A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs, CO 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

Fax: 719

- 632

- 6417

www.ushpa.aero U.S. Department of Transportation

Docket Operations, M

- 30

West Building ground floor

1200 New Jersey Avenue, SE

Washington, DC 20590

March 20 th , 2014

RE: Request for Extension of Exemption No. 4144O

Office of the Chief Counsel:

The United States Hang Gliding and Paragliding Association (USHPA) hereby petitions for renewal

of Exemption number 4144O, to be identified as 4144P, to continue to allow unpowered ultralight

vehicles to be towed aloft by USHPA tow

- endorsed ultralight pilots with powered ultralights for

recreational and/or instructional purposes only.

Comments in Support of the Request

Exemption number 4144 was originally granted in 1984. Renewal has been continuously approved

since that time, most recently in 2012. Aerotowing is a vital component of our sport, and is the

primary or only launch method available to hang glider pilots in many parts of the country. Over the

years, thousands of aerotow flights have been pe rformed by USHPA tow

- endorsed powered

ultralight pilots operating under this exemption. Since its renewal in 2012, there have been no

incidents involving activities involving Part 103 ultralights towing hang

- gliders.

While many hang gliding aerotow fligh ts are performed each year using light sport aircraft as tugs,

use of true Part 103 ultralights as tugs continues to be a viable and active segment of our sport.

There are several independent efforts underway to further develop the viability of Part 103

co mpliant aircraft as aerotowing platforms.

As part of the exemption renewal process, the USHPA has kept the FAA informed and updated on

the safety record of hang glider aerotowing operations. Our letter of request to renew exemption

4144M, dated March 24, 2012, reported a history of ten incidents related to the aerotowing of hang

gliders, spanning the years from 1985 through 2011. Of those, only the one in 1985 involved the use

of a true 103 compliant ultralight as a tug; the other nine incidents occurred when a light sport

aircraft or heavy two

- place ultralight (no longer viable) was used as a tow plane. There have been no

incidents involving Part 103 compliant ultralights as a tug since then. No fatal hang gliding aerotow

accidents involving the use of a true ultralight tug operating under Exemption #4144 have occurred

since 1985.

The overall reliability and safety of the aerotow method for launching of hang gliders is well

proven, as shown by our overall record, and has increased substantially since its inception nearly 40

years ago. USHPA's operating guidelines governing this practice represent a complete program for

aerotowing safety. The association's efforts to continuously improve its aerotow operation standards,

disseminate this information, and as sure and monitor its adoption are comprehensive and designed

to increase the safety and viability of the sport. Based on this safety record, the needs of our

membership, and the effective structure of our existing USHPA aerotow safety program, we request

t he renewal of Exemption 4144 to continue to allow towing of unpowered ultralights by powered

ultralights for recreational and/or instructional purposes only.A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs, CO 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

Fax: 719

- 632

- 6417

www.ushpa.aero Summary for the Federal Record

The United States Hang Gliding and Paragliding Association (USH PA) requests an extension and

revision of Exemption 4144O into Exemption 4144P, to continue to allow unpowered ultralight

vehicles to be towed aloft by USHPA tow

- endorsed ultralight pilots with powered ultralights for

recreational and/or instructional purp oses only.

Respectfully submitted,

Martin Palmaz

Executive Director

United States Hang Gliding and Paragliding Association, Inc.

Phone: 719

- 632

- 8300

Fax: 719

- 632

- 6417

Email: executivedirector@ushpa.aero

cc: Rich Hass, President

Ke n Grubbs, Vice President

Bill Bolosky, Secretary

Mark Forbes, Treasurer

Felipe Amunategui, Regional Director, Chair for the Towing committee

Greg Kelley, Chair for the Safety and Training committee

attachments: FAA Towing Exemption 4144P (draft)A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs, CO 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

Fax: 719

- 632

- 6417

www.ushpa.aero FAA TOWING EXEMPTION No. 4144 P (draft)

Pursuant to the authority contained in Sections 313(a) and 601(c) of the Federal Aviation Act of

1958, delegated to me by the Administrator (14 CFR 11. 53), the individuals authorized by the

USHPA are granted an exemption for the FAR's to the extent necessary to allow unpowered

ultralight vehicles to be towed aloft by USHPA tow

- endorsed ultralight pilots with powered

ultralights for recreational and/or in structional purposes only.

This exempti on terminates on May 31st

, 2016 , unless sooner superseded or rescinded.

(name)

Director, Flight Standards Service

Issued in Washington, D.C. on October 25, 1984 and renewed on (date)

The exemption is subject to the following limitations regarding unpowered ultralight vehicles to be

towed aloft by USHPA tow

- endorsed ultralight pilots with powered ultralights for recreational

and/or instructional purposes only:

1. Each operation must comply with all sections of 14 CFR Part 103 except 103.1(b).

2. No charge, assessment or fee may be made for the operation of the towing ultralight except the

actual expenses of the specific flight.

3. Both pilots on both ultralights must possess a current pilot rating issued by the USHPA.

4. For identification purposes, the USHPA shall issue an individual authorization to each person

allowed to conduct operations under this exemption. Each authorization shall include an

identification number and a copy of this exemption. The USHPA shall h ave a procedure to rescind

this authority when needed.

5. Each individual who operates an ultralight vehicle under the authority of this exemption must be

familiar with the provisions contained herein and must have in his or her personal possession a copy

of the authorization issued by the USHPA and a copy of this exemption. These documents shall be

presented for inspection upon request by the FAA.

6. Operations conducted under this exemption shall be in accordance with the safety and

certification rules an d guidelines, as amended, established by the USHPA, including those specified

in paragraphs 1 through 12 in the petitioners supportive information, as follows:

The following requirements must be adhered to:

1. Both vehicles (powered and unpowered ultralig ht) must meet the vehicle standards of Part 103.

2. Both vehicles must meet the requirements of the USHPA Towing standards.

3. While towing, both vehicles may be used for recreational and/or instructional purposes only.

4. The pilot of the powered ultralig ht vehicle must possess and have in his possession a current

A erotow Vehicle P ilot appointment issued by the USHPA.

5. The pilot of the unpowered ultralight vehicle must possess and have in his possession a current

pilot rating issued by the USHPA, with A e rotow special skill endorsement. This rating shall be at

least a USHPA Intermediate (level 3) for a recreational pilot and a USHPA Novice (level 2) for a

student pilot under the supervision of a USHPA certified instructor.

6. The towed unpowered ultralight (hang glider) may be used for two place instructional purposes if

the instructor possesses a current USHPA instructor rating and is operating under the conditions of

the two

- place exemption.

7. Prior to a student's first flight in a towed unpowered ultral ight, the pilot of the powered ultralight

and the instructor must inform the student that instruction under tow is conducted under an

exemption granted to the USHPA by the FAA.

8. The instructor must keep written record of all operations conducted under th is exemption. The

record shall include the student's name, the date and the location of the instruction. The record must

be maintained for 12 calendar months. The instructors shall present this record for inspection upon

reasonable request by the USHPA o r the FAA.

9. The instructor shall notify the USHPA within 30 days of any accident occurring while operating

under this exemption. This information shall be made available upon reasonable request by the

FAA.A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs, CO 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

Fax: 719

- 632

- 6417

www.ushpa.aero 10. The structural integrity of the tow hitch an d tow line must be substantiated in accordance to

USHPA standards and recorded in the tow launch vehicle records by the owner.

11. To qualify for ultralight towing operations under this exemption, the operational capabilities of

the powered ultralight to s atisfactorily tow and release an unpowered ultralight must be initially

demonstrated in an assigned test area under actual operational conditions to a USHPA observer and

be duly recorded in the tow vehicle records.

12. Both towed and towing pilots must obe y operational procedures set forth in the USHPA Towing

standards.