AFS-08-329-E 

May 25, 2010 

 Exemption No. 4416M 

 Regulatory Docket No. FAA-2002-12831 

Mr. Paul W. Railsback 

Director of Operations 

Air Transport Association of America, Inc. 

1301 Pennsylvania Avenue, NW., Suite 1100 

Washington, DC 20004-1707 

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 and describes its effect. 

The Basis for Our Decision 

By letter dated April 20, 2010, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Air Transport Association of America, Inc. (ATA), 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 ATA. 
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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 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. 

The Effect of Our Decision 

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

September 30, 2012, unless sooner superseded or rescinded. 
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All conditions and limitations of Exemption No. 4416, as amended, remain the same. This 

letter must be attached to, and is a part of, Exemption No. 4416. 

Sincerely, 

/s/ 

John W. McGraw 

Acting Director, Flight Standards 

 Service