7/15/2016 

Federal Aviation Administration 

800 Independence Ave SW 

Washington, DC 20591 

Rtm~~ 

Ultralight & Light Sport Aircraft 

Sales, Service & Flight Instruction 

Ed Pitman 1840 Airport Blvd., Red Bluff, CA 96080 

slt.!JIJ!Ll\e: 1736,0 R110.cho Teb.alllll ll~.,_ Co(ni.P.g, CA 96021 

billing: P. 0. Box 5248 Corning, CA 96021 

ed_pitman@hotmall.com 530-945-1860 

Extension of Exemption 11104 

Subject: Request for Extension of Exemption 11104 to 14 CFR 91.309(a)(2) and 91.309(a)(3) 

This is a formal request for extension of exemption 11104 which is an exemption to 14 CFR 9 l.309(a)(2) 

and 91.309(a)(3) to allow use of the Bailey Tow & Release System on Dragonfly Aircraft as defined in 

Pitman Air LLC Dragonfly Pilot Operating Handbook (POH) and Maintenance Manuals. 

Public Interest: 

It has been proven for decades that the use of the Bailey Tow & Release System on Dragonfly Aircraft 

provides optimum safety for towing. 

Private Interest to Pitman Air LLC: Because an STC cannot be "Approved by the Administrator" for 

Light Sport Aircraft, this Exemption is Required. 

The FAA's Decision 

"In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, 

pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40 I 13 and 44 701 delegated to me by the 

Administrator, Pitman Air LLC is granted an exemption for the Bailey Tow & Release System from §§ 

91.309 (a)(2) and 9 l .309(a)(3) of Title 14 Code of Federal Regulations to the extent necessary for owners 

of the Dragonfly SLSA and ELSA aircraft certificated under §§ 21.190 and 21.191 (i)(l), manufactured by 

Pitman Air LLC, equipped with the Bailey Tow & Release System to tow aircraft and be in compliance 

with the issued operation limitations under §§ 91.327(a)(l) and 91.319(e)(l) as applicable. Operators of 

the Dragonfly aircraft that opt to utilize the Bailey Tow and Release System on their Dragonfly aircraft 

must follow the Conditions and Limitations of this exemption, subject to the conditions and limitations 

listed below." 

Equivalent Safety: 

Exemption 11104 provides equivalent safety to that found in Release Systems granted STC's under 

General Aviation Operations. And since an STC cannot be issued to Light Sport Aircraft, this Exemption 

is Required. 

Conditions and Limitations (should remain the same) 

l. The owner/operator will utilize the Bailey Tow and Release System only on the 

Pitman Air Dragontl y Light Sport Aircraft certificated under §§ 21.190 and 

21.191(i)(l) of Title 14 Code of Federal Regulations. 
. . 

2. The owner/operator will maintain and operate the tow hook assembly utilizing the 

Operation, Maintenance & Inspection Instructions for the Bailey Tow and Release 

System. 

3. The information in the Dragonfly LSA Maintenance Manual and Pilot Operating 

Handbook (POH) must meet the requirements of ASTM standard F2245 Annex Al .I 

through Al .7, when the aircraft is equipped for towing. 

4. For tow operations, the Light Sport Aircraft operator must meet the 100 hour 

Inspection requirements of§§ 91.319(g)(l) or (g)(2), or 91.327(c)(l) or (c)(2), of Title 

14 Code of Federal Regulations as certificated. 

5. A copy ofthis exemption must either be incorporated into the aircraft Pilot Operating 

Handbook (POH) or carried on the aircraft while operating under this exemption. 

Request Not to Publish the Summary, under 14 CFR 11.87 

We further request that consideration be given to non-publication of the summary of this petition based on 

14 CFR 11 .87 which recognizes granting of similar requests and pre-planning process that have set this 

path before us. 

Respectfully Submitted, 

Edgar D ~~ Pitman · ager Pitman Air LLC