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# GAROFALO GOERLICH HAINBACH PC

1200 NEW HAMPSHIRE AVENUE NW, Sum:59U W,\SH!NGT,)N DC 20036-6802 TELEPHONE202T/6-3970 ·**FAC'SI~HlE**202776·3975**W\Y'~ .GOH-AIRLAW.COM**  February 23, 2015

Federal AviationAdministration Office ofRulemaking, Aircraft 

### & Airports Rules Division (ARM-203) 800 Independence Ave. SW Washington, DC20591 Attn: Ms. SandraK. Long
RE: FAA-2015-0175 Petition for Exemption-SupplementNo. 1



### DearMs. 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 behalfofZero 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 ofFAA Exemption 8333, as amended. In the Petition, the parties represented that

### thejustificationfor relief

### granted in 

### Exemption 8333, as 

### amended 

### remained unchanged 

### and would 

### apply equally to Tatonduk to

### replace Amerijet in

### the operation ofparabolicflights 

### as Zero G's serviceprovider. 

### 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 ofthe 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

### withthe traffic collision and avoidance systemrequirements

### 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 relieffrom §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 ofAFS·200 on September 12, 2003 as to how the aircraft would comply with the TCAS requirements of§121.356(a) ifmore 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·seatconfigurationhave 

### 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 ofZero Ghaving 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 ofExemption 

### 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 

### a30-seat

### lin1itation on 

### Exen1ption 8333.

If

### you have 

### any questions regarding this clarification, or any other matter related to the 

### Petition, please 

### contactthe 

### undersigned.

Gary B. Garofalo 

### Victor

### H. Smith 

### Sincerely,

Counselto Tatonduk 

### Outfitters Limited 

### Mike Henke Counsel to 

### Zero Gravily

### Corporation

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