FAR 91.215-- may an aircraft with no electrical system and no transponder overfly Wheeler AAF at 9500' MSL?
Yes, the following statement indicates that aircraft without electrical systems may penetrate the mode C veil at any altitude (presumably excluding cases where the penetration would immediately bring them into Class B or C airspace, or would immediately place them above underlying Class B or C airspace):


  "The practical effect of paragraph (b)(3) with respect to your
  question is that it allows non-equipped aircraft to enter the
  30-nautical mile circles surrounding Appendix D, Section 1 airports
  between the surface and 10,000' MSL and to operate beneath the floors
  of the associated Class B airspace..."


From this page 2 of this 2006 interpretation from the FAA Office of the Chief Counsel.