Scott Barrett sent along this letter to Max Bishop:

Dear Mr. Bishop,

This letter is provided as feedback on the actions taken by CIVL under the
agenda of improving safety in hang gliding during 2009.

The following outlines the process that has been followed to date,:

CIVL, as a body, acted upon recommendations from DHV officials as well as CIVL
delegates and EHGU members. This has occurred at a political/representative
level, but not a technical level. We believe that the direction that has been
taken by CIVL is not the most productive, the most cost effective, or the
technically correct means to address safety issues.

CIVL previously formed a working group of pilots (but with only one qualified
technical expert). The working group was assigned to determine required
measurements (and their error bands) and the specific penalties for violations
to apply to pilots whose equipment exceeds those limits. CIVL officials then
inappropriately intervened and overturned the decisions on penalties made by the
working group.

At the 2009 Worlds the final rules promulgated by CIVL were withdrawn, given the
fact that they were made too late, just prior to the World Championships. The
actual penalties were then to be made at the discretion of the meet director
which was an excellent result. It turned out that no penalties for equipment
issues were required.

We believe that the effect of the new proposed rules (when and if they are
implemented) will be:

1) Discrimination against women (our smaller pilots) flying gliders certified to
DHV standards. The DHV standard is deficient for small gliders, resulting in a
decreased level of safety for pilots flying in the DHV certified configuration
and the decreased level of performance of small gliders.

2) Pilots and experts in the field have reported to the CIVL working group that
small gliders tuned to DHV certification are unsafe due to a reduction in
controllability.

3) The application of a manufacturers' safe setting to a small glider is
problematic in the short term as the data often does not exist. There must be a
path for small pilots to compete without the current rules exposing them to more
danger as our first concern and secondly, to avoid handicapping them.
Unfortunately, at present there are few small gliders that have used the
parallel path of using the Hang Gliding Manufacturers Association or BHPA design
standards (these are fair to small gliders and result in small gliders with good
pitch stability and controllability).

The scrutinizing procedures being applied does not guarantee safety as it does
not guarantee the pitch stability of a glider. Certified settings for washout
struts do not indicate that the pitching moments are also certified, as many
other factors of tuning are involved. Pilot education is the most successful
means of avoiding arbitrarily low strut settings or other dangerous adjustments.

There is plenty of motivation for pilots (of mid and large size gliders) to
comply with the rules, (there is little performance advantage for anyone who
does not comply) and it can be expected that educated pilots will do this as a
matter of course regardless of penalties being applied or not.

The most effective way to achieve better safety is looking at the problem more
holistically. The pilots understand what affects their safety the most and allow
the recommendations to come from the pilots, this will indicate the most
productive areas and methods to achieve better safety in competition.

Pilot technique has a huge impact on safety through pitch stability. Tumbling a
certified glider is easily achieved through use of inappropriate technique. Due
to the complexity of adjustments and the ineffectiveness of scrutinizing to
determine actual pitch stability (not strut settings), the most effective way to
address safety is by pilot education on technique and tuning. There are experts
that have volunteered their time for free to achieve this and they have been
quite successful in their education programs.

The Australian pilots request the following:

1) We want time for the manufacturers' safe settings to be developed and to be
applied to small gliders. We want a two year transition period to be applied
without penalties, to allow for the certification of new models of small gliders
as a part of the certification process. This means that the DHV certification
system, which does not allow for this, needs time to be changed. Or a parallel
path needs to be made into European markets using technically elegant design
standards such as the Hang Gliding Manufacturers Association design standard. A
transition period will allow this to occur without losing our small pilots (who
already include our minority of female pilots)

2) We want due process to be used in selecting the best pay-off activities to
achieve safety. We recommend that CIVL form a working group to determine the
areas to best achieve safety, this group needs to consist of competition pilots
and technical experts.

3) We recommend that technical matters be dealt with by (qualified) technical
committees within CIVL, as a part of due process the technical committee will
make recommendations to the delegates.

4) We want due process to be used in CIVL, for CIVL to follow their own
procedures, including following the recommendations of their working groups.

5) We want conflicts of interest of committee members in CIVL to be disclosed
and for CIVL to use an appropriate means to deal with conflicts that are
disclosed.

The aims of the recommendations made in this letter are to improve procedures
within CIVL to avoid technical decisions being made at a political level
(without technical validation). To ensure that the technical recommendations
made from within the CIVL working groups are transitioned into rules (where
those rules are accepted by the political level within CIVL).

Yours Sincerely

Australian Delegate CIVL