Tandem instructors are required by USHPA rules to report their
accidents. Their ratings can be revoked if they do not. These are individual
instructors, not the ACA, but employees of ACA.

Not all sites require USHPA site insurance. Many commercial operations do not
require any liability insurance, especially if they are owned by the commercial
entity. Wally Ranch, for example. It is my understanding the ACA has submitted a
bond to the city of San Diego for Torrey Pines in lieu of insurance and is does
not have USHPA site insurance and certainly hasn't for many years, at least.

It seems to me that USHPA certified tandem instructors are free to fly under the
USHPA tandem exemption or under the ASC tandem exemption. Their choice. I'm
confused as to why they would be in violation of the USHPA tandem exemption if
they are not using it when flying a tandem under the ASC exemption. Perhaps Paul
will clarify this. As I understand it the ASC exemption does not require the
tandem student to be an ASC member.

Many commercial operations have in the past gone bare, i.e. not purchased 3rd
party liability insurance. They have done so because they can not afford to pay
for this insurance. This is true also today. Many commercial operations can not
afford to participate in PASA or the RRRG. It seems to me to be unrealistic to
expect them to do so. I'm sure that it would be nice to distribute the risk and
the cost of the RRRG among as many operations as possible to help make it
viable, but this may be more difficult than the USHPA had hoped for.

Some schools have looked into alternate liability policies given the high cost
of RRRG or PASA insurance. As I recall from various discussions they have been
made aware of the fact that these policies may not be adequate. For the most
part they appear to me to be choosing to go bare. As these sites don't have
USHPA site insurance, the scenario detailed above where the plaintives go after
the USHPA does not play out as indicated.

Paul wrote:

USHPA SOPs require that tandems students must be USHPA members. If
instructors are flying students who are USHPA members but under the ASC
exemption USHPA currently has no issue. If students are not USHPA members then
the tandems are being conducted outside USHPA SOPs. USHPA would then review
those cases and potentially revoke ratings.

I am really confused by this. The first line is only true if the
tandem pilots are flying the tandem students under the USHPA tandem exemption.
If ASC certified tandem instructors are flying tandem students without USHPA 30
day memberships under the ASC exemption, whether the instructors are also USHPA
certified tandem instructions seems to me to be totally irrelevant. Please help
me understand why that would not be the case.