AFS-16-14096-E

October 28, 2016

 Exemption No. 11104A

 Regulatory Docket No. FAA-2013-0508

Mr. Edgar D. Pitman

Member/Manager

Pitman Air LLC

1840 Airport Blvd.

Red Bluff, CA 96080

Dear Mr. Pitman:

This letter is to inform you that we have granted your petition to extend Exemption No. 

11104. It transmits our decision, explains its basis, and gives you the conditions and 

limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated July 15, 2016, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Pitman Air LLC (Pitman) for an extension of Exemption No. 11104. That 

exemption from §§ 91.309(a)(2) and 91.309(a)(3) of Title 14, Code of Federal Regulations

(14 CFR) allows owners of the Dragonfly Special Light Sport Aircraft (SLSA) and 

Experimental Light Sport Aircraft (ELSA) aircraft certificated under §§ 21.190 and 

21.191(i)(1), manufactured by Pitman Air LLC, equipped with the Bailey Tow & Release 

System to tow aircraft and be in compliance with the issued operation limitations under 

§§ 91.327(a)(1) and 91.319(e)(1), as applicable. Operators of the Dragonfly aircraft that opt 

to utilize the Bailey Tow and Release System on their Dragonfly aircraft must follow the 

Conditions and Limitations of that exemption.

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Pitman.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 11104

remains valid with respect to this exemption and is in the public interest. Therefore, under the 

authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator 

has delegated to me, I grant Pitman Air LLC (Pitman) an exemption from 14 CFR 

§§ 91.309(a)(2) and 91.309(a)(3) to the extent necessary for owners of the Dragonfly SLSA 

and ELSA aircraft certificated under §§ 21.190 and 21.191(i)(1), manufactured by Pitman 

equipped with the Bailey Tow & Release System to tow aircraft and be in compliance with the 

issued operation limitations under §§ 91.327(a)(1) and 91.319(e)(1), as applicable. Operators 

of the Dragonfly aircraft that opt to utilize the Bailey Tow and Release System on their 

Dragonfly aircraft must follow the Conditions and Limitations of this exemption, subject to 

the conditions and limitations listed below.

Conditions and Limitations

1. The owner/operator will utilize the Bailey Tow and Release System only on the 

Pitman Air Dragonfly Light Sport Aircraft (LSA) certificated under §§ 21.190 and 

21.191(i)(1) of Title 14 Code of Federal Regulations.

2. The owner/operator will maintain and operate the tow hook assembly utilizing the 

Operation, Maintenance & Inspection Instructions for the Bailey Tow and Release 

System.

3. The information in the Dragon LSA maintenance manual and pilot operating 

handbook (POH) must meet the requirements of American Society for Testing and 

Materials (ASTM) standard F2245 Annex A1.1 through A1.7, when the aircraft is 

equipped for towing.

4. For tow operations, the Dragon LSA operator must meet the 100 hour inspection 

requirements of §§ 91.319(g)(1) or (g)(2), or 91.327(c)(1) or (c)(2), of Tile 14 Code of 

Federal Regulations as certificated.

5. A copy of this exemption must either be incorporated into the aircraft POH or carried 

on the aircraft while operating under this exemption.
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The Effect of Our Decision

This exemption terminates on November 30, 2018, unless sooner superseded or rescinded.

Sincerely,