September 17, 2012 

Mr. Patrick Roth 

72 Lovely Street 

Unionville, CT 06085 

Dear Mr. Roth: 

This letter is to inform you that we are unable to process your request for an exemption from 

§§ 45.22(b)(1) and 45.29(b)(1) of Title 14, Code of Federal Regulations (14 CFR). It 

explains why we can’t process your request, gives you some important information about how 

we have handled similar requests, and tells you what you should do in the next 30 days. 

Why We Can’t Process Your Request

We entered your August 9, 2012, exemption request into the public docket 

(No. FAA-2012-0843), but we are unable to process your request any further. The 

information you sent doesn’t comply with the requirements of 14 CFR § 11.81 (copy 

enclosed). For us to consider the request any further, you must send us all of the following: 

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

 The reasons why granting the exemption wouldn’t adversely affect safety or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek an exemption. 

 Any more information, views, or arguments available to support your request. 

How We Have Handled Similar Requests 

Your request for exemption applies to the requirements for the nationality and size of 

registration marks on your Great Lakes Model 2T-1A aircraft. 

It is important for you to know that we have issued denials of exemption in circumstances 

similar to those presented in your petition. We are enclosing examples of denials, Exemption 

Nos. 7760 and 10623. As noted in these denials, the FAA has determined that allowing the 

petitioner to display 2-inch registration marks in place of the required 12-inch marks for 

aesthetic reasons is not in the public interest and would not provide a level of safety 

equivalent to that provided by the regulation. 
2 

The FAA notes that the petitioner is not unique from the general class of regulated persons 

who are subject to the requirements of § 45.29(b)(1). The display of 12-inch registration 

marks on your Great Lakes Model 2T-1A aircraft may detract from its aesthetics; however, 

the FAA has determined that installation of distinctive paint schemes, insignias, and logos do 

not appropriately substitute for the 12-inch registration marks. We find that the12-inch 

registrations marks will best allow the FAA to fulfill its responsibility for positive 

identification of aircraft and its obligations to protect persons and property. 

Because the previous denials of exemption dealt with circumstances similar to those 

presented in your petition, there is little reason to believe that we would grant your petition 

for exemption. 

What You Should Do 

 Before we commit agency resources to process and analyze your exemption request, we 

suggest that you review the enclosed denials of exemption. 

 If, after that review, you still want the agency to process your petition, you must tell us 

how the facts and circumstances of your particular situation are significantly different 

from the previous denials of exemption. 

 Send the information about your particular situation, and the information we requested 

earlier in this letter that will enable us to process your request, to reach us within 30 days. 

We will consider the docket on your request open for that period. 

If We Don’t Hear From You 

If we don’t hear from you within 30 days, we will close the docket without further contact. 

If you have any questions or need more time, you may call (202) 267-4059. 

Sincerely, 

/s/ Brenda D. Courtney for 

Lirio Liu 

Acting Director, Office of Rulemaking 

Enclosures