Tandem Paramotor Training With Wheels Clarified
By Jeff Goin, Dec 17, 2010 | USPPA Training
Program Including Tandem
 Tandem
powered paragliding is allowed under FAA exemptions for "foot launched"
flying. That's the wording of both exemptions carried by the USPPA and ASC
since USPPA got the first exemption approved after the originals expired. It
should be noted that ASC charges $100 per year for access to their
exemption, USPPA charges nothing.
Last year some of our instructors were told they could use wheels under
the ASC exemption even though there was no change in the exemption wording
or status. Then ASC told the EAA that there was a change and pilots could
use wheels for tandems. Again, there was, in fact, no change.
They published that article in October, 2010. We
obviously worried what impact this "reinterpretation" might have if FAA
regulators discovered it. We submitted, and EAA published, an article
questioning ASC's interpretation--the EAA article is included below.
We'd love for it to have been true but felt that unilaterally
redefining "foot launched" was not a good long-term idea. So we sent a
letter to the FAA asking for clarification.
You can see that
letter as a PDF here or in text form below. We added a question as to whether there was any difference in applicability
between the two exemptions. There isn't.
Basically, our letter stated that we agreed wheeled tandems would be
safer and make it available to more instructors, but wanted to make sure it
would be an acceptable interpretation.
On Dec 17, 2010, we got their response and, not surprisingly, wheeled
launching of powered paragliders is indeed not covered under either
exemption. You can see
the FAA's response here. Putting wheels on a tandem PPG makes it a Light
Sport Aircraft. The launch must be on foot. The FAA sent a copy of the
letter to ASC as well "for standardization."
While we'd love to make our own rules, we suspect that doing so would not
be responsibly executing the self oversight that we've collectively been
entrusted with.
EAA Article:
If Only It Were True: Dual Instruction in Wheeled PPGs
By Jeff Goin,
Originally Published
Nov 2010 in EAA Light Plane World
Jeff Goin, president
of the U.S. Powered Paraglider Association (USPPA), filed this response
in reaction to the announcement in our October 2010 issue of a training
exemption for two-place wheeled powered paragliders. Read the original
story
here.
Last month, EAA Light
Plane World published a news story where the CEO of Aerosports
Connection (ASC) suggested that dual training in wheeled powered
paragliders (PPGs) was now legal. While we would all love for that to be
the case, in our opinion it is not supported by the facts.
Enactment of the Sport
Pilot rule ended all previous ultralight training exemptions including
those for foot-launched PPG. So the United States Powered Paragliding
Association (USPPA) worked hard with the FAA to get a new exemption,
including for wheeled PPGs. But the FAA would not allow wheels and made
that very clear—we earned our exemption only after removing all
references to wheels. A couple months later, the ASC got theirs with
identical applicability wording and, not surprisingly, with no mention
of wheels. Then this year, USPPA and ASC got their exemptions extended,
again with identical wording, but, for some reason, ASC chose to broaden
its interpretation. Let’s look at the exemptions’ wording (emphasis
added).
USPPA #9751A: “This
exemption applies only to flights for the purpose of giving
instruction in foot-launched, two-place powered paragliders.”
ASC #9785A: “This
exemption applies only to flights for the purpose of giving
instruction in foot-launched, two-place powered and unpowered
paragliders.”
Sound similar? Some
observations: 1) this is no different than what the USPPA has had since
2008, 2) we see no basis for redefining “foot-launched” as “foot
launchable” and 3) think it’s reckless, at best, to unilaterally
redefine a prime aspect of our exemptions in an apparent effort to
broaden their appeal.
Also, USPPA got wording in its grant of exemption that allows the motor
to support its own weight, reasonably inferring that it could have
wheels as long as the pilot and student were supporting their weight
during launch and landing. We sure hope that our collective behavior
doesn’t put that allowance at risk, but I fear it might.
We readily acknowledge
that foot launching is hard, and that doing this on wheels is safer, but
being flippant with the authority we’ve been granted puts that authority
at risk, so USPPA has asked the FAA for clarification. Responsible
behavior is waiting to get an official clarification before accepting
such a broad definition.
Note that the USPPA does
not charge instructors for access to its exemption and, in fact, pays
pilots a small training reimbursement for achieving ratings. ASC charges
$100 per year for using the exemption in addition to the membership
amount. USPPA is sincerely trying to encourage more pilots to graduate
to instructor level to help others get started in the sport. Visit
www.USPPA.org/Training for more information on our tandem program.
FAA Letter of Clarification
Dec 17, 2010
Received by USPPA in
Naperville and published in the Docket on Dec 13, 2010..
AFS-11-032-E
Dec 13 2010
Regulatory Docket No. FAA-2001-9032
Mr. Jeff Goin
United States Powered Paragliding Association
931 West 75th Street
#137-150,
Naperville, IL 60565
Dear Mr. Goin:
This is in response to
your October 16, 2010 letter (FAA-2002-12476) and the letter dated
November 16, 2010 requesting that the Federal Aviation Administration
(FAA) clarify the
intent of the exemptions issued to United States Powered Paragliding
Association (USPPA)
and to Aero Sports Connection (ASC). The USPPA exemption (9751A) permits
training
using foot-launched, two-place powered paragliders. The ASC exemption
(9785A) permits
training using foot-launched two-place powered or unpowered paragliders
or hang gliders.
Both the USPPA and ASC
exemptions contain virtually the same wording and are intended
to convey the same meaning. These exemptions permit only the operation
of foot-launched
powered or unpowered paragliders or hang gliders. The use of wheels is
not acceptable. The
addition of wheels, skids, carts, etc., will create a powered parachute
or a weight shift control
(WSC) trike, both of which are subject to FAA certification as aircraft.
Below you will find
specific answers to the questions you forwarded to the FAA for
clarification:
1. Is it acceptable that
foot launchable powered paraglider that happens to have wheels
be launched or landed on a tandem instructional flight, using those
wheels, under
either exemption listed above?
Response – It is not
acceptable for a two place foot-launched powered paraglider
(or hang glider) to use wheels for any launch or landing, solo or under
the
exemptions in question.
2. Is it acceptable that
the motor unit has skids or wheels intended to support its own
weight during launch or landing? The instructor or student are
supporting their own
weight during the launch and landing.
Response – Any support
of the motor unit is acceptable only when static. The
launch and landings must be solely by foot.
3. Is there any
difference in applicability or meaning of the term “foot-launched”
between the ASC and USPPA exemptions?
Response – There is no
difference in the applicability or meaning of the term
“foot-launched.”
A copy of this
clarification will be provided to ASC to ensure standardization.
Sincerely,
Raymond Towles
Acting Director, Flight Standards Service
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