November 19, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave. S.E.

Washington, D.C. 20590

RE: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 

2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 

C.F.R. 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

C.F.R. Part 11, The University of Idaho College of Law, Small Business Legal Clinic files this 

petition on behalf of Gulo GIS Consulting, LLC (“Gulo”), an operator of unmanned aircraft 

systems (UAS) used for agricultural surveillance and research. 

Specifically, Gulo seeks an exemption for the operation of two UAS platforms: (1)The 

Universeye Finwing Penguin, and (2) The DJI Phantom 3 Professional. The following 

exemption applications provides a detailed explanation of why Gulo is seeking this exemption 

and what steps Gulo will take to ensure the safe operation of both platforms while complying 

with all applicable rules and laws. Please do not hesitate to contact either Jeremy Tamsen or 

Cody Earl at the University of Idaho College of Law should you have any questions or concerns. 

Respectfully, 

Jeremy Tamsen

Cody Earl 
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Publishable Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the Federal 

Register, should it be deemed that publication is needed:

Petitioner seeks an exemption from the following Federal Aviation Regulations (FAR):

21(h); 43.7; 43.11; 45.11; 45.27; 45.29; 61.113(a) and (b); 61.23; 91.7(a); 

91.9(b)(2) and (c); 91.103(b)(2); 91.105; 91.109; 91.113(b); 91.119(c); 91.121; 

91.151(a); 91.203 (a) and (b); 91.215; 91.403; 91.405(a); 91.407(a)(1); 

91.409(a)(1) and (a)(2); 91.417(a) and (b).

Approval for the exemption for Petitioner will allow commercial operation of the Universeye 

Finwing Penguin and the DJI Phantom 3 Professional for the collection of aerial data, aerial 

inspection, aerial photography, and aerial videography. The requested exemption should be 

granted because the operation of these two unmanned aircraft systems (UAS) will strictly adhere 

to the conditions outlined below, will provide an equivalent level of safety, and will benefit the 

public in a variety of ways. Furthermore, this exemption request comports perfectly to the seven 

factors Congress has directed the FAA to consider when approving Section 333 exemption 

petitions: (1) size; (2) weight, (3) speed, (4) operational capability, (5) proximity to airports, (6) 

proximity to populated areas, and (7) operation within visual line of sight. Specifically, the 

UAS’s are small in size and will be operated at slow speeds close to the ground. The substantial 

increase of safety and decrease of human life, coupled with low risk use of UAS’s to conduct 

these operations, weigh heavily in favor of granting the exemption. 

I. Petitioner’s Contact Information

Gulo GIS Consulting, LLC

Jeffrey J. Lonneker, General Manager

1022 E. 8th Street

Moscow, Idaho 83843

Phone: (208) 615-5452

Email: jeff@gulogisconsulting.com

Counsel for Petitioner

The University of Idaho, College of Law

Small Business Legal Clinic

514 W. Jefferson, Room 123

Boise, Idaho 83720-0051

Phone: (208) 364-4074
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II. Proposed Operations

a. Platforms

The requested exemption will permit Petitioner to operate both: (i) the Universeye Penguin, and 

(ii) the DJI Phantom 3 Professional. Both of these platforms have been exempted from the 

certification procedures for products and parts in other exemption petitions (see exemption nos. 

11318 and 13101), and therefore do not require a Certification of Airworthiness for operations. 

The UAS platforms will be operated in a manner that conforms to guidelines, rules, and 

regulations applicable to a Section 333 exemption, including such restrictions and conditions 

which are expressed in this petition.

i. Universeye Finwing Penguin

The Penguin consists of a lightweight battery operated fixed wing aircraft, a computer based 

ground control station (GCS), onboard cameras and associated communications equipment. The 

aircraft carries an onboard geographic referenced camera that allows it to perform precision 

photogrammetry and crop scouting at the resolutions necessary for precision agriculture. This 

high-resolution data can direct prescriptions for variable seeding rates and precision application 

of fertilizer and agricultural chemicals. 

The petitioner requests 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 previously determined that this aircraft meets the conditions 

of Section 333 (See exemption No. 11724 – Galaxy UAV Systems; see also exemption No. 

11571 – HAZON Solutions, LLC).

ii. DJI Phantom 3 Professional

The requested exemption would permit commercial operation of the DJI Phantom 3 Professional, 

which weighs less than 55 lbs. and travels at significantly less than 87 knots, by Petitioner. The 

DJI Phantom 3 Professional is entirely battery operated and will be operated by an individual(s) 

during daytime Visual Flight Rules (VFR) conditions and within visual line of sight (VLOS) of 

the pilots. Furthermore, the DJI Phantom 3 Professional will abide by all rules and regulations 

regarding the certain distances away from airports or heliports the platform must remain while 

being operated. 

The DJI Phantom 3 Professional has the following specifications:

Weight (Including Battery and Propellers) – 1280 gram [approximately 2.82 lbs]
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Diagonal Size (Including Propellers) – 590 mm

Max Ascent Speed – 5 m/s

Max Descent Speed – 3 m/s

Hover Accuracy - Vertical +/- 0.1m

- Horizontal +/- 1.5m

Max Speed - 16 m/s

Max Altitude Above Sea Level – 6000m

b. The Crew

The Crew for the operation of both UAS’s will consist of a pilot in command (PIC) and at least 

one visual observer (VO). The 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.

The PIC and VO will receive training in the operation(s) of both UAS’s generally and will 

receive up-to-date information on the UAS’s to be operated pursuant to this grant. The PIC will 

have completed, at a minimum, 10 hours of UAS flight training with each specific UAS –

Universeye Finwing Penguin or DJI Phantom 3 Professional – prior to commercial operation of 

said UAS, and will be required to participate in annual training thereafter. 

c. Flight Conditions 

The petitioner requests exemption to fly UAS platforms in Class G airspace nationwide at or up 

to 500 feet above ground level (“AGL”), unless otherwise prescribed by an ATO issued COA, 

and under controlled conditions over rural agricultural property. Petitioner will work with the 

local FSDO when planning operations. Petitioner will only operate its UA in visual

meteorological conditions (“VMC”). The UA will at all times be no less than 500 feet below and 

no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct operations 

unless visibility is at least 3 statute miles from the PIC. The flight crew will always make a 

safety assessment of the risk of every operation, and will only operate when it is determined that 

no hazards are present. 
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The 500 feet AGL limitation is in line with the Small UAS Notice of Proposed Rulemaking 

(NPRM). Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg. 9543 at 9547 

(proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.)). The FAA 

determined that this higher ceiling was a safe limit because: 

“most manned aircraft operations take place above 500 feet. Specifically, most manned 

aircraft operations conducted over uncongested areas must be flown at an altitude above 

500 feet AGL, while most manned aircraft operations conducted over congested areas 

must be flown at an even higher altitude. Thus, a 500-foot altitude ceiling for small UAS 

operations would create a buffer between a small unmanned aircraft and most manned 

aircraft flying in the NAS... [T]here is significantly less air traffic at or below 500 feet 

than there is above 500 feet altitude. As a result of this difference in air-traffic density, 

the FAA has determined that small UAS operations would not pose a significant risk to 

manned aircraft operations taking place below 500 feet altitude if proper precautions are 

taken by the small UAS operator” Id. at 9562-63. 

Should the FAA not allow flights up to 500 feet AGL under this exemption petition, petitioner 

requests exemption for:

(i) flights limited to 200 feet AGL, in accordance with the “blanket” COA which now 

automatically accompanies new §333 exemption grants, under the FAA’s summary grant 

process for Section 333 exemptions (see https://www.faa.gov/news/updates/?newsId=82245; 

see also https://www.faa.gov/news/updates/?newsId=82485); or, in the alternative

(ii) flights limited to 400 feet AGL, in accordance with prior exemptions for the two UAS 

platforms for which petitioner requests exemption (For Universeye Finwing Penguin: see 

exemption No. 11724 – Galaxy UAV Systems; see also exemption No. 11571 – HAZON 

Solutions, LLC; For DJI Phantom 3: see exemption No. 13101 – Elevated Vision, LLC). 

Note: Petitioner will adhere to any conditions and restrictions set forth in any grant of exemption 

issued by the FAA pursuant to this petition, but respectfully requests an exemption allowing 

flights up to 500 feet AGL. 

d. Proposed Uses

The petitioner requests authority to use the above UAS platforms for the following commercial 

usage settings:

1. precision agriculture;

2. 2D and 3D mapping;

3. Photography;

4. Cinematography;

5. Aerial Data Collection;
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6. Filmmaking;

7. Live and taped broadcasting;

8. Visual Inspection - primarily towers, poles, pipelines, powerlines, cables, 

bridges, flare stacks, chimneys, vertical structures, solar arrays, wind generators, pow

er stations & substations, coal ash ponds, absorbers, and buildings;

9. Real estate;

10. Golf courses;

11. Orthographic photos;

12. Special Events;

13. Construction progress;

14. Public service - Primarily: 

a. search & rescue,

b. law enforcement,

c. fire,

d. security,

e. disaster management & relief,

f. wildfires,

g. floods,

h. hurricanes,

i. news broadcasting, and

j. tornados;

15. Banner towing (for advertising);

16. Announcements;

17. Radio Frequency directional finding - Primarily: 

a. fire & rescue,

b. animal tracking,

c. Alzheimer patient tracking,

d. non-cooperative satellite communication interception,

e. stolen vehicles, 

f. high value assets,

g. hikers, and

h. skiers; 

18. Radiation detection;

19. Noxious gas detection;

20. Forestry &logging;

21. Wildlife management;

22. Insurance assessments;

23. Surveys;

24. Mining;

25. Volumetric analysis;

26. Research and Development;
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27. Traffic monitoring; and

28. Sporting events.

III. Proposed Conditions of Exemption

In accordance with the exemptions already granted to other operators, petitioner proposes the 

following conditions apply to the exemption grant issued pursuant to this petition:

1. Operations will be limited to the Universeye Penguin and 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 the exemption granted pursuant 

to this petition. 

2. Operations for the purpose of closed-set motion picture and television filming will not 

be permitted. 

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

petitioner will 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 will be operated at an altitude of no more than the altitude listed in the 

restrictions and conditions set forth by the FAA grant. Altitude will be reported in feet 

AGL. 

5. The UA will 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 will utilize a visual observer (VO). The UA will 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 will be able to communicate verbally at all times; electronic messaging or 

texting will not be permitted during flight operations. The PIC will be designated before 

the flight and will not transfer his or her designation for the duration of the flight. The 

PIC will ensure that the VO can perform the duties required of the VO. 

7. The FAA 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 will be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, the 

conditions and limitations listed in the FAA exemption take precedence and must be 

followed. Otherwise, the operator will follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It will be 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 will 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 will petition for an amendment to its grant of exemption. The petitioner will 

contact the FAA’s UAS Integration Office (AFS−80) 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, will undergo a 

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

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

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

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

9. The operator will be 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 will conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection will 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 will 

be 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 will follow the UAS manufacturer’s maintenance, overhaul, 

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

components. 

12. Each UAS operated under an exemption granted pursuant to this petition will comply 

with all manufacturer safety bulletins. 

13. Under an exemption granted pursuant to this petition, a PIC will hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate. The PIC will 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 will 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. 
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14. The operator will 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 an exemption granted pursuant to this petition, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours and currency will 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 an exemption granted pursuant to this petition will be 

conducted only under the terms of the exemption granted pursuant to this petition. 

However, training operations will only be conducted during dedicated training sessions. 

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

flight operations will be considered nonparticipants, and the PIC will operate the UA with 

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

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

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

under special visual flight rules (SVFR) will not be authorized. 

16. The UA will 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 FAApublished 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 will be made available to the Administrator or 

any law enforcement official upon request. 

17. The UA will 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 will return to a predetermined location within the private or controlled-access property. 

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

20. The PIC will be 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 will be conducted in accordance with an ATO-issued COA. The petitioner will 

apply for a new or amended COA if it intends to conduct operations that cannot be 

conducted under the terms of a COA issued pursuant to this petition. 
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22. All aircraft operated in accordance with this exemption will 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 will 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 will be available to the 

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

documents will be made available to the Administrator or any law enforcement official 

upon request. 

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

activities at all times. 

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

26. All Flight operations will 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 will 

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 will cease immediately in a manner ensuring the 

safety of nonparticipating persons; and 

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

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

risk of operating closer to those objects and determines that it does not present an 

undue hazard. 

The PIC, VO, operator trainees or essential persons will not be considered 

nonparticipating persons under this exemption. 

27. All operations will 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. 

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

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

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

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.
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IV. Privacy

There is little concern that the proposed flights will cause invasion of privacy because of the 

manner in which the flights will be conducted. The flights will occur over rural, private farmland 

that Petitioner has been contracted to fly over. At all times of operation, the platform’s onboard 

camera will be focused on the ground area, which Petitioner has been hired to fly over. At no 

point during operation will the platform’s cameras focus on nonparticipating persons. Upon 

completion of each scheduled flight, the platform’s data will be collected, the file will be 

trimmed to only contain pertinent images of the field being monitored, and the data collected will 

never be shared to any person or entity other than those persons employed by Petitioner and 

Petitioner’s client(s). 

Petitioner intends to conduct flight operations in Idaho, among other places. Idaho Code section 

21-213 requires that any operator of a UAS adhere to specific consent requirements before 

capturing information about, or photographs of, individuals. The petitioner will at all times 

adhere to the requirements of I.C. 21-213. Therefore this state law does not significantly affect 

the privacy concerns regarding the grant of an exemption pursuant to this petition.

V. Public Interest and Safety

Using UAS’s to conduct surveillance of agriculture in lieu of manned aircraft will enhance safety 

and reduce the impacts on the environment. Specifically, the small size and maneuverability of 

the UAS’s will create much less risk of injury upon a person than would be present if a large, 

manned-aircraft were to do similar surveilling. Furthermore, with both UAS’s being operated 

solely by battery power, the environmental impact due to emissions is essentially non-existent. 

The granting of this petition will further promote public interest in that there is a potential for 

economic growth, both for Petitioner and the agricultural industry as a whole. With the services 

provided by Petitioner, through the use of UAS, members of the agricultural industry will be able 

to attain data and statistics at a fraction of the current costs. As the agricultural industry begins to 

reap the benefits of obtaining the same information for less cost, it can be assumed that the 

industry will pass on the cost reduction to individuals in and around their area. 

In sum, there are three main public interests which favor the granting of this petition: (1) 

providing a much safer method in which to collect and compile data, which is critical to 

sustainable agriculture operations; (2) reducing, if not eliminating altogether, the environmental 

impact of surveilling agricultural operations; and (3) the potential for economic growth. In sum, 

Petitioner’s use of UAS’s to assist the agricultural industry is a benefit not only to farmers, but to 

the public as a whole, and the environment. 
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VI. Regulations from Which Exemption is Requested 

FAR Provision Description of Provision FAA Exemption Decision

21(h) Requirements regarding 

airworthiness certificates

Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11111, 11110, 11114, 

11136, 11138, 11150, 11153, 

11156, 11157, 11166, 11167, 

11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 

11192, 11193, 11195

43.7 Persons authorized to approve 

aircraft, airframes, aircraft 

engines, propellers, 

appliances, or component 

parts for return to service after 

maintenance, preventive 

maintenance, rebuilding, or 

alteration

No. 11208

43.11 Content, form, and disposition 

of records for inspections 

conducted under parts 91 and 

125 and §§135.411(a)(1) and 

135.419

No. 11208

45.11 Marking of products No. 11208

45.27 Location of marks on fixedwing aircraftNo. 11188

45.29 Size of Marks Nos. 11136, 11157, 11170, 

11185, 11193

61.113(a) and (b) Private pilot privileges and 

limitations: Pilot in command

No. 11318

61.23 Medical certificates: 

Requirement and duration

No. 11318

91.7(a) Civil aircraft airworthiness Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11136, 11138, 

11150, 11153, 11156, 11157, 

11158, 11160, 11161, 11166, 

11167, 11170, 11171, 11172, 

11174, 11177, 11178, 11184,

11185, 11188, 11189, 11191, 

11192, 11193, 11195, 11204
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91.9(b)(2) and (c) Civil aircraft flight manual, 

marking, and placard 

requirements

Nos. 11136, 11174, 11185

91.103(b)(2) Preflight action No. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11138, 11150, 11153, 

11156, 11158, 11160, 11161, 

11166, 11167, 11171, 11172, 

11176, 11177, 11178, 11184, 

11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 

11204

91.105 Flight crewmembers at 

stations

No. 11185

91.109 Flight instruction; Simulated 

instrument flight and certain 

flight tests

Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 

11138, 11150, 11153, 11156, 

11157, 11166, 11167, 11170, 

11171, 11174, 11177, 11184, 

11185, 11189, 11191, 11192, 

11193, 11194, 11195, 11206, 

11208

91.113(b) Right-of-way rules: Except 

water operations

No. 11238

91.119(c) Minimum safe altitudes: 

General

Nos. 11162, 11163, 11164, 

11165, 11166, 111080, 11109, 

11110, 11111, 11112, 11114, 

11136, 11138, 11150, 11153,

11156, 11160 11161, 11166, 

11167, 11170, 11171, 11172, 

11174, 11176, 11178, 11185, 

11188, 11189, 11190, 11193

91.121 Altimeter settings Nos. 11162, 11163, 11164, 

11165, 11166, 111080, 11109, 

11136, 11138, 11150, 11153, 

11156, 11160 11161, 11166, 

11167, 11170, 11171, 11174, 

11176, 11178, 11185, 11188, 

11189, 11190, 11193

91.151(a) Fuel requirements for flight in 

VFR conditions

Nos. 11110, 11153, 11156, 

11161; 111109, 11110, 11112, 

11136, 11138, 11150, 11153, 

11156, 11160 11161, 11166, 
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11167, 11170, 11171, 11172, 

11174, 11176, 11178, 11185, 

11188, 11189, 11190, 11193

91.203(a) and (b) Civil aircraft: Certifications 

required

Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 

11153, 11156, 11157, 11170, 

11171, 11172, 11174, 11176, 

11177, 11178, 11184, 11185, 

11188, 11188, 11189, 11191, 

11192, 11193, 11195

91.215 ATC transponder and altitude 

reporting equipment and use

No. 11185, 11195

91.403 Maintenance, Preventative 

Maintenance, and Alterations: 

General

No. 11185

91.405(a) Maintenance, Preventative 

Maintenance, and Alterations: 

Maintenance required

Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 

11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 

11185, 11188, 11188, 11189, 

11191, 11192, 11193, 11195, 

11204

91.407(a)(1) Operation after maintenance, 

preventive maintenance, 

rebuilding, or alteration

Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 

11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 

11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 

11204

91.409(a)(1) and (a)(2) Inspections Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 

11109, 11110, 11111, 11112, 

11114, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 
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11160, 11161, 11166, 11167, 

11170, 11171, 11172, 11174, 

11176, 11177, 11178, 11184, 

11185, 11188, 11189, 11191, 

11192, 11193, 11195, 11204

91.417(a) and (b) Maintenance records No. 12820