Paul writes:

As I understand it, there are requirements to perform tandems as a
USHPA tandem instructor. Those SOPs are 12-02.02 and 12-03.03. These SOPs fall
under the general statement (12-01.01): “The purpose of this SOP is to outline
operational procedures for pilots participating in the Tandem Program.”

It is not indicating that these SOPs are necessary for operation under exemption
4721. So it is perhaps misleading to say that a pilot “is still required to act
as though he is under USHPA tandem exemption." I would instead phrase it that he
is still required to conduct tandems per USHPA SOPs in 12-02.02 and .03.

Semantics, perhaps, but both our tandem program and our exemption 4721 have the
same requirement. As such, even if one is operating outside the USHPA 4721
exemption, they would still be required as a USHPA tandem pilot to operate
according to our Tandem program SOPs

Does this make sense?

The argument that Paul is making is that if you are rated as a
USHPA tandem instructor you are acting in that capacity no matter what. Even if
you are providing tandem instruction under the ASC tandem exemption you are
still acting as though you are a USHPA tandem instructor. That is, you can not
leave your designation as a USHPA tandem instructor behind, at home. It is
permanently attached to you.

For example, if you are at a hang gliding site, even one not USHPA insured, and
you are watching tandem paragliding or hang gliding flights (being flown under
the ASC exemption), you are required under Paul's interpretation of the USHPA
SOPs to make sure that the students have USHPA membership.  This is the
case even if you are not involved in the tandem operation.