Dear FAA Administrator,

The United States Powered Paragliding Association requests an exemption to FAR Part 103.1 to allow for Tandem Training as described below. This would be in addition to our existing foot-launched exemption. We believe that we can improve the safety of powered paragliding and consequently the safety of aviation as a whole by increasing the education level of this segment. Having better-educated pilots equips them to avoid places and situations where they might put themselves and/or others at risk. After 6 years observing powered paragliding tandem training, here are some of the relevant observations: 1. There have been two fatalities that we're aware of, neither one was part of the USPPA program. Both were drowning's. One occurred in a wheeled craft and the other was foot launched. The type of launch was irrelevant to the fatal nature of the accidents. One was in an area that is not near water but the flight was taken to a river. 2. Water imposes the greatest fatal accident risk to the sport as a whole for both tandem and single place operations. 3. Foot launching a tandem is physically difficult and therefore many instructors will not do it. Of those that do, they aren't likely to do it in very light winds (the best times to fly) and/or with large or impaired students. 4. We have at least one reported injury of an instructor who was hurt when his student sat down early on the launch run. The instructor was out of commission for over 6 months with major leg injuries. 5. There are many reports of damaged equipment due to students either sitting down early or not running as necessary. 6. The overall safety of tandem powered paragliding, within the certified realm, is very good. 7. Having more pilots get airtime BEFORE going on their first solo is obviously advantageous and increasing access to this capability, by virtue of allowing it to be on wheeled craft, would be a benefit. 8. There are no existing LSA craft that offer the same control paradigm as powered paragliders (hand throttle and hand brake toggles). We believe we can improve the overall safety of the sport though by making tandem training more readily available. In consideration of the above, we propose the following. Wheels are allowed to support foot launchable powered paraglider tandem training units ( tandem units) during launch and landing as follows: 1. Foot launchable means that the powerplant is also used on existing production foot launched paramotor units. 2. Approved Vehicle Floatationis an auto-inflating device that works upon submersion in water and provides buoyancy of at least the weight of the tandem machine on which it is mounted and float it upright. This would provide excessive floatation by the amount of water displacement. 3. The tandem unit is equipped with Approved vehicle floatation if there is any overwater flight. 4. Existing rules for all tandems, including foot launch, will require that no flight be flown over water, beyond gliding distance to shore, unless the craft has Approved Vehicle Floatation andboth occupants are wearing US Coast Guard approved type III personal floatation devices.

5. The tandem unit must offer a control method identical to that used by at least 50% of powered paraglider units used for certification programs. That means hand throttle and hand controls to the wing. 6. The instructor will meet all the requirements of a tandem instructor with a wheel launch (WL) add on. 7. The tandem unit must have a label issued by the USPPA affixed in a location which is readily visible on the unit. The label must specify the following: 1. The unit meets the requirements of this exemption. 2. The unit is not certified by the FAA for anything other than for instructional purposes when used with two people. 3. The unit is not a registered aircraft.

Jeff Goin USPPA President