Two-seaters are a part of ultralight aviation FAA reports in NPRM 11133 that two-place ultralight exemptions for flight training began "in 1995 when it [FAA] issued the first exemption from part 103 for training" This is far from true. FAA issued the first exemption allowing two-place ultralights (yes, they are ultralights because of the exemption) to be used for flight instruction in the spring of 1983; only 9 months after the issuance of ultralight regulation itself (part 103). Since then there has been an uninterrupted series of renewals and grants of additional exemptions to this day, 19 years later. Those who ignore or deny that there have been two-place ultralights are wrong. Two-seaters have been with us since the beginning. When FAA says that NPRM 11133 will not change ultralight operations (part 103), it is hiding the reality that requiring all existing ultralight flight instructors to begin all over in a different set of regulations does indeed change ultralight operations as they have been for almost 2 decades.