Petition for Exemption

• Your name and mailing address. You may include other contact information such as a fax 

number, telephone number, or email address

Pitman Air LLC 1840 Airport Blvd., Red Bluff, CA 96080 Ph. 530 945 1860 

Website:www.pitmanair.com/dragonfly 

Contact Person: Edgar D Pitman “Member” email: ed_pitman@hotmail.com

• The specific section or sections of Title 14 of the Code of Federal Regulations (CFR) from 

which you seek an exemption

FAR 91.309 (a)(2) and 91.309 (a)(3)

• The extent of relief you seek and the reason you seek the relief

To improve safety by the use of a structured and detailed use of the Bailey Tow & Release System on the 

Light Sport Dragonfly Aircraft by Pitman Air, which includes:

1) A bridle which allows for greater pitch control of the tow aircraft during tow. This bridle is unique to 

the Dragonfly and Bailey Tow & Release System.

2) Strategically located Safety Links which provide optimum protection for the Airframe of the Dragonfly 

as well as protection for the craft and pilots being towed.

3) The Bailey Tow and Release System has been used, refined and proven for more than 20 years.

4) The proper use, configuration, maintenance and inspection of the Bailey Tow and Release System is 

well defined in the Pitman Air Dragonfly Pilot Operating Handbook and Flight Training Supplement, 

Appendix D, and in the Dragonfly Maintenance Manuals Appendix G. Current Manuals located online at: 

www.pitmanair.com/dragonfly 

5) The Pitman Air Dragonfly Manuals specify required Operating Procedures, Maintenance and 

Inspection Procedures, which are Required on Special Light Sport Aircraft. But only recommended for 

Experimental Light Sport Aircraft as there is a lot of flexibility in maintenance requirements of Aircraft of 

Experimental status.

6) Waiver should state that the exemption and relief from FAR 91.309(a)(2) and 91.309(a)(3) is for SLSA 

Pitman Air Dragonfly Aircraft and/or ELSA Dragonfly Kits, built and maintained in accordance with 

Pitman Air Dragonfly Maintenance and Inspection procedures.

7) If ELSA Dragonfly owners choose to be included in this exemption: 

a) They must agree to maintain their aircraft and tow system in accordance with SLSA Dragonfly 

requirements. 
b) They must also agree to participating in the Continued Operational Safety Monitoring System 

for Dragonfly Aircraft by Pitman Air. 

c) And will pay a modest fee for this administrative and monitoring process. SLSA and ELSA Kits 

built by Pitman Air since 2012, are already included in this process.

• How your request would benefit the public as a whole

1) There is no mechanism to seek Approval of the Administrator, as stated in 91.309 (a)(2), on Light 

Sport Aircraft. i.e. STC, 337, etc.

2) Aero Towing of Unpowered Ultralights (i.e. hang-gliders), Light Sport Gliders and other Light Gliders 

is necessary in most parts of the United States and its territories due to the lack of suitable mountainous 

terrain from which a flight can begin. The Waiver would enable flight of Unpowered Ultralights, Light 

Sport Gliders and other Light Gliders, for many sections of the United States, which normally would not 

be able to enjoy this type of aviation.

3) Waiver would insure maintenance and inspection of aircraft and tow system components are done in 

accordance with tested and proven guidelines specified in the manuals for the Pitman Air Dragonfly also 

referred to as; Bailey Moyes Dragonfly by Pitman Air.

4) The Dragonfly and Bailey Tow and Release System, meets or exceeds the requirements of the FAA 

accepted “Consensus Standard” “ASTM F2245-11 Standard Specification for Design and Performance of 

Light Sport Airplane”. And, “Annex A1” of that Standard titled “Additional Requirements for Light Sport 

Airplanes used to Tow Gliders.”

• Reasons why the exemption would not adversely affect safety, or how the exemption would 

provide a level of safety at least equal to the existing rule

1) The guidelines contained in the Pitman Air Dragonfly Pilot Operating Handbook and Flight Training 

Supplement, as well as the Dragonfly Maintenance Manual provide a 20+ year tested and proven system 

as well as maintenance and inspection procedures to insure optimum safety. and,

2) Users of the Waiver would be required to adhere to the safety practices, maintenance and inspection 

procedures detailed in the Pitman Air Dragonfly Manuals. and,

3) Users of the Waiver would be included in the Pitman Air Dragonfly “Continued Safety Monitoring 

System” to insure anomalies in the system, are identified and remedied as quickly as possible to insure 

maximum safety levels. and,

4) The Dragonfly and Bailey Tow and Release System, meets or exceeds the requirements of the FAA 

accepted “Consensus Standard” “ASTM F2245-11 Standard Specification for Design and Performance of 

Light Sport Airplane.” And, “Annex A1” of that Standard titled “Additional Requirements for Light Sport 

Airplanes used to Tow Gliders.”

5) This Exemption or Waiver could bring ELSA Aircraft that transitioned in from Ultralights under 

21.191 (i)(1) before January 31st 2008, if it is worded properly, to impose the same maintenance and 

inspection procedures as SLSA Dragonfly’s and inclusion in the “Continued Operational Safety 

Monitoring” that is already included with SLSA Dragonfly’s produced by Pitman Air.

• A summary we can publish in the Federal Register stating: 

o The rule from which you seek the exemption

Pitman Air is seeking relief from FAR 91.309(a)(2) and 91.309(a)(3) for the purpose of utilizing the 

Bailey Tow & Release System on the Dragonfly Light Sport Aircraft and/or approval of the proven 

configuration, maintenance and inspection procedures to insure the maximum level of safety. And 

inclusion in “Continued Operational Safety Monitoring” conducted by Pitman Air LLC.

o A brief description of the exemption you seek
1) The “Pitman Air Dragonfly” also referred to as “Bailey Moyes Dragonfly by Pitman Air” using the 

“Bailey Tow and Release System” is exempt and granted relief from FAR 91.309(a)(2) and 91.309(a)(3)

Providing the following requirements are met

a) Waiver only applies to Aircraft which are SLSA Dragonfly’s or ELSA Dragonfly’s built and 

maintained in accordance with current Pitman Air Dragonfly Pilot Operating Handbook and Flight 

Training Supplement, as well as the current Dragonfly Maintenance Manual. Current manuals posted 

online at: www.pitmanair.com/dragonfly, and

b) Dragonfly Aircraft Owners/Operators must be enrolled in and participate in the Pitman Air Dragonfly 

“Continued Operational Safety Monitoring System” to insure future anomalies are remedied as quickly as 

possible, insuring a maximum level of safety.

• Any additional information, views, or arguments available to support your request

Rather than submitting the Pitman Air Dragonfly manuals which contain all pertinent information with 

this application, we have posted them online at: www.pitmanair.com/dragonfly for all to see and utilize. 

The manuals will continue to evolve as safety concerns arise. Safety Directives, Safety Alerts and Service 

Bulletins will also be posted online, as well as being mailed to registered users, to insure maximum levels 

of safety is available to all. 

FAR 91.309 does not account for the Light Sport Rule which has no mechanisim for “Aproval”. It is for 

that reason, we seek relief.

Respectfully Submitted, Edgar D Pitman Member Pitman Air LLC