September 24, 2015

Exemption No. 12980

Regulatory Docket No. FAA−2015−2745

Mr. Davide Calda

2725 South Lockwood Ridge Road

Sarasota, FL 34239

Dear Mr. Calda:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letters posted to the public docket on July 9 and August 25, 2015, you petitioned the 

Federal Aviation Administration (FAA) for an exemption. You requested to operate an 

unmanned aircraft system (UAS) to conduct aerial photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

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

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 3.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Davide Calda is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Davide Calda is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 
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Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on October 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
' ........ 

Docket Operations, 

M-30 U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. Room W12-140, 

West Building Ground Floor Washington, DC 20590-0001 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act Of 2012 and CFR Part 11, 

DAVIDE CALDA, Videomaker and photographer, owner and operator of Small Unmanned Aircraft 

Systems (UAS's), request to be exempted from the Federal Aviation Regulations (FAR's) listed 

below so may operate UAS's commercially within airspace regulated by the FAA, as long as such 

operations are conducted within and under the conditions outlined here in or as may be 

established by the FAA as required by Section 333. 

As described below, the requested exemption would permit the operation of light weight (less than 

55 lbs. total take off weight) UAS's under controlled conditions for commercial use by myself 

thereby enhancing safety and fulfilling the Secretary of Transportation's responsibility to "establish 

requirements for safe operation of such aircraft systems in national airspace systems." Section 

333(c), of the Reform Act. 

Davide Calda's Drone is rotorcraft weighing less than 55 pounds including payload (DJI Phantom 

3 Quad Copter). They operate at a speed less than 50 knots and have the capability to hover and 

move in the vertical and horizontal plane simultaneously. The DJI Phantom 3 has an auto return to 

the departure point when exceeding the manufacturers recommended distance from the controller, 

when the signal between the controller is lost or when battery power is under 25%. The UAS will 

be operated within "line of sight" in a protected flight area at 200' AGL or less. These operations 

will not create a hazard to users of the nations airspace or the public. 

Davide Calda submits this application in accordance with the Reform Act, 112 P.L. 95 331:334, 

seeking relief from any currently applicable FAR's operating to prevent commercial use of small 

UAS's to operate in the national airspace system as described below. The Reform Act Section 332 

provides for such integration of civil unmanned aircraft into our national airspace system as it is in 

the public's interest to do so. I meet the definition of "small unmanned aircraft" as defined by 

Section 331 and therefor the integration of theses UAS's are expressly contemplated by the 

Reform Act. I would like to operate it's light weight UAS's prior to the time period by which the 

Reform Act requires the FAA to promulgate rules governing such aircraft. The Reform Act directs 

the Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in national airspace before completion of the rule making required under Section 

332 of the Reform Act. In making this determination, the Secretary of Transportation is required to 

determine which UAS's do create a hazard to users of the national airspace system or the public or 

pose a threat to national security in light of the following. The UAS's size, speed, weight and 

operational capability. 

• Operation of the UAS's in close proximity to airports and populated areas. 

• Operation of the UAS's within visual line of sight of the operator. 

Reform Act 333(a). If the secretary determines that such vehicles "may operate safely in the 

National Airspace System, the secretary shall establish requirements for the safe operation in 

national airspace. 
Davide Calda will be using rotorcraft weighing less than 55 lbs and operate at speeds less than 50 

knots with the ability to operate in the vertical and horizontal plane simultaneously. The UAS's will 

operate only within "line of sight" of the operator within a protected flight area and at 200' AGL or 

less. This will not present a hazard to the national airspace or the public. 

The very small nature of these UAS's combined with the safe guards presented below, will allow 

for the safe operation greater than that envisioned by Congress for the FAA to establish and by 

exemption allow commercial operations of UAS's to commence immediately. Also due to the size 

of UAS's and the areas and altitudes they will operate approval of this exemption presents no 

national security issues and absolutely minimal safety concerns which have been mitigated 

through our rigorous risk management process. Given the clear direction given in Section 333 of 

the Reform Act, the authority contained in the Federal Aviation Act, as amended, the strong 

equivalent level of enhanced safety, reduced emissions utilizing UAS's versus traditional aircraft as 

well as the economic impact of greatly reducing the cost of aerial photography thereby benefitting 

the greater public's interest. Accordingly, the applicant requests that the FAA grant the requested 

exemption without delay. 

The following will be considered as the Standard Operating Procedures (SOP) : 

1.Fiights will only occur between sunrise and sunset. 

2.Fiights will be operated in the line of sight of the operator (PIC). 

3.Fiights will be terminated at any time weather and wind deteriorate to "unsafe for flight" based on 

manufacturer's limitations. 

4.The UAS's will weigh less than 551bs. 

5.Fiights will be operated at less than 200' AGL. 

6.The UAS's operator will perform a check of the flight area and make certain of the safety of all 

persons in the area. 

?.Consent will be obtained from all persons within the video capabilities to ensure their privacy. 

8.AII required FAA clearances will be obtained and distances from airports strictly adhered too. 

9.AII UAS's will have the capability to return automatically to the operator in a safe manner with the 

auto return function checked and working. 

1 O.Fiights will only operate in VFR conditions. 

11.UAS controllers display range and remaining battery power. 

12.AII preflight checks will be done prior to each flight. 

13.AII routine inspections and maintenance will be done in accordance as specified by DJI. 

14 CFR, Part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7 (a), 91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of 

necessary certificates in relation to FAR 91.203(a)(1). The size, weight and defined area of 

operations for Drone View Aerial Photo UAS's flights permits exemption from Part 21 because 

they meet an equivalent level of safety pursuant to Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from airworthiness certificates in consideration of 
weight, size, speed, maneuverability and proximity to areas such as airports and dense 

populations. Davide Calda meets or exceeds each of these items. 

As of March 23, 2015 the FAA has stated that it will automatically grant a "blanket" COA for flights 

at or under 200' AGL to any UAS operators with a Section 333 Exemption. 

14 CFR, Part 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. 

These are inapplicable for the same reasons stated above. The equivalent level of safety will be 

achieved by maintaining such certifications and registrations by Drone View Aerial Photo. 

14 CFR, Part 91.7 (a) prohibits the operation of an aircraft without an airworthiness certificate. As 

no such certificate will be applicable in the form contemplated by the FAR's this regulation is 

inapplicable. 

14 CFR, Part 91.9(b)(2) requires an "Civil Aircraft Flight Manual" in aircraft. As there are no pilots 

or passengers and given the size of the UAS's this regulation is inapplicable. 

The FAA has previously issued exemptions to this regulation in Exemptions 8607, 8737, 8738, 

9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 332827. 

14 CFR, Part 91.119 Minimum safe altitudes prescribes safe altitudes for operation of civil 

aircraft .. It allows helicopters to be operated at lower altitudes under certain conditions. Davide 

Calda will only operate it's UAS's at or below 200' AGL. They will be operated in a well defined 

area of operation that has been carefully reviewed for hazards and minimizes the presence of any 

persons not essential for these operations. Flights will only be over private property with the 

owner's consent. 

Approval of these 333 Exemptions allowing commercial use of small UAS's in the service of aerial 

photography will greatly enhance safety by reducing the overall risk associated with traditional 

aircraft. Traditional aerial photography requires large aircraft with fuel potentially flying over or in 

close proximity to populated areas. With the use of small battery powered UAS's of 55 lbs or less 

the risk of injury to people on the ground is drastically reduced. 

Granting Davide Calda the above exemption will allow for the expansion of the use of UAS's 

aircraft in the future for the safe conduct of free enterprise. 

Davide Calda respectfully requests the FAA grant it's exemption without delay. The FAA has the 

authority to issue this exemption pursuant to the Federal Aviation Act, 85 P.L. 726 (1958) as 

amended (the act). 

Sincerely, 

DAVIDE CALDA VIDEOMAKER & PHOTO 

2725 South Lockwood Ridge Rd 

Sarasota 34239 FL 

Phone (941) 284 2428 

Davide. calda@gmail.com 
Mr.	Davide	Calda

2725	South	Lockwood	Ridge	Rd

Sarasota	34239	Florida

Petition	under	Section	333	of	the	FAA	Modernization	Act	of	2012	(FRMA)	for	

waiver	of	Airworthiness	Certificate

Petitioner	plans	on	operating	an Unmanned	Aircraft,	more	specifically	a	DJI Phantom	3	

Professional,	for	the	following	purposes:

1. To	take	videos	or	photographs	of	homes,	commercial	buildings,	land	or	lots for	sale	to	

be	used	in	marketing said	properties.

2. To	Take	video	for	Documentary,	Wedding,	Corporate.

3. To	Take	video	for	inspection	of	buildings, normally	roof	and	gutters,	for owners.

4. To	inspect	bridges,	roads	and	railroads	for	maintenance	purposes	or	such	purposes	

requested	by	owners	which may	be	government	entities.

5. Aircraft	may	be	used	at	times	by	the	owner	for	recreational	purposes	for	which	the	air	

certificate	is	not	required.

Operation	of	the	unmanned	aircraft	will:

1. Be	by	petitioner,	a	person	over	17	years	in	age who	is	trained	in	the	operation	of	the	

identified	aircraft.	

2. Be	at	altitudes	not	to	exceed	500	feet above	the	ground.

3. Remain	in	visual	line	of	sight	of	the	operator.

4. Be	flown	close	enough	to	the	operator	for	the	operator	to	be	able	to	see	the	aircraft	

with	vision	unaided	by	any	device	other	than	corrective	lenses.

5. Be	flown	only	when	the	visibility	is	3	or	more	miles	from the	operator.	

6. Give	due	consideration	for	the	safety	of	persons	and	property	in	the	area	of	operation

and	the	aircraft	will	not	be	flown	over	persons	not	involved	in	the	operation.

7. Not	be	flown	dangerously	or	recklessly.

8. Be	flown	only	between	sunrise	to	sunset

9. Yield	right-of-way	to	other	aircraft	whether	manned	or	unmanned.

10. Not	be	operated	at	a	speed	over	35	mph,	the	maximum	speed	of	the	aircraft..

11. Be	operated only outside a	5 miles	radius	of	any	airport.
12. Only	be	undertaken	after	a	preflight	inspection	as	set	forth	in	Manufacturer’s Safety	

Guidelines	and	Disclaimer attached.

The	DJI	Phantom	3	Professional	weighs	less	than 3	pounds,	and	has	a	top	speed	of	35	mph.	

It	calculates speed,	altitude	and	GPS	information	which	is	displayed	on	the	operator’s	

consol.	It	also	has	a	“go	home”	capability	which	will	return	it	to	the	GPS	location	the	flight	

started	from	on	command	or	when	battery	voltage	decreases	beyond	a	certain	value.

Manufacturer	certifies	that	the	aircraft	and	its	controls	comply	with	part	15	of	FCC Rules	in	

Safety	Guidelines	and	Disclaimer attached.	

Petitioner	seeks	an	exemption	of	the	Airworthiness	Certificate	under	the	authority	granted	to

the	Secretary by	Section 333.