800 Independence Ave., S.W.

Washington, DC 20591

April 18, 2016

Mr. Keith Siilats

304 East 6th Street

New York, NY 10003-8701

Dear Mr. Siilats:

This is in response to your letter dated January 27, 2016, posted to the public docket 

(No. FAA-2016-2646) 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 provided--

(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 lighterthan-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 turbine-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 specifications, 

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 of 
2

paragraph (f) of this section, except that, the owner or operator of a turbinepowered 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 to 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, the 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 based on the current 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 will 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 rulemakings, you can find the status on the Department of 

Transportation’s (DOT) website (http://www.dot.gov/regulations/report-onsignificant-rulemakings). 

 For non-significant rulemakings, you can find the status on the DOT’s semiannual 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