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 ofExemption 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 ofthe 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 ofthe 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 ofexemption 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 i s granted an exemption for the Bailey Tow & Release System from §§ 91.309 (a)(2) and 9 l .309(a)(3) ofTitle 14 Code ofFederal 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 ofthis 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 Dragontly Light Sport Aircraft certificated under §§ 21.190 and 21.191(i)(l) of Title 14 Code ofFederal 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 A l .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 ofFederal 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 ofthe summary ofthis 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