August 4, 2014

A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs , C O 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

F ax: 719

- 632

- 6417

www. ushpa.aero U.S. Department of Transportation Docket Operations, M

- 30 West Building ground floor

Room W12

- 140 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

RE: Request for Renewal of Exemption (Docket Number FAA

- 2002

- 13588)

No. 4721 M from Title 14 CFR ( FAR Section)

- 103.1 (a ) & (b)

The United States Hang Gliding and Paragliding Association, Inc., (USHPA) hereby petitions, pursuant to section 11.25 of the Federal Aviation Regulations , fo r an exemption from paragraph (a ) & (b) of FAR 103.1 as amended, so that the definition of “ultralight vehicle” will apply to the use of unpowered vehicles weighing 155 pounds or less to carry two USHPA

- rated occupants for the purpose of flight instruc tion and the development of advanced flying skills/training by

USHPA

- certified instructors.



# Comm ents In Support Of This Request

The USHPA believes that the quality of the education and the safety of hang glider and paraglider pilots are enhanced by permit ting the continuation of “in

- flight” instruction in two

- place hang gliders and paragliders . Two

- place flights have been conducted since the beginning of our sport

and the number of two

- place flights has increased substantially since the exemption was gran ted in

1983.

Two

- place instruction is especially helpful in developing proper control techniques, particularly stall recognition and stall recovery responses. It is an effective means for more experienced pilots to share their knowledge with junior pil ots who are transitioning to flying in more complex situations. It is also a very effective resource for familiarizing a pilot with a new flying site.

The USHPA is committed to enhancing the safety of two

- place hang gliding and paragliding

instruction an d operational standards. In the thirty

- one years since the original exemption was granted, the USHPA continues to research and develop two

- place instructional standards and to upgrade certification programs detailing proper two

- pla ce instructional techniq ues.

USHPA’s Hang Gliding and Paragliding Accident/Incident Review committees evaluate flying

related accidents and incidents for the purpose of enhancing the safety of the sport. The committees publish accident and incident reports and provide annual s ummaries detailing the causes of hang gliding and paragliding

- related incidents, accidents and fatalities in the Association’s monthly newsletter.

During the term of the current exemption, No. 4721M, there were no reported tandem accidents involving fatalities.

During the term of the current exemption, No. 4721M, there were 2 reported tandem accidents involving serious injury. Both incidents occurred during the landing approach during Tandem Instructional flights with the Tandem Instructor at the con trols. The first incident occurred when the tandem flight was subject to turbulence in the landing field while on final approach, resulting in a collision with a tree followed by a fall to the ground. The Tandem Instructor suffered injuries to his back. The Student Pilot was uninjured. The Tandem Instructor was an Advanced rated pilot with over 13 years of accident

- free flight experience, had demonstrated the special skills of landing in restricted landing fields and flying in turbulence, and had held a Tandem Instructor rating for 4 years. This accident is a reminder to our Tandem Instructors and Tandem Pilots to avoid landing in

known turbulent conditions.August 4, 2014

A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs , C O 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

F ax: 719

- 632

- 6417

www. ushpa.aero The second incident occurred when the tandem flight encountered wind gradient resulting

in a par tial collapse of the canopy at about 30 feet AGL, followed by an unexpected impact with the ground. This impact resulted in back injuries to both the Tandem Instructor and the Student Pilot. The Tandem Instructor was an Advanced rated pilot with

over four years of accident

- free flight experience. He was an active and avid pilot, with demonstrated skills in negotiating restricted landing fields and turbulence, and in flying

cross

- country. He received his Tandem Instructor rating a little over a year before the accident. This accident is a reminder to all pilots, even those with the experience and demonstrated skills of the Tandem Instructor involved in this accident, of the importance of predicting and recognizing wind gradient and taking appropriate preca utions against the known adverse affects that wind gradient can have on a flight.

USHPA continues to closely monitor two

- place instructional procedures to enhance safety and evaluate rules for the maintenance of a tandem rating. These policies are re

- eva luated during each exemption period.

The USHPA has effectively administered FAA exemption from FAR Part 103.1(a ) & (b) , which allows USHPA members to operate two

- place unpowered ultralight vehicles for flight instruction and pilot upgrade recreational f lying for over 31 years. The conduct of two

- place flight provides a

realistic environment that has proven to be a safer and more effective approach to hang gliding and paragliding instruction. The two

- place instructional capability provides a “hands

- on” training experience that facilitates a student’s transition to individual flight. It has also proven to be a valuable training asset for disseminating knowledge from experienced pilots to lesser

- experienced pilots during recreational tandem flights.

Th e USHPA hereby petitions for an e xtension for Exemption No. 4721M , as amended f rom FAR 103.1(a ) & (b) , and for the continuation of accepted USHPA two

- place ultralight administrative procedures.



# Comm ents In Support Of Attached Edits to Exemption

In order t o align terminology utilized in Exemption No. 4721, USHPA, and the Fédération Aéronautique Internationale (FAI), the attached edits are proposed for consideration.

Per the FAI, paragliders have been defined, and classified in competition, as Class 3 Han g Gliders since inception of the wing type. Due to the rapid growth in popularity of the wings and sport, USHPA believes this growing participant base should have clear terms through standardization across relevant documents, including the FAA Exemption No . 4721. Adding “(e.g. hang gliders and paragliders)” removes any potential confusion that may exist in terminology.

“Tandem” has been added before “Instructors” to align with USHPA’s requirement to obtain a Tandem Instructor rating prior to conducting ins tructional tandems. The edit aligns terminology with this exemption and long

- standing training requirements in USHPA documentation.

The last proposed edit, replacing “advanced hang gliding” with “Tandem Pilot,” clarifies USHPA’s rating requirement to conduct recreational tandems. The edit aligns terminology with this exemption and long

- standing training requirements in USHPA documentation.August 4, 2014

A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs , C O 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

F ax: 719

- 632

- 6417

www. ushpa.aero 

# S ummary for the Federal Register

The United States Hang Gliding and Paragliding Association (USHPA) petitions f or an extension of Exemption No. 4721M, as amended, from FAR 103.1(a ) & (b) , of the Federal Aviation Regulations so that the definition of “ultralight vehicle” will apply to the use of unpowered vehicles weighing 155 pounds or less to carry two USHPA

- rated occupants for the purpose of flight instruction and development of advance d flying skills/training by USHP A certified instructors. The conditions and reasons stated in the original petition upon which the exemption was initially granted remain unchanged.

Respectfully,

Martin Palmaz

Executive Director United States Hang Gliding and Paragliding Association, Inc. executivedirector@ushpa.aero

cc: Rich Hass, President Ken Grubbs, Vice President Bill Bolosky, Secretary Mark Forbes, Treasurer Paul Voight , Regional Director, Tandem C ommittee Chair Greg Kelley, Safety and Training C ommittee Chair

A ttachments: Proposed Text of FAA Tandem Exemption #4721N (draft)August 4, 2014

A 501 (C) (3) Corporation

PO Box 1330

Colorado Springs , C O 80901

- 1330

Tel : 800

- 616

- 6888 / 719

- 632

- 8300

F ax: 719

- 632

- 6417

www. ushpa.aero 

## Proposed Text of FAA Exemption #4721N

[This] exemption to § 103.1(a) and (b) of Title 14, Code of Federal Regulations allows USHPA to operate unpowered ultralight vehicles ( e

. g. hang gliders and paragliders ) weighing less than 155 pounds, with another occupant, for the purpose of sport, training,

or recreation.

Conditions and Limitations

1. Each operation must comply with all sections of Part 103, except § 103.1 (a).

2. For training purposes, this exemption applies only to flights for the purpose of giving

instruction in two

- place un powered ultralight vehicles from USHPA

- approved launch

sites.

3. Both occupants on all two

- place training flights must possess a current p ilot rating issued by the USHPA and at least one occupant must possess a current USHPA Tandem

I nstructor rating.

4. Prior to all two

- occupant training flights, the student must be informed that the flight is conducted under an exemption granted by the FAA and that the ultralight vehicle does not meet aircraft certification standards set forth by the FAA.

5. Both occupa nts on all two

- place flights, other than for training purposes, must possess

a current p ilot rating issued by the USHPA and at least one occupant must possess a

current Tandem Pilot rating issued by the USHPA.

6. 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 also have a procedure to rescind this authori ty when needed.

7. 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 USH PA and a copy of this exemption. These documents shall be presented for inspection upon request by the

FAA.

[This] extends the termination date of Exemption No. 4721, as amended, to October 31,

201 6 , unless sooner superseded or rescinded.