231 SW Bonanza Gln 269-209-1466 

Lake City, FL 32025 386-269-0469 fax

kimojim@aol.com www.aerosports.org

Aero Sports Connection, Inc.

231 SW Bonanza Glen

Lake City, FL 32025

269-209-1466

kimojim@aol.com

10/25/2016 Extension of Exemption 9785C (Ref FAA-2001-10583)

Federal Aviation Administration

800 Independence Ave SW

Washington, 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 

CFR 103.1a such that ASC recognized pilots may operate tandem ultralight vehicles 

for purposes of sport, recreation and other 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 aircraft 

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, the 
231 SW Bonanza Gln 269-209-1466 

Lake City, FL 32025 386-269-0469 fax

kimojim@aol.com www.aerosports.org

standards are not now complete and will not be done before the existing exemption 

9785 expires. We 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 paraglider, 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, 2008 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 exemption renewal.

One Field Issue

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

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

recommends that, for this exemption only, the definition should read: 

“Foot Launch – a vehicle that 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 documentation 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 instructor 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 and 
231 SW Bonanza Gln 269-209-1466 

Lake City, FL 32025 386-269-0469 fax

kimojim@aol.com www.aerosports.org

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 Another 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.