Sir/Maam,

The following is the information needed to comply with the requirements of 11.81.

"The reason why granting the request would be in the public interest; that is, how it would benefit the 

public as a whole"

This exemption would allow me to offer the service of aerial video/photography through my business 

"Marks Service Center located at 342 US Route 11 Central Square, NY 13036." There is a growing 

public demand for professionally shot and edited aerial video content and obtaining this exemption 

would allow us to satisfy that need for our customers.

"The reasons why the exemption would not adversely affect safety"

THE APPLICABLE LEGAL STANDARD UNDER SECTION 333

Mark Martino Jr./Mark's Service Center Inc. submits that grant of this exemption application for use of 

the proposed

UAS's in of aerial photography, aerial videography, and aerial inspections, and other sUAS

flight operations will advance the Congressional mandate in Section 333 of the Reform Act to

accelerate the introduction of UASs into the national airspace system (“NAS”) if it can be

accomplished safely. This law directs the Secretary of Transportation to consider whether

certain UASs may operate safely in the NAS before completion of the rulemaking required

under Section 332 of the Reform Act. In making this determination, the Secretary is required

to determine which types of UASs do not create a hazard to users of the NAS or the public or

pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the sUAS in close proximity to airports and populated areas; and

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

Reform Act § 333(a)(1). If the Secretary determines that such vehicles “may operate safely in

the national airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis added).1

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under

§40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness

certificate and those regulations requiring commercial pilots to operate aircraft in commercial

service:

The Administrator may grant an exemption from a requirement of a regulation

prescribed under subsection (a) or (b) of this section or any of sections

44702-44716 of this title if the Administrator finds the exemption is in the

public interest.

1 Applicant submits that this provision places a duty on the Administrator to not only process 

applications for exemptions under Section 333, but for the Administrator, if he deems the

conditions proposed herein require modification in order to allow approval, to supply conditions

for the safe operation of the UAS. ark Martino Jr./Mark's Service Center Inc. welcomes the opportunity

to consult with FAA

staff in order to address any issues or concerns that this proposal may raise that they believe
may require modification.

49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on the clear direction in

Section 333 of the Reform Act; the additional authority in the Federal Aviation Act, as amended; 

4

the strong equivalent level of safety surrounding the proposed operations; and the significant

public benefit, including enhanced safety and cost savings associated with transitioning to

UASs for aerial photography, aerial videography, and aerial inspections and other .

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption

without delay.

Airworthiness of the sUAS

A critical element of the exemption application involves evidence of the airworthiness of the

sUAS. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,

upon consideration of the size, weight, speed, operational capability, and proximity to airports

and populated areas of the particular sUAS. Our small UAS's will operate at low speed in a

controlled environment, at least five miles from an airport. An analysis of these criteria

demonstrates that the UAS operated without an airworthiness certificate, in the restricted

environment and under the conditions proposed will be at least as safe, or safer, than a

conventional aircraft (fixed wing or helicopter) operating with an airworthiness certificate

without the restrictions and conditions proposed.

RISK MITIGATION

Mark Martino Jr./Mark's Service Center Inc., has reviewed FAA exemptions references 1-3 Condition 

and Limitations sections

and believes that procedures specified therein are reasonable and will be utilized in order to

manage and mitigate risk and ensure public safety. A preflight checklist developed and

employed to ensure that the sUAS airworthiness will be verified before launch. Airworthiness will

be maintained by performance of routine inspections before each flight, maintaining flight and

maintenance logs to record time failure prone components.

Mark Martino Jr./Mark's Service Center Inc. requests that in a manner similar to reference 3, he be 

allowed to operate within 5

miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written approval

from the FAA. The UA may not operate within 5 nautical miles of the geographic center of a 

nontowered

airport as denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is conducted

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the

airport management must be made available to the Administrator upon request.”

Operations within five (5) miles of an airport are not anticipated to be routine, but Mark Martino 

Jr./Mark's Service Center Inc.

is requesting a mechanism to facilitate such activities without requesting a new and separate

exemption(s) should the need arise. Operations within Class B airspace are not requested due

to lack of mode C transponder.

Mandatory Operating Conditions (see O&M and Safety Lists)

Grant of the exemption to Mark Martino Jr./Mark's Service Center Inc. will be subject to the following 
mandatory

conditions, which are based upon operating conditions set forth for operation of

sUAS by public entities pursuant to Certificates of Authorization, with additional

restrictions:

• All operations to occur in Class G airspace.

• Operations to be conducted over private or controlled-access property.

• Permission from land owner/controller required before commencing any flight.

5

• Operations to occur during Visual Flight Rules Meteorological Conditions (VMC).

• Aircraft to remain within Visual Line of Sight (VLOS).

• Above Ground Level (AGL) altitude to be restricted to 400 feet.

• All operations conducted in vicinity of airport to remain more than 2.5 NM from

centerline azimuth of runway centerline measured from runway thresholds.

• All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire, or other appropriate

governmental agencies.

Operator Requirements

Mark Martino Jr./Mark's Service Center Inc. respectfully proposes that operator requirements should 

take into

account the characteristics of the particular sUAS. Certain UASs, such as the DJI Phantom 3 Advanced,

is characterized by a high degree of control and various built-in technical capabilities

that limit the potential for operation outside of the operating conditions set forth above.

Please see details in the attached O&M manuals for each in Appendix B.

Additional automated safety functions and safety enhancing features of the sUAS's include

the following:

• Auto-pilot detection of lost GPS or of insufficient satellites initiates an

immediate return to aircraft take-off location ("home")

• Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%

levels.

• If the auto-pilot detects a lost-link to the GCS for longer than 30 seconds,

landing procedure begins.

Given these safety features, Mark Martino Jr./Mark's Service Center Inc. proposes that operators of the 

sUAS should not

be required to hold a commercial or private pilot certification. Instead, operators should be

required to:

• have successfully completed, at a minimum, FAA private pilot ground

school instruction and passed the FAA Private Pilot written examination or FAArecognized

equivalents;

• have completed the manufacturer’s training or a minimum of 40 hours training

program for operation of the sUAS's.

Mark Martino Jr./Mark's Service Center Inc. notes that the FAA has found that safety factors permitted 

operation of sUASs by

operators with these qualifications in the case of operations pursuant to public COAs when the

mandatory operating conditions specified above were present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority to grant exemptions to the

requirements for and privileges associated with the grant of airmen’s certificates. 49 USC
§44701 (f).

* * *

In summary, applicant seeks an exemption from the FARs set forth above and in Appendix A

to allow commercial operations of a sUAS's conducting precision aerial inspections or surveys.

6

Approval of the exemption allowing commercial operations of the sUAS for precision inspection

and survey work will enhance safety by reducing risk. Conventional aerial photography, aerial

videography and aerial inspection operations, using helicopter or piston-powered aircraft

present risks associated with vehicles that weigh in the neighborhood of 5,000 to 7,000 lbs., or

more, carry large quantities of fuel, passengers, and, in some cases, cargo. Such aircraft must

fly to and from the location. Other conventional manned climbing or manned lifts risk safety

hazards associated with falls, electrical hazards, fuel related hazards, and inhalation hazards

associated with the structures being inspected. In contrast, a sUAS weighing less than 25 lbs.

and powered by batteries eliminates a portion of that risk given the reduced mass and lack of

combustible fuel carried on board a manned aircraft and the lack of risks associated with

manned lifts or manned climbing apparatus. The sUAS will carry no passengers or crew and,

therefore, will not expose any individuals to the risks associated with manned aircraft flights,

manned lifts or climbing hazards.

Additionally, no national security issue is raised by the grant of the requested exemptions.

Given the size, load carrying capacity, speed at which it operates, and the fact that it carries no

explosives or other dangerous materials, the sUAS poses no threat to national security.

The operation of the sUAS, weighing less than 25 lbs., for aerial photography, aerial

videography, and aerial inspections in accordance with the strict conditions outlined above,

will provide an equivalent level of safety supporting the grant of the exemptions requested

herein, including exempting Mark Martino Jr./Mark's Service Center Inc. from the requirements of Part 

21.

The sUAS’s satisfaction of the criteria set forth in Section 333 of the Reform Act—size, weight,

speed, operating capabilities, lack of proximity to airports, operation within visual line of sight,

and national security—and its showing of an equivalent level of safety as it may relate to the

requirement for FAA training, provide more than adequate justification for the grant of the

requested exemptions allowing commercial operation of the sUAS in the commercial aerial

photography, aerial videography, and aerial inspections business.

Mark Martino Jr./ Mark's Service Center Inc. is requesting this exemption for the purpose of aerial 

photography, aerial

videography, aerial inspections and other flight operations that may arise. The reason for such

a general based exemption request is to integrate a horizontal business model in order to

capitalize on vast opportunities in the future without delay in additional exemption requests. 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Mark Martino Jr./Mark's Service Center Inc. requests an exemption from the following regulations as 

well

as any additional regulations that may technically apply to the operation of the

sUAS's:

14 C.F.R. § 45.23(b): Marking of the Aircraft

The regulation provides:
When marks include only the Roman capital letter “N” and the registration

number is displayed on limited, restricted or light-sport category aircraft or

experimental or provisionally certificated aircraft, the operator must also display

on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words “limited,”

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.

The sUAS's has no entrance to the cabin, cockpit, or pilot station on which the word

“Experimental” can be placed. Given the size of the sUAS, two-inch lettering will be

impossible. The word “Experimental” will be placed on the forward fuselage in compliance with

§ 45.29(f). The equivalent level of safety will be achieved by having the sUAS marked on its

forward fuselage as required by § 45.29(f) where the pilot, observer, and others working with

the UAV will see the identification of the sUAS as “Experimental.” The FAA has issued the

following exemptions to this regulation to Aerial Pros, Exemption No. 10700, and to others,

including Exemption Nos. 8738, 10167 and 10167A.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

14 CFR § 91.203(a)(1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and

limited operating area associated with the aircraft to be utilized by Mark Martino Jr./Mark's Service 

Center Inc., an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement

for an airworthiness certificate, upon consideration of the size, weight, speed, operational

capability, and proximity to airports of the particular UAS. Our small sUAS's will be operated at

low speed in a controlled environment, at least five miles from an airport. An analysis of these

criteria demonstrates that the sUAS's operated without an airworthiness certificate, in

the restricted environment and under the conditions proposed will be at least as safe, or safer,

than a conventional aircraft (fixed wing or helicopter) operating with an airworthiness

certificate without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within a secured area. Like other civil aircraft, operations under this exemption will be tightly

controlled and monitored by the operator, pursuant to the Manual's requirements, and under 

9

the requirements and in compliance with local public safety requirements, to provide security

for the area of operation as is currently done on active construction sites.

These safety enhancements, which already apply to civil aircraft operated in connection with

construction sites, power plant sites and the like provide a greater degree of safety to the

public and property owners than conventional operations conducted with airworthiness

certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same

criteria demonstrates that there is no credible threat to national security posed by the UAS,

due to its size, speed of operation, location of operation, lack of explosive materials or

flammable liquid fuels, and ability to carry an external load no greater than two lbs.

14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in

Command; Commercial Pilot Privileges and Limitations.

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a

conventional aircraft that carries a pilot, passengers, and cargo, the sUAS in this case is

remotely controlled with no passengers or property of others on board. Section 61.133(a)
requires an individual with a commercial pilot’s license to be pilot in command of an aircraft

for compensation or hire. Mark Martino Jr. Mark'Service Center Inc. respectfully proposes that 

operator requirements

should take into account the characteristics of the particular sUAS. Mark Martino Jr./Mark's Service 

Center Inc. sUAS has a

high degree of control and various built-in technical capabilities that strictly limit the potential

for operation outside of the operating conditions set forth in the exemption application.

The sUAS has navigation and control system comprised of a Ground Control Station (GCS) and

auto-pilot system. All flights utilize precision GPS guidance. In the case of unplanned events,

the operator inputs evasive maneuvers from the control unit, and the control unit executes that

maneuver. Operator interventions include diversion to the right; initiation of holding at present

position; suspension of mission; fly back to launch point; fly to point and hold; abort mission and

land; and emergency power cut off and land (Flight Termination System).

Given these safety features, Mark Martino Jr./Mark's Service Center Inc. proposes that operators of the 

sUAS should not

be required to hold a commercial or private pilot certification. Instead, operators should be

required to:

• have successfully completed, at a minimum, FAA private pilot ground

instruction and passed the FAA Private Pilot written examination or FAA- recognized

equivalents;

• have completed manufacturer's training program or a minimum 40 hours

training program for operation of the UAS.

Mark Martino Jr./Mark's Service Center Inc. notes that the FAA has found that safety factors permitted 

operation of sUASs by

operators with these qualifications in the case of operations pursuant to public COAs where the

mandatory operating conditions specified above are present. See Federal Aviation

Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at

20-21 (July 30, 2013). The FAA has the statutory authority, granted at 49 U.S.C.§44701(f) to

waive the pilot requirements for commercial operations.

Given these conditions and restrictions, an equivalent level of safety will be provided by

allowing operation of the sUAS without a private pilot’s certificate or a commercial pilot’s

certificate, under the conditions set forth herein.

10

The risks associated with the operation of the sUAS (given its size, speed, operational

capabilities, and lack of combustible fuel) are so diminished from the level of risk associated

with private pilot operations or commercial operations contemplated by Part 61 with

conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth

above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b)

and does not rise to the level of requiring a commercial pilot to operate the aircraft under

§ 61.133(a).

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of the sUAS without

an airworthiness certificate, no standard will exist for airworthiness of the sUAS. Given the size

of the aircraft and the requirements that have presumably already been met for the sUAS (for

instance, the sUAS’s Operations and Maintenance Manual and Safety Manual and Checklist),

an equivalent level of safety will be achieved by insuring compliance with the Mark's Service Center 

Inc.

manuals prior to each flight.
14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:

No person may operate a U.S.-registered civil aircraft ...

For which an Airplane or Rotorcraft Flight Manual is not required by §21.5

(2) of this chapter, unless there is available in the aircraft a current approved

airplane or Rotorcraft Flight Manual, approved manual material, markings, and

placards, or any combination thereof.

Given the size and configuration of the sUAS, it has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because

there is no room or capacity to carry such an item on the aircraft.

The equivalent level of safety will be achieved by keeping the flight manual (see, e.g., User

Guide, Exhibit 4) at the ground control point where the pilot flying the sUAS will have

immediate access to it. The FAA has issued to others the following exemptions to this

regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 32827, and 10700.

14 C.F.R. 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure

the safety of flight. An exemption is needed from this requirement as the pilot will take

separate preflight actions, including checking for weather conditions, checking flight

battery requirements, checking takeoff and landing distances, and all other actions in the

Preflight Checklist in the Manual and Safety Checklists. These actions will provide an

equivalent level of safety.

14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

11

The sUAS is a remotely piloted aircraft and by design, does not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates

with the aircraft via radio communications. If instruction is accomplished through a training

program, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has

approved exemptions for flight training without fully functional dual controls for a number of

aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A.

The equivalent level of safety will be achieved by the manufacturer providing the training as

outlined.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c)

limits aircraft flying over areas other than congested areas to an altitude of 500 feet above the

surface, except over open water or sparsely populated areas. In those cases, the aircraft may

not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

As set forth herein, the sUAS will never operate at higher than 400 feet AGL. Because aerial

photography, aerial videography, and aerial inspections must be accomplished at relatively low

altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is

needed.

14 C.F.R § 91.121 Altimeter Settings

Mark Martino Jr./Mark's Service Center Inc. requests an exemption from 14 C.F.R. 91.121. This Part 

provides guidelines for

altimeter use below 18,000 feet mean sea level (“MSL”) in maintaining the cruising altitude or

flight level of the aircraft. Mark Martino Jr./Mark's Service Center Inc. operation of the sUAS will not 
exceed 400 feet AGL and

will be operated in a fashion that is not a sustained cruising flight such as a manned aircraft will

typically fly. The ground station has live feedback and GPS information about the sUAS,

including but not limited to the height of the sUAS, its forward velocity, and compass heading.

The operator will be able to observe and control the maximum height of the sUAS. Additionally,

the sUAS will be operated within the line of sight. Therefore, the equivalent level of safety

provided by Section 91.121 will be met.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly

to the first point of intended landing and, assuming normal cruising speed – (1) During the day,

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The sUAS batteries provide approximately 15-30 minutes of powered flight. Without an

exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20

minutes in length. Given the limitations on its proposed operations and the location of those

proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable.

Mark Martino Jr./Mark's Service Center Inc. believes that an exemption from 14 CFR § 91.151(a) is 

safe and within the scope

of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate

without compliance with 91.151(a)). Operating the small UAS, without 30 minutes of reserve

fuel does not engender the type of risks that Section 91.151(a) was meant to prevent given the

size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo 

12

also enhances its safety. Additionally, limiting sUAS flights would greatly reduce their utility. In

the unlikely event that the sUAS should run out of battery charge, it would simply land. Given its

weight and construction material, the risks are less than contemplated by the current regulation.

Mark Martino Jr./Mark's Service Center Inc. believes that an equivalent level of safety can be achieved 

by maintaining 10

minutes of reserve battery, which, allows approximately 30 minutes of flight time, but Mark Martino 

Jr./Mark's Service Center Inc. limits all flights to no greater than 20 minutes, would be more than 

adequate to return

the sUAS to its planned landing zone from anywhere in its operating area.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

(a) . . . no person may operate a civil aircraft unless it has . . . an appropriate

and current airworthiness certificate.

(b) No person may operate a civil aircraft unless the airworthiness certificate

required by paragraph (a) of this section or a special flight authorization issued

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The sUAS's fully loaded weighs no more than 25 lbs. As such, there is no ability or place to

carry certification and registration documents or to display them on the sUAS. In addition,

there is no pilot on board the aircraft.

An equivalent level of safety will be achieved by keeping these documents at the ground control

point where the pilot flying the sUAS will have immediate access to them. The FAA has issued

numerous exemptions to this regulation. A representative sample of other exceptions includes

Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a) & (b): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected
as prescribed in subpart E of this part and shall between required inspections, except as

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of

this chapter . . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section

91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate.

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots

and records of approval of the aircraft for return to service.

Maintenance of the sUAS's will be accomplished by the owner/operator pursuant to the

manuals. An equivalent level of safety will be achieved because the sUAS is small in size, will

carry no external payload, will operate only in restricted predetermined areas and is not a

complex mechanical devise. As provided in the attached Maintenance Manual and the Safety

Checklist, the trained operator of sUAS will ensure that the sUAS is in working order prior to

initiating flight, perform required maintenance, and keep a log of any maintenance that is

performed. Moreover, the operator is the person most familiar with the aircraft and is best

suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level of

safety.

13

APPENDIX B

SUMMARY OF TRIMBLE SECTION 333 EXEMPTION REQUEST

Mark Martino Jr./Mark's Service Center Inc. hereby provides pursuant to Part 11 a summary of its

exemption application to allow commercial operation of the DJI Phantom 3 Advanced sUAS's for 

aerial photography, aerial

videography, and aerial inspections. An exemption is requested from the following

regulations:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.113(a) &

(b);

14 C.F.R. 61.133(a);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) &

(b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a) & (b).