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Aero Sports Connection, I nc. 231 SW Bonanza Glen Lake City , FL 32025 269
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- 1466 kimojim@aol.com 10/23/2014 Extension of Exemption 9785 Federal Aviation Administration 800 Independence Ave SW Washington, DC 20591 **Subjec t:**  Request for Extension of Exemption 9785b to 14 CFR 103.1 to Allow Qualified ASC members to Operate Ultralight V ehicles W ith Another Occup ant. This is a formal request for extension of exemption 9785b 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 o ther purposes. Exemption 9785b 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 9785b appropriate at it s 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 cover s all types of powered and unpowered aviation. W ith 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 S tates. **Sp ort Pilot and Light**  **- Sp**  **ort Ai**  **rcraf t do not cov**  **er these issues** ASC has been involved in the development of S port Pilot and Light
- Sp ort Aircraf t from the beginning. Throughout this process, it has been the F AA position that light aircraft that meet 14 CFR 1 03 except there is a student/p assenger harnessed to the craft should not be p art of S port Pilot. T o 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 st andards are not complete. Wh en these standards are complete, they will supplant this exemption. However , the231 SW Bonanza Gln 269
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st andards are not now complete and will not be done before the existing exemption 9785 expires. We are depending on tho se F AA 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 paragl ider , hang glider and powered hang glider types that cannot and will not be serviced by the S port - Pilot/Light
- Sp ort Aircraf t rules. The community has now depended on this approach such that there is no alternative. The January 31, 2008 end date for bring ing 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. **In the P ublic Interest**  This request has been demonstrated to be in the public interest. W ithout this exemption many pilots will be unable to continue operation while having followed F AA direction not to come under S port - Pilot/Light
- Sp ort Aircraf t. This exemptio n is the only alternative. **Equiv alent safety**  The existing exemption 9785b has demonstrated equivalent safety as a result of programs of training, flight requirements, dual evaluations of instructors and examiners, documented Practical T est S tandards and instructor peer review processes. This is supported by national tracking of instructors. **Request Not to Publish the Summary Under 14 CFR 1**  **1.87** We further request that consideration be given to non
- publication of the summary of this petition based on 14 CFR 1 1.87 which recognizes granting of similar requests and the pre
- planning process that have set this p ath before us.231 SW Bonanza Gln 269
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**Summary** : Request for Extension of Exemption 9785b to 14 CFR 103.1 to Allow Qualified ASC members to Operate Ultralight V ehicles W i th Another Occup ant. If there any other questions, please feel free to contact me as shown on the letter head. Sincerely , 

## Jim Stephenson Jim S tephenson CEO/President Aero S ports Connection.