l..AWOPFJCES 

GAROFALO GOERLICH HAINBACH PC 

1200 NEW HAMPSHIRE AVENUE NW, Sum:59U W,\SH!NGT,)N DC 20036-6802 

TELEPHONE 202 T/6-3970 · FAC'SI~HlE 202 776·3975 

W\Y'~ .GOH-AIRLAW.COM 

February 23, 2015 

Federal Aviation Administration 

Office of Rulemaking, Aircraft & Airports Rules Division (ARM-203) 

800 Independence Ave. SW 

Washington, DC 20591 

Attn: Ms. Sandra K. Long 

RE: FAA-2015-0175 Petition for Exemption-Supplement No. 1 

Dear Ms. Long: 

On January 23, 2015, Zero Gravity Corporation c·zero-G") and Tatonduk Outfitters 

Limited C~Tatonduk") filed a Petition for Exemption from the requirements of 14 CFR 

§§91.303(t) and 91.307(c) to the extent necessary to allow Tatonduk and its pilots to operate a 

specially-modified Boeing 727 aircraft (the ~'Aircraft") under Part 121 on behalf of Zero G in 

parabolic flight operations (the "Petition"). The authority sought in the Petition, if granted, 

wouJd be identical to the authority granted to Amerijet International Inc. ("Amerijet") on May 

18, 2004 by way of FAA Exemption 8333, as amended. In the Petition, the parties represented 

that the justification for relief granted in Exemption 8333, as amended remained unchanged and 

would apply equally to Tatonduk to replace Amerijet in the operation of parabolic flights as Zero 

G's service provider. 

Although immaterial to the FAA's findings in granting Exemption 8333 on May 18, 

2004, the exemption, on page 7, refers to a statement of Zero G regarding the then 30-seat 

configuration of the Aircraft which "relieves Zero G from having to comply with the collision 

avoidance system requirements of § 121.356., The exemption also noted that "Amerijet 

voluntarily complies with the traffic collision and avoidance system requirements of§ 121.356.H1 

The purpose of this Supplement No. 1 to the Petition is to note that the Aircraft is 

currently configured for 38 seats. The increase from the original 30-seat configuration to 38 

seats was approved by FAA in 2007 as part of Revision J to Zero G's STC ST0105ILA. The 

addition of 8 seats has no bearing on the public interest and safety findings that underlie the 

relief from §91.303(f) and 91.307(c) granted by Exemption 8333, as amended, since the Aircraft 

These statements are based on responses of Zero G and Amerijet. dated October 18, 2003, to an 

information request of AFS·200 on September 12, 2003 as to how the aircraft would comply with the TCAS 

requirements of§ 121.356(a) if more than 30 seats were installed. The answer provided was that .. Zero G will not 

insta\\ more than 30 passenger seats. However Amerijet's aircraft voluntarily meets the TCAS requirements set 

forth in 14 CFR section 121.356." 
GAROFALO GOERLICH HAINBACH PC 

has at all times met, and will continue to meet, the TCAS requirements in § 121.356 when 

operated by Amerijet and Tatonduk. Nor does the 38·seat configuration have an adverse impact 

on Tatonduk's ability to cornply with the conditions and limitations in Exemption 8333) as 

amended. 

Indeed, compliance with the TCAS require1nents of§ 121.356 was the only reason for 

FAA having inquired about the seating capacity of the Aircraft There was no intent to limit 

Exemption 8333, as amended, to 30 seats especially in light of Zero G having obtained an STC 

in 2007 to increase the seating capacity to 38 seats; nor was Exemption 8333, as originally 

issued, or as amended, ever limited or conditioned on a 30 seat configuration. Thus, on this 

point, the reference to seating capacity is irrelevant and imtnaterial to the grant of Exemption 

8333. Nevertheless we are supplementing the Petition to eliminate any concern, albeit 

unfounded, that Zero G's October 2003 response to FAA's information request might be 

misconstrued as providing a 30-seat lin1itation on Exen1ption 8333. 

If you have any questions regarding this clarification, or any other matter related to the 

Petition, please contact the undersigned. 

Gary B. Garofalo 

Victor H. Smith 

Sincerely, 

Counsel to Tatonduk Outfitters Limited 

Mike Henke 

Counsel to Zero Gravily Corporation 

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