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Aero Sports Connection, Inc.

231 SW Bonanza Glen Lake City, FL 32025

269

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10/25/2016 Extension of Exemption 9785 C (Ref FAA

- 2001

- 10583)

Federal Aviation Administration 800 Independence Ave SW

Washin gton, DC 20591

Subject: Request for Extension of Exemption 9785c to 14 CFR 103.1 to Allow Qualified ASC members to Operate Ultralight Vehicles With Another Occupant.

This is a formal request for extension of exemption 9785c which is an exemption to 14

CF R 103.1a such that ASC recognized pilots may operate tandem ultralight vehicles for purposes of sport, recreation and o ther purposes. Exemption 9785c applies to vehicles that in all ways meet 14 CFR 103 except that the additional occupant is

harnessed to the craft or pilot. The issues that made exemption 9785c appropriate at

its initial release remain active.

ASC is a national non

- profit tax

- exempt corporation, which supports aviation safety and development through programs of registration, training and education. ASC covers all types of powered and unpowered aviation. With a national magazine, an existing instructor network, and vehicle registration, ASC is uniquely defined as the broadest most active organization directly supporting light aviation in the United States.

Sport Pilot and Light

- Sport Aircraft do not cover these issues

ASC has been involved in the development of Sport Pilot and Light

- Sport Aircraft from the beginning. Throughout this process, it has been the FAA position that light aircr aft that meet 14 CFR 103 except there is a student/passenger harnessed to the craft should not be part of Sport Pilot. To that end, the community has been developing an ASTM set of standards to provide a structure for both the qualification of pilots and the administration of the program. The ASTM standards are not complete.

When these standards are complete, they will supplant this exemption. However, the231 SW Bonanza Gln 269

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standards are not now complete and will not be done before the existing exemption 9785 expires. W e are depending on those FAA agreements to now release an appropriate extension to further the process.

This exemption is not the old two

- place exemption. It does not address aircraft that weigh more than 254 lb. This specifically addresses only the para glider, powered paraglider, hang glider and powered hang glider types that cannot and will not be serviced by the Sport

- Pilot/Light

- Sport Aircraft rules.

The community has now depended on this approach such that there is no alternative. The January 31, 2 008 end date for bringing in existing fleet aircraft is past. That means this plan is locked in place. Part of that plan is releasing a renewal of this exemption to continue operation in the near term. Therefore, we are submitting this request of exempt ion renewal.

One F iel d I ssue

There is no accepted standard definition for “ foot launched ” vehicles. They are not

defined in 14CFR1 or 14CFR103. This has lead to difficulties i n the field. ASC

recommend s that

, for this exemption only, the definition sho uld read:

“Foot L aunch

– a vehicle th at has documented successful takeoff and landing relying on the pilots legs

, only”

We believe this will clear up issues in the field. Given this is accepted, ASC will require

instructors to have written documenta tion of compliance.

Equivalent safety

The existing exemption 9785C has demonstrated equivalent safety as a result of programs of training, flight requirements, dual evaluations of instructors and examiners, documented Practical Test Standards and instru ctor peer review processes. This is supported by national tracking of instructors.

Request Not to Publish the Summary Under 14 CFR 11.87

We further request that consideration be given to non

- publication of the summary of this petition based on 14 CFR 11 .87 which recognizes granting of similar requests and231 SW Bonanza Gln 269

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the pre

- planning process that have set this path before us.

Summary :

Request for Extension of Exemption 9785C to 14 CFR 103.1 to Allow Qualified ASC members to Operate Ultralight Vehicles With Anothe r Occupant.

If there any other questions, please feel free to contact me as shown on the letter

head.

Sincerely, 

## Jim Stephenson

Jim Stephenson

CEO/President Aero Sports Connection.