### 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.pitman air.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 exe mption

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 A irframe of the Dragonfly as well as protection for the craft and pilots being towed. 3) The Bailey Tow and Release S ystem has been used, refined and proven for more than 20 years. 4) The proper use, configuration, maintenance and inspection of the Bailey T ow 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 Manual s Appendix G

. Current Manuals located online at: www.pitmanair.com/dragonfly

5 ) T he Pitman Air Dragonfly M anuals specify required Operating Procedures, Maintenance and Inspection P rocedures, 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 accorda nce 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) Th ey must also agree to participating in the Continued Operational Safety Monitoring System for Dragonfly Aircraft by Pitman Air. c) And will pay a modes t fee for this administrative and monitoring process. SLSA and ELSA Kits built by Pitman Air since 201 2 , are already included in this process.

• How your request would benefit the public as a whole

1) There is no mechanism to seek Ap proval of the Administrator

, as stated in 91.309 (a)(2)

, on Light Sport Aircraft

. i.e. STC, 337, etc. 2) Aero Towing of Unpowered U ltralights (i.e. hang

- gliders) , Light Sport Gliders and other Light G liders 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 e nable flight of U npowered Ultralights, Light Sport Gli ders and other Light G liders, for many sections of the United States, which normally would not be able to enjoy this type of aviation. 3) Waiver w ould insure maintenance and inspection of aircraft and t ow 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 exc eeds 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 To w 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. a nd, 2) User s of the Waiver would be required to adhere to the safety pr actices, maintenance and inspection procedures detailed in the Pitman Air Dragonfly M anuals

. a nd, 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 an d remedied as quickly as possible to insure maximum safety levels. a nd, 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 Pe rformance 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 31 st 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 p roduced 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 9 1.309(a)(2) and 91.309(a)(3) for the purpose of utilizing the Bailey Tow & Release System on the Dra gonfly Light Sport Aircraft and /or approval of the proven configuration, maintenance and inspection procedures to insure the maximum level of safety . A nd

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

.

o A brief descripti on of the exemption you seek1) The “Pitman Air Dragonfly” also referred to as “ Bailey Moyes Dragonfly by Pitma n Air ” using the

“ Bailey Tow and R elease System ” is exempt and granted relief from FAR 9 1.309(a)(2) and 91.309(a)(3) Providing the following re quirements 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 Dragon fly Maintenance Manual. Current manuals posted

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

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

“Continued Operational Safety Monitoring System” to insure fu ture 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 p osted 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.

Respe ctfully Submitted, Edgar D Pitman Member Pitman Air LLC