AFS-12-452-E

July 30, 2012

 Exemption No. 4416O

Regulatory Docket No. FAA-2002-12831

Mr. Paul W. Railsback

Director of Operations

Air Transport Association d.b.a. Airlines for America

1301 Pennsylvania Avenue, Suite 1100

Washington, DC 20004

Dear Mr. Railsback:

This letter is to inform you that we have granted your petition to extend Exemption No. 4416, 

as amended. It explains the basis for our decision, describes its effect, and lists the conditions 

and limitations.

The Basis for Our Decision

By letter dated June 27, 2012, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Air Transport Association d.b.a. Airlines for America (A4A) for an extension of 

Exemption No. 4416, as amended. That exemption from § 61.157(a); item I (b) of appendix 

A to part 61; § 121.424(a), (b), and (d)(1); item I (a) of appendix E to part 121; and item I (b) 

of appendix F to part 121 of Title 14, Code of Federal Regulations allows ATA member 

airlines and other qualifying part 121 certificate holders to conduct training and checking of 

pilots on airplanes that require two flight crewmembers for the required preflight inspection, 

both interior and exterior, using approved advanced pictorial means.

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to A4A.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 4416, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 

under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I grant your petition, subject to the following conditions and limitations.

Conditions and Limitations

1. Each part 121 certificate holder desiring to use the provisions of this exemption must 

develop still and/or motion pictures providing distant and detailed closeup views of 

each passenger compartment and exterior preflight inspection item depicting normal 

and abnormal conditions.

2. The projection equipment must provide rapid and random access capability to any

picture for training and checking purposes.

3. The pictures and descriptions of the items must be approved by the appropriate FAA 

Flight Standards District Office holding the operating certificate.

4. Each pilot must receive training to proficiency and demonstrate proficiency on at least 

one complete visual inspection of the interior and exterior of a static airplane of the 

appropriate type. This training and demonstration of proficiency must be successfully

completed and documented by a check airman before the completion of operating 

experience required by § 121.434.

5. Training devices used for the flight deck portion of the preflight visual inspection must 

be approved for that function, must accurately replicate the aircraft flight deck 

geography, and must simulate appropriate systems functions to include control, switch, 

instrument, and circuit breaker functions in regard to normal, abnormal, and 

emergency procedures.
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The Effect of Our Decision

Our decision extends the termination date of Exemption No. 4416, as amended, to

September 30, 2014, unless sooner superseded or rescinded. 

Sincerely,

/s/

John Duncan

Acting Director, Flight Standards

Service