August 4, 2014

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

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. 4721M 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, for 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 instruction and the development of advanced flying skills/training by 

USHPA-certified instructors.

Comments 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 permitting 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 granted 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 pilots 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 and 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-place instructional techniques. 

USHPA’s Hang Gliding and Paragliding Accident/Incident Review committees evaluate flyingrelated accidents and incidents for the purpose of enhancing the safety of the sport. The 

committees publish accident and incident reports and provide annual summaries 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 controls. 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, CO 80901-1330

Tel: 800-616-6888 / 719-632-8300

Fax: 719-632-6417

www.ushpa.aero

The second incident occurred when the tandem flight encountered wind gradient resulting 

in a partial 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 precautions 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-evaluated 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 flying 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. 

The USHPA hereby petitions for an extension for Exemption No. 4721M, as amended from FAR 

103.1(a) & (b), and for the continuation of accepted USHPA two-place ultralight administrative 

procedures.

Comments In Support Of Attached Edits to 

Exemption

In order to 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 Hang 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 instructional 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, CO 80901-1330

Tel: 800-616-6888 / 719-632-8300

Fax: 719-632-6417

www.ushpa.aero

Summary for the Federal Register

The United States Hang Gliding and Paragliding Association (USHPA) petitions for 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 advanced flying skills/training by USHPA 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 Committee Chair

Greg Kelley, Safety and Training Committee Chair

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

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

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 unpowered ultralight vehicles from USHPA-approved launch 

sites.

3. Both occupants on all two-place training flights must possess a current pilot rating 

issued by the USHPA and at least one occupant must possess a current USHPA Tandem

Instructor 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 occupants on all two-place flights, other than for training purposes, must possess 

a current pilot 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 authority 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 USHPA 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, 

2016, unless sooner superseded or rescinded.