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 20th, 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 performed 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 flights 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 

compliant 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 wellproven, 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 assure 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 

the 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 (USHPA) 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 purposes 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

Ken 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. 4144P (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 instructional purposes only.

This exemption 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 have 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 and 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 ultralight) 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 ultralight vehicle must possess and have in his possession a current 

Aerotow Vehicle Pilot 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 Aerotow 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 ultralight, 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 this 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 or 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 and 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 satisfactorily 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 obey operational procedures set forth in the USHPA Towing 

standards.