Help with FAA glider exemption petiton

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

Just for clarification, single seat jets are exempt from the checkride requirement. It's FAR 61.58, if you're interested.




On Tuesday, October 16, 2012 1:49:21 PM UTC-6, (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

Here is the FAR in just in case your FAR/AIM in not sitting next to your keyboard

ed note: The first sentence says:"requiring more than one pilot flight crewmember" which would make every glider I know of exempt from this section; Nor do I see any references to "turbine". Is 14CFR61.58 the correct section?


§ 61.58 Pilot-in-command proficiency check: Operation of aircraft requiring more than one pilot flight crewmember.

(a) Except as otherwise provided in this section, to serve as pilot in command of an aircraft that is type certificated for more than one required pilot flight crewmember, a person must—

(1) Within the preceding 12 calendar months, complete a pilot-in-command proficiency check in an aircraft that is type certificated for more than one required pilot flight crewmember; and

(2) Within the preceding 24 calendar months, complete a pilot-in-command proficiency check in the particular type of aircraft in which that person will serve as pilot in command.

(b) This section does not apply to persons conducting operations under subpart K of part 91, part 121, 125, 133, 135, or 137 of this chapter, or persons maintaining continuing qualification under an Advanced Qualification program approved under subpart Y of part 121 of this chapter.

(c) The pilot-in-command proficiency check given in accordance with the provisions of subpart K of part 91, part 121, 125, or 135 of this chapter may be used to satisfy the requirements of this section.

(d) The pilot-in-command proficiency check required by paragraph (a) of this section may be accomplished by satisfactory completion of one of the following:

(1) A pilot-in-command proficiency check conducted by a person authorized by the Administrator, consisting of the maneuvers and procedures required for a type rating, in an aircraft type certificated for more than one required pilot flight crewmember;

(2) The practical test required for a type rating, in an aircraft type certificated for more than one required pilot flight crewmember;

(3) The initial or periodic practical test required for the issuance of a pilot examiner or check airman designation, in an aircraft type certificated for more than one required pilot flight crewmember; or

(4) A military flight check required for a pilot in command with instrument privileges, in an aircraft that the military requires to be operated by more than one pilot flight crewmember.

(e) A check or test described in paragraphs (d)(1) through (d)(4) of this section may be accomplished in a flight simulator under part 142 of this chapter, subject to the following:

(1) Except as provided for in paragraphs (e)(2) and (e)(3) of this section, if an otherwise qualified and approved flight simulator used for a pilot-in-command proficiency check is not qualified and approved for a specific required maneuver—

(i) The training center must annotate, in the applicant's training record, the maneuver or maneuvers omitted; and

(ii) Prior to acting as pilot in command, the pilot must demonstrate proficiency in each omitted maneuver in an aircraft or flight simulator qualified and approved for each omitted maneuver.

(2) If the flight simulator used pursuant to paragraph (e) of this section is not qualified and approved for circling approaches—

(i) The applicant's record must include the statement, “Proficiency in circling approaches not demonstrated”; and

(ii) The applicant may not perform circling approaches as pilot in command when weather conditions are less than the basic VFR conditions described in §91.155 of this chapter, until proficiency in circling approaches has been successfully demonstrated in a flight simulator qualified and approved for circling approaches or in an aircraft to a person authorized by the Administrator to conduct the check required by this section.

(3) If the flight simulator used pursuant to paragraph (e) of this section is not qualified and approved for landings, the applicant must—

(i) Hold a type rating in the airplane represented by the simulator; and

(ii) Have completed within the preceding 90 days at least three takeoffs and three landings (one to a full stop) as the sole manipulator of the flight controls in the type airplane for which the pilot-in-command proficiency check is sought.

(f) For the purpose of meeting the pilot-in-command proficiency check requirements of paragraph (a) of this section, a person may act as pilot in command of a flight under day VFR conditions or day IFR conditions if no person or property is carried, other than as necessary to demonstrate compliance with this part.

(g) If a pilot takes the pilot-in-command proficiency check required by this section in the calendar month before or the calendar month after the month in which it is due, the pilot is considered to have taken it in the month in which it was due for the purpose of computing when the next pilot-in-command proficiency check is due.

[Doc. No. 25910, 62 FR 40899, July 30, 1997, as amended by Amdt. 61–109, 68 FR 54559, Sept. 17, 2003; Amdt. 61–112, 70 FR 54814, Sept. 16, 2005]

Sorry Todd, but you're wrong. Maybe you're using an older version of FAR 61.58. This change is only about a year old.

Here's the current wording of the heading of the section:

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

It's the words "OR turbojet powered" that make it apply to single pilot jets. It's the word aircraft (not airplane) that makes it apply to gliders.

I have the checkride endorsement in my logbook. This has also become a VERY big deal in the jet warbird community, since there are only 7 designees that can perform this checkride. FAA has not allowed designees to perform the jet glider checkride. Only an actual FAA examiner.

Bob

On Tuesday, October 16, 2012 6:38:08 PM UTC-6, Todd wrote:
Here is the FAR in just in case your FAR/AIM in not sitting next to your keyboard



ed note: The first sentence says:"requiring more than one pilot flight crewmember" which would make every glider I know of exempt from this section; Nor do I see any references to "turbine". Is 14CFR61.58 the correct section?





§ 61.58 Pilot-in-command proficiency check: Operation of aircraft requiring more than one pilot flight crewmember.



(a) Except as otherwise provided in this section, to serve as pilot in command of an aircraft that is type certificated for more than one required pilot flight crewmember, a person must—



(1) Within the preceding 12 calendar months, complete a pilot-in-command proficiency check in an aircraft that is type certificated for more than one required pilot flight crewmember; and



(2) Within the preceding 24 calendar months, complete a pilot-in-command proficiency check in the particular type of aircraft in which that person will serve as pilot in command.



(b) This section does not apply to persons conducting operations under subpart K of part 91, part 121, 125, 133, 135, or 137 of this chapter, or persons maintaining continuing qualification under an Advanced Qualification program approved under subpart Y of part 121 of this chapter.



(c) The pilot-in-command proficiency check given in accordance with the provisions of subpart K of part 91, part 121, 125, or 135 of this chapter may be used to satisfy the requirements of this section.



(d) The pilot-in-command proficiency check required by paragraph (a) of this section may be accomplished by satisfactory completion of one of the following:



(1) A pilot-in-command proficiency check conducted by a person authorized by the Administrator, consisting of the maneuvers and procedures required for a type rating, in an aircraft type certificated for more than one required pilot flight crewmember;



(2) The practical test required for a type rating, in an aircraft type certificated for more than one required pilot flight crewmember;



(3) The initial or periodic practical test required for the issuance of a pilot examiner or check airman designation, in an aircraft type certificated for more than one required pilot flight crewmember; or



(4) A military flight check required for a pilot in command with instrument privileges, in an aircraft that the military requires to be operated by more than one pilot flight crewmember.



(e) A check or test described in paragraphs (d)(1) through (d)(4) of this section may be accomplished in a flight simulator under part 142 of this chapter, subject to the following:



(1) Except as provided for in paragraphs (e)(2) and (e)(3) of this section, if an otherwise qualified and approved flight simulator used for a pilot-in-command proficiency check is not qualified and approved for a specific required maneuver—



(i) The training center must annotate, in the applicant's training record, the maneuver or maneuvers omitted; and



(ii) Prior to acting as pilot in command, the pilot must demonstrate proficiency in each omitted maneuver in an aircraft or flight simulator qualified and approved for each omitted maneuver.



(2) If the flight simulator used pursuant to paragraph (e) of this section is not qualified and approved for circling approaches—



(i) The applicant's record must include the statement, “Proficiency in circling approaches not demonstrated”; and



(ii) The applicant may not perform circling approaches as pilot in command when weather conditions are less than the basic VFR conditions described in §91.155 of this chapter, until proficiency in circling approaches has been successfully demonstrated in a flight simulator qualified and approved for circling approaches or in an aircraft to a person authorized by the Administrator to conduct the check required by this section.



(3) If the flight simulator used pursuant to paragraph (e) of this section is not qualified and approved for landings, the applicant must—



(i) Hold a type rating in the airplane represented by the simulator; and



(ii) Have completed within the preceding 90 days at least three takeoffs and three landings (one to a full stop) as the sole manipulator of the flight controls in the type airplane for which the pilot-in-command proficiency check is sought.



(f) For the purpose of meeting the pilot-in-command proficiency check requirements of paragraph (a) of this section, a person may act as pilot in command of a flight under day VFR conditions or day IFR conditions if no person or property is carried, other than as necessary to demonstrate compliance with this part.



(g) If a pilot takes the pilot-in-command proficiency check required by this section in the calendar month before or the calendar month after the month in which it is due, the pilot is considered to have taken it in the month in which it was due for the purpose of computing when the next pilot-in-command proficiency check is due.



[Doc. No. 25910, 62 FR 40899, July 30, 1997, as amended by Amdt. 61–109, 68 FR 54559, Sept. 17, 2003; Amdt. 61–112, 70 FR 54814, Sept. 16, 2005]

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.

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)

§ 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