't until the final rule was printed in the Congressional Record that the glider inclusive words 'turbine powered aircraft' appear. Even then, the summary chart printed along with final rule still uses the word 'airplane'.



I have applied for an exemption to this rule for my turbine powered TST-14 BonusJet. The exemption process requires FAA to open the proposal for public comment. FAA is required to consider and respond to these comments before making a decision.



If you would like to support this effort, please go to this link and click the "Comment Now!" button:



http://www.regulations.gov/#!documen...2012-0970-0001





To be effective, these comments should be passionate, but also professional and courteous. Some of the items to mention might be:



Your own experience with the TST-14 (don't use the name 'BonusJet'), other motorgliders and unpowered gliders.



Include any specific qualifications that may add credibility to your comment (engineer, flight instructor, high-time pilot, lots of turbine time, etc.).



The excellent safety record of turbine gliders.



The simplicity of operating the TST-14's engine systems (much simpler than conventional motorgliders, which only require an instructor endorsement).



The very normal operating parameters (same takeoff and landing speeds, same weight, same altitudes as conventional gliders)



The improved safety (no towplane or ropes, prevention of off-airport landings, excellent climb performance - especially at high density altitude airports, low drag with engine extended, etc).



The probable inadvertent, last-minute addition of the word 'aircraft' in place of 'airplane', and that this change was made after the NPRM comment period closed, with no way for the public to comment on the subject of 'non-airplane' turbine powered aircraft. This wording change may be in violation of the Administrative Procedures Act and FAA policy.



The improvement in safety that would result if more turbine powered sailplanes were built, and the fact FAA checkrides are a hindrance to acceptance by sport and recreational pilots.



An equivalent level of safety will be maintained. No increased risk to the public will result if this exemption is granted.



Anything else you think should be said about the matter.



I'm not sure when the comment period ends, but they posted it long before sending me verification of receipt, so we may not have much time. Please take a few minutes to make a difference in the future of soaring. If they receive no comments, they can act on the assumption that no one cares. Thanks.



Blue skies,



Bob Carlton

I submitted this comment:

I am a glider pilot with 3,600 hr of PIC time. I am also a licensed power pilot (SEL). I am also a motorglider pilot with 2000 hr of PIC time. While I do not fly turbine powered aircraft, either airplanes or gliders, I regard the annual recertification requirement for turbine powered gliders to be unnecessarily onerous. This is obviously intended for very light jets, not gliders. While I value the training I received to fly powered airplanes, this training bore very little similarities to the issues involved in flying motorgliders. I shudder to think of the burden that would be placed on me if I had to do a similar recertification EVERY YEAR to fly my motorglider! This would not add to my safety, but may make me stop flying altogether! Fix this unintentional regulatory burden.

Tom

On 10/16/2012 8:02 PM, 2G wrote:


I submitted this comment:

I am a glider pilot with 3,600 hr of PIC time. I am also a licensed
power pilot (SEL). I am also a motorglider pilot with 2000 hr of PIC
time. While I do not fly turbine powered aircraft, either airplanes
or gliders, I regard the annual recertification requirement for
turbine powered gliders to be unnecessarily onerous. This is
obviously intended for very light jets, not gliders. While I value
the training I received to fly powered airplanes, this training bore
very little similarities to the issues involved in flying
motorgliders. I shudder to think of the burden that would be placed
on me if I had to do a similar recertification EVERY YEAR to fly my
motorglider! This would not add to my safety, but may make me stop
flying altogether! Fix this unintentional regulatory burden.

I submitted something similar, modeled after Tom's:

I am a glider pilot with 6500 hr of PIC time in powered and unpowered
gliders. I do not currently fly turbine powered gliders, but I plan to
do so in a year or two.

The annual recertification requirement for turbine powered gliders,
which are simpler to operate than most piston powered self-launching
gliders, will only add expense and not safety; in fact, by discouraging
pilots from using the simpler turbojet powered designs, safety may
actually be reduced.

This is requirement, apparently intended for very light jets, makes
sense for them, but not for gliders, which use the engine briefly, and
otherwise fly like most gliders.

Please change the rule to apply to "airplanes" and not "aircraft", so
that gliders are no longer included.


--
Eric Greenwell - Washington State, USA (change ".netto" to ".us" to
email me)

My comment:

I am an 11,000 hour ATP rated pilot with commercial ASEL, rotorcraft, and glider privileges. I am also type rated in LR-Jet, D-328Jet, MiG-15 and MiG-17 aircraft. I feel that the requirement to undergo an annual proficiency check in a jet powered glider is unnecessary and creates an undo burden on the limited FAA resources. The difference in risk to the public between a normal glider and a turbine powered glider would be negligible. There is no speed difference between the two aircraft and the amount of fuel carried in a turbine powered glider is generally less than 20 gallons. This limited risk would not justify the high level of FAA surveillance through annual proficiency check.

§ 61.58 Pilot-in-command proficiency check: Operation of an aircraft
that requires more than one pilot flight crewmember or is turbojet-
powered.

We could almost argue that since it is a glider, it is not a "turbojet-
powered aircraft." An engine in a glider is used as a launch method,
not "power," as if it had the latter it would be an "airplane"

Maybe too clever......The jet sustainers certainly hinge on the
outcome here

John Cochrane

On Oct 17, 2:04*pm, John Cochrane wrote:
§ 61.58 * Pilot-in-command proficiency check: Operation of an aircraft
that requires more than one pilot flight crewmember or is turbojet-
powered.

We could almost argue that since it is a glider, it is not a "turbojet-
powered aircraft." *An engine in a glider is used as a launch method,
not "power," as if it had the latter it would be an "airplane"

Maybe too clever......The jet sustainers certainly hinge on the
outcome here

John Cochrane

Not much use trying to apply logic to this. FAA has, for some bizare
reason decided that turbojets and turbofans require some special skill
set. In fact, modern electronically controlled turbojets and
turbofans are incredibly simple to operate as compared to recips with
manually controlled propeller pitch, fuel flow, cooling, and starting.

The only reason to assume turbofans and tubojets require a special
skill set is that they are typically higher performance that recips.
Perhaps the main reason to oppose the rule is that a turbojet equipped
self launch, or sustainer, glider has no higher performance than the
same glider without the motor. The Vne is no greater and the climb
rate under power is far less than can be achieved on a winch launch or
even behind a high powered tug.

Even if an exemption is granted, I suspect that the current
requirement for a type rating will kill any introduction of turbojet
powered gliders in USA. Again the FAA failed to understand that a
turbojet is far easier to manage, and likely far more reliable, than a
recip.

Andy

Andy,

Correct on all points except one. The climb rate of my two seat turbine glider is NOT less than a high powered tug. I easily out-climb our club's 250 HP Pawnees and I'd bet my turbine Salto would probably out-climb a winch.

Bob

On Wednesday, October 17, 2012 5:13:09 PM UTC-6, Andy wrote:
On Oct 17, 2:04*pm, John Cochrane wrote:

§ 61.58 * Pilot-in-command proficiency check: Operation of an aircraft

that requires more than one pilot flight crewmember or is turbojet-

powered.



We could almost argue that since it is a glider, it is not a "turbojet-

powered aircraft." *An engine in a glider is used as a launch method,

not "power," as if it had the latter it would be an "airplane"



Maybe too clever......The jet sustainers certainly hinge on the

outcome here



John Cochrane



Not much use trying to apply logic to this. FAA has, for some bizare

reason decided that turbojets and turbofans require some special skill

set. In fact, modern electronically controlled turbojets and

turbofans are incredibly simple to operate as compared to recips with

manually controlled propeller pitch, fuel flow, cooling, and starting.



The only reason to assume turbofans and tubojets require a special

skill set is that they are typically higher performance that recips.

Perhaps the main reason to oppose the rule is that a turbojet equipped

self launch, or sustainer, glider has no higher performance than the

same glider without the motor. The Vne is no greater and the climb

rate under power is far less than can be achieved on a winch launch or

even behind a high powered tug.



Even if an exemption is granted, I suspect that the current

requirement for a type rating will kill any introduction of turbojet

powered gliders in USA. Again the FAA failed to understand that a

turbojet is far easier to manage, and likely far more reliable, than a

recip.



Andy

On Saturday, October 20, 2012 6:27:22 AM UTC-7, wrote:
Andy,



Correct on all points except one. The climb rate of my two seat turbine glider is NOT less than a high powered tug. I easily out-climb our club's 250 HP Pawnees and I'd bet my turbine Salto would probably out-climb a winch.



Bob,

By "high powered tug" I was thinking of the SAIA-Marchetti SM.1019 (turbine Birddog), or an Ag-Cat. I need no special qualification to tow behind either. Can the Bonus Jet beat those with your normal reduced climb thrust, or even at max thrust?

In any event I still think the type rating remains the major obstacle to the introduction of turbine sustainers or self launch. If that was fixed the other requirement would look silly and would be more likely to go away.

Andy

Hi John,

I believe my exemption petition qualifies as 'almost arguing' that very point with FAA.

Bob

On Wednesday, October 17, 2012 3:04:00 PM UTC-6, John Cochrane wrote:
§ 61.58 Pilot-in-command proficiency check: Operation of an aircraft

that requires more than one pilot flight crewmember or is turbojet-

powered.



We could almost argue that since it is a glider, it is not a "turbojet-

powered aircraft." An engine in a glider is used as a launch method,

not "power," as if it had the latter it would be an "airplane"



Maybe too clever......The jet sustainers certainly hinge on the

outcome here



John Cochrane

On Wednesday, October 17, 2012 6:11:53 AM UTC+1, Eric Greenwell wrote:


I do not currently fly turbine powered gliders, but I plan to

do so in a year or two.




Do you, Eric? What might tempt you out of the ASH 26?

On 10/17/2012 10:39 AM, waremark wrote:
On Wednesday, October 17, 2012 6:11:53 AM UTC+1, Eric Greenwell
wrote:


I do not currently fly turbine powered gliders, but I plan to

do so in a year or two.

Do you, Eric? What might tempt you out of the ASH 26?

A turbine powered, self-launching DuckHawk (variously called "JetHawk"
or "Jet DuckHawk") would be very tempting. Two are under construction,
with first flights likely early next year. Power-on climb performance
should be awesome, but Windward hasn't released any performance figures
yet.

Other companies are planning, or at least contemplating, self-launching
jets, so I think there will be at least a couple opportunities to fly a
jet self-launcher in the next two years, so I hope it only takes logbook
endorsement to be legal.

--
Eric Greenwell - Washington State, USA (change ".netto" to ".us" to
email me)