AFS-16-11910-E

September 6, 2016

 Exemption No. 4416Q

 Regulatory Docket No. FAA-2002-12831

Ms. Sophia Ghezai

Director, Aviation Safety and Operations

Airlines for America

1275 Pennsylvania Avenue, NW. Suite 1300

Washington, DC 20004

Dear Ms. Ghezai:

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, describes its effect, and lists the conditions and 

limitations.

The Basis for Our Decision

By letter dated May 20, 2016, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Airlines for America (A4A) for an extension of Exemption No. 4416, as amended. 

That exemption from § 121.424(a)(1), (b)(3), 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 (14 CFR) 

allows part 119 certificate holders conducting operations under part 121 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.

When A4A previously petitioned for this exemption, the FAA granted relief to the petitioner’s 

member airlines, as well as to “other qualifying part 119 certificate holders.” However, in an 

effort to manage exemptions granted by the FAA and to facilitate operator compliance with the 

conditions and limitations of a grant of exemption, the FAA is no longer including “other 

qualifying part 119 certificate holders” in grants of exemption. The FAA recognizes that 
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several certificate holders that are not members of A4A have been authorized use of this 

exemption. In order to provide sufficient time for these certificate holders to petition for similar 

relief and for the FAA to address the petitions, the FAA is extending this exemption with relief 

granted to other qualifying certificate holders for a limited period of six months. 

The FAA highlights that the Regional Airline Association (RAA) has been granted a separate 

exemption to allow its part 121 member airlines to conduct training and checking of pilots on 

airplanes that require two flightcrew members for the required preflight inspection, both interior 

and exterior, using approved advanced pictorial means (Exemption No. 17066). Exemption No. 

17066 applies to RAA members only. 

Any part 119 certificate holder that is not a member or associate member of A4A or RAA 

wishing to exercise the relief provided by this grant of exemption after March 31, 2017 must 

submit a petition for similar relief to the docket. Once the FAA has received the certificate 

holder’s petition for exemption, after analysis of the petition, if appropriate, the FAA will amend 

Attachment 1 to Exemption No. 4416 to include the additional certificate holder. After March 

31, 2017, a certificate holder may only exercise the relief provided by the grant of exemption 

when it is listed in Attachment 1 to Exemption No. 4416, as amended. 

The FAA notes that similar exemptions previously included relief from § 61.157(a). The FAA 

further notes that Appendix A to part 61 and the reference to Appendix A found in 14 CFR 

61.157(a) were removed from 14 CFR as part of the “Pilot, Flight Instructor, Ground 

Instructor, and Pilot Schools Certification Rules” final rule (62 FR 16220, April 4, 1997). Thus, 

as these sections no longer exist, the FAA is no longer including relief from § 61.157(a) in 

exemptions of this nature. 

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 A4A member 

airlines.

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. §§ 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, Airlines for America is hereby granted an extension that 

allows part 119 certificate holders conducting operations under part 121 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, subject to the 

following conditions and limitations.
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Conditions and Limitations

1. Each certificate holder desiring to use the provisions of this exemption must develop still 

and/or motion pictures providing distant and detailed close-up 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 FAA Principal 

Operations Inspector assigned to that certificate holder. 

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

This exemption terminates on March 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John Barbagallo

Deputy Director, Flight Standards Service