4111 Bndgeway Avenue, Columbus OH 43219 "V' T ,''\C^'"';l"^in \ •-» 

-•• - i 'Jrcn/'.iiijN.:';' 

NETJETS"^ mrK u P 2: is' 

December 15, 2010 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor 

Room W12-140 

1200 New Jersey Avenue, SE, 

Washington, DC 20590 

Re: Petition for extension of exemption No. 9807A, granted October 23, 2009 Regulatory Docket 

No. FAA-2008-1222 

Dear Sir or Madam: 

On behalf of NetJets Aviation, Inc., Operating Certificate No. DXTA401D, please accept this 

letter for petition to extend exemption No. 9807A from 14 CFR 135.225 (f). The existing 

exemption authorizes NJA pilots to operate at a military or foreign airport when IFR takeoff 

visibility is less than 1 mile or instrument approach visibility is less than V2 mile. The exemption is 

scheduled to expire on May 31, 2011. 

While the economic impact of this regulation is difficult to quantify, NJA currently operates over a 

thousand flights a month to international destinations in a competitive business environment. 

NetJets is at a competitive disadvantage to operators who are able to utilize weather minimums 

established by the authority having jurisdiction over a particular international airport. 

An equivalent level of safety is maintained by the method of documentation found in Grant of 

Exemption No. 9807A, which has been in place without negative impact for over a year. 

Thank you for your consideration of this petition. Should questions arise, please feel free to 

contact me. 

- ^ 

Sincerely, 

Eric Lamf 

Director of Operations 

yP'I^ight Operations 

Enclosure: Copy of exemption 9807A 

Cc: David Pierce 

EL/bc 

Nel|ets Inc is a Bftshire Hathaway company 
us Deparimcnt 900 i(iiH:[)C(iOence /we s w 

OtTfOnsporiatiOfl '.Vashmqion DC. 20M: 

Federal Aviation 

AdmlnlslraNon 

October 23,2009 

Exeniplion No. 9S07A 

Regulatory Docket No. FAA-2008-1222 

Mr. Diivid McConnick 

Director. Flight Tccliniciil Programs 

NelJels Aviiiiion. Inc. 

4111 J3ridgc\va)'AveJUie 

Columbus, 01-143219 

Dear Mr. McCornilck: 

Thislelter is to inlbnii you thafwc have granted your request for exemption. It \ransmi\s our 

decision, explains its basis, and gives you tlie conUidons and liniitaiions of the exemption, 

including the dale it ends. 

The IJiisis f(»r Our Decision 

By letter tkUed.March 18,.2009, you petitioned (he Federal Aviation Adniinislration (FAA) c)ii 

behalfoTNetJets Aviation, Inc. (NJA). for an exemption from § 135.225(f) of Title H,Code 

of Federal Regulations (14 CFR) lo ihc extent necessary (o allow NJA to make instrument 

flight lulcs (!FR) lakeofi's from foicign find military iiiiports when the visibility is less than 

1 statute mile or.makc.an instrument [ipproach when (he.visibility is less than V2 mile. 

The FAA has determined (hat good.cause exists for not publishing a summary oi'the petition 

in the Federal Register because the requested exemption would not set a piecedent, nnd tiny 

delay iiracling on iliis petition would be detrimeiunl to NJA.. 

The FAA has issv\ed a grant of exemption in circumstanees similar in ail mmerial respects to 

ilio.se presented in your petition. \u Gnint of f-xemption No. 9752 (copy enclosed), the FAA 

found it in the public interest to permit Ni[,,lne. (NJl), to make IFR lakcoffs from foreign, and 

military airports when the visibility is less thaii 1 statuleinile or make an instriimeni approach 

when the visibility is less than Yi mile, subject to certain conditions and limitations. Thistuiding is based on the tact that it is in the public interest and maintains a level ol'safely 

equivalent to that.providcd by the current regulations. 

AFS-09'170-12 
Weather.minimums for aircraft operating under part 135 are prescribed in §§ 91.175 and 

135.225. Section 135.225 restricts a pilot operating under part 135 from making a takeoff at 

any foreign civil airport when the visibility is less llian 1 mile. Therefore, (akeoffs with less 

than 1 mile visibility at these foreign civil airports caiUAov be authorized ihiough opevalions 

specifications. 

NJl has extensive experience operating to lower minimums domestically under part 135 and 

worldwide under pai! 91. NJl crews receive training in low visibility operations as part of 

their FAA-approved part.l21 training program and routinely utilize the lower minimums 

when flying into foreign airports while operating under pari 91. FuiHiennore, since no 

miiiimum restrictions are placed on part 121 operators and NJl trains to part 121 standards, 

the FAA believes that an eciuivalenl level of safety could be maintained while operating to 

foreign or military airporis under pari 135-

One of the conditions of the grant of exemption to NJl was (hat the crews utilizing the 

exemption had to be trained and qualified to the standards of part 121. This is because 

part 121 does not contain the supplemental restrictions on landing weather minima for foreign 

or mitilui7 airports found in part 135. Since Nil trains to the sunie.standards as other aiv 

carriers operating under part 121, it was appropriate to permit it relief from part 135 such that 

it can operate in a similar fashionas an air carrier operating under part 121. 

Having reviewed your reasons for requesting an exemption, 1 find that— 

• they do not differ materially from those presented by the petitioner in the enclosed grant of 

exemption; 

• the reasons staled by the FAA for gianting the enclosed exemption also apply to the 

situation you present; and 

• a grant of exemption is in the public interest. 

Our Occision 

Under the auihorily contained in49U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to.me, 1 hereby grant NetJets Aviation, Inc., an exemption from 

14 CFR § 135.225(0 to the extent necessary to allow NJA pilots to operate to a militaiy or 

foreign airpoil while complying wiih applicable instrument approach procedures and weather 

minimums prescribed by the State and/or authority having jurisdiction over that airport, 

subject to the conditions and limits described below. 

Conililions imd Limitatiuns 

1. Provisions of this exemption apply to all turbojet-powered airplanes operated by 

NJA. 

2. Crews utilizing this exemption must have been trained and qualified to the 

standards specified under part 121, subparts N and 0. 
3 

3. Airporis at which NJA intends lo utilize the provisions of this exemption must 

have had approach procedures developed in accordance with U.S. Terminal 

Instrument Procedures or International Civil Aviation Organization Procedures for 

Air Navigations Services criteria. 

This exemption terminates on May 31, 2011, unless sooner superseded or rescinded. 

Sincerely, 

Chester D. Dalbey 

AcLi'ng Director, Flight: Standards 

Service 

Fnclosure