800 Independence Ave., S .W. Washington, DC 20591

April 18 , 2016

Mr. Keith Siilats

304 East 6 th Street

New York

, N Y 10003

- 8701

Dear Mr. Siilats :

This is in response to your letter dated January 27

, 2016

, posted to the public docket (No

. FAA

- 201 6

- 2646 ) petitioning the Federal Aviation Administration (FAA) to initiate rulemaking to amend § § 91.213 and 91.409 of Title 14 Code of Federal Regulations (14 CFR)

. In your petition, you request that §§ 91.213 and 91.409 be amended to read as follows:

Sec. 91.213 Inoperative instruments and equipment ; Make the following change : (d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an approved Minimum Equipment List pr ovided

-- (1) The flight operation is conducted in a

-- [(i) Rotorcraft, nonturbine

- powered airplane, ***ADD*** turbine powered very light (under 6000 pounds MTOW) airplane ***, glider, or lighter

- than

- air aircraft, powered parachute, or weight

- shift

- control aircraft, for which a master minimum equipment list has not been developed; or] (ii) Small rotorcraft, nonturbine

- powered small airplane, ***ADD*** turbine powered very light (under 6000 pounds MTOW) *** airplane, glider, or lighter

than

- air aircraft for which a Master Minimum Equipment List has been developed;

and

Sec. 91.409 Inspections; Make the following change: e) Large airplanes (to which part 125 is not applicable), turbojet multiengine airplanes, turbopropeller

- powered multiengine airplanes, and t urbine

- powered rotorcraft. No person may operate a large airplane, turbojet multiengine airplane, turbopropeller

- powered multiengine airplane, or turbine

- powered rotorcraft unless the replacement times for life

- limited parts specified in the aircraft speci fications, type data sheets, or other documents approved by the Administrator are complied with and the airplane or turbine

- powered rotorcraft, including the airframe, engines, propellers, rotors, appliances, survival equipment, and emergency equipment, is inspected in accordance with an inspection program selected under the provisions of2

paragraph (f) of this section, except that, the owner or operator of a turbine

powered rotorcraft or ***ADD*** turbine powered very light airplane (under 6000 pounds MTOW) *** may elect to use the inspection provisions of Sec. 91.409(a), (b), (c), or (d) in lieu of an inspection option of Sec. 91.409(f).

In accordance with 14 CFR § 11.73 , the FAA must use the following criteria when making a decision as to whether or not t o amend current regulations based on a petition for rulemaking:

1) The immediacy of the safety or security concerns you raise; 2) The priority of other issues the FAA must deal with; and 3) The resources we have available to address these issues

.

Each year, t he FAA prioritizes its rulemaking projects based on issues that are crucial to the safety of the aviation community and the traveling public to ensure the FAA delivers the most value to the aviation system

.

After reviewing your request b ased on the curren t priorities for the FAA and the guidelines found in § 11.73, we determined the issue you raised does not meet the criteria
to pursue immediate rulemaking at this time. However, your comments and arguments for the proposed rule change in your petition wil l be placed in a database, which we will examine when we consider future rulemaking to these areas

.

If the FAA does pursue rulemaking in this area in the future, you would be able to track it through one of the two following websites :

 For significant r ulemakings, you can find the status on the Department of Transportation’s (DOT) website ( http://www.dot.gov/regulations/report

- on

significant

- rulemakings )

.

 For non

- signific ant rulemakings, you can find the status on the DOT’s semi

annual regulatory agenda , through the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affair’s (OIRA) Unified Agenda website ( http://www.reginfo.gov/public/do/eAgendaMain ).

For the reasons above, we are dismissing your petition for rulemaking in accordance with 14 CFR § 11.73.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service