12/2/2015 

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R. 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, ewalk Software Corporation files this petition for exemption from the listed Federal

Aviation Regulations (“FARs”) to allow commercial operations of small Unmanned Aircraft Systems

(“UAVs”) for real estate photography. Specifically, petitioner seeks an exemption from the “FARs” listed

in Section VIII, so long as such operations are conducted within and under the conditions outlined herein

or as may be established by the FAA in a grant of this petition, or as required by Section 333. This request

is substantially similar to other data collection petitions previously approved, and should be considered

under the expedited summary grant procedure. Additionally, this petition should be eligible for the

summary grant because of the voluntary altitude restriction to 200 feet above ground level (AGL).

Approval of the exemption for petitioner will allow commercial operation of the DJI Phantom 3 or similar 

UA for real estate photography and video in Class G airspace nationwide, or as otherwise prescribed by an 

Air Traffic Organization (ATO) issued COA. The UA covered by this petition is a small battery-powered 

craft, weighing between approximately 2.2 lbs. (1 kg.) and 2.74 lbs. (1.24 kg.), inclusive of battery and 

payload. Operation of the UAs under the strict conditions proposed below will provide an equivalent level 

of safety, as Congress intended, while still allowing commercial operations. Operations using these UAs 

are far safer than conventional operations conducted with helicopters and fixed-wing aircraft that weigh 

thousands of pounds, carry highly flammable fuel, and operate in close proximity to the ground, trees, 

infrastructure, and people. 

Congress directed the FAA to consider seven factors in deciding whether to approve Section 333 

exemption petitions - size, weight, speed, operational capability, proximity to airports, proximity to 

populated areas, and operation within visual line of sight. In this case, each factor supports the exemption 

request. In particular, the UA is small, and will operate at slow speeds and close to the ground. It will 

be able to more safely and efficiently take aerial photography of real estate. The substantial 

increase of safety and decrease of risk to human life and to property weighs heavily in favor of 

granting the exemption.

For your ease in reviewing this petition, please refer to the table of contents which begins on page 2. 

If we can provide any additional information to assist your understanding or review of this document, 

please do not hesitate to contact us at 408-458-0492 or art@ewalk.com. 

Art Clark

CEO

eWalk Software Corporation

1
Table of

Contents

I. Publishable Summary.............................................................................................................. 3

II. Petitioner’s Contact Information ............................................................................................. 3

III. Proposed Operations................................................................................................................ 4

A. The UA........................................................................................................................... 4

B. The Crew ........................................................................................................................ 5

C. Flight Conditions............................................................................................................ 5

D. Flight Operations............................................................................................................ 5

IV. Aircraft and Equivalent Level of Safety.................................................................................. 5

V. Proposed Conditions of the Exemption................................................................................... 6

VI. Privacy..................................................................................................................................... 9

VII. Public Interest and Safety........................................................................................................ 9

VIII.Regulations from Which Exemption is requested. These are FARs as to which eWalk 

Software Corporation wishes the same determination to be made as has been made 

previously.............................................................................................................................. 11

2
I. Publishable Summary

Pursuant to 14 C.F.R. § 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27;

14 C.F.R. 45.29; 14 CFR 61.23(a) and (c); 14 CFR 61.101(e)(4) and (5) 14 CFR

61.113(a); 14 CFR 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R.

91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R.

91.113(b); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R.

91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R.

91.407(a)(1); 14 C.F.R. 409(a)(1) and (a)(2); and 14 C.F.R. 91.417(a) and (b)

to operate commercially a small unmanned aircraft system (UA) (2.74 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation 

of the DJI Phantom 3 for real estate photography in Class G airspace nationwide, or 

as otherwise prescribed by an Air Traffic Organization (ATO) issued COA. The 

requested exemption should be granted because operation of small UAs, weighing 

between approximately 2.2 lbs. (1 kg.) and 2.74 lbs. (1.24 kg.) inclusive of battery 

and payload, conducted in the strict conditions outlined below, will provide an 

equivalent level of safety, while still allowing commercial operations. The 

lightweight aircraft covered by the exemption are far safer than conventional 

operations conducted with helicopters and fixed-wing aircraft weighing thousands of 

pounds and carrying highly flammable fuel, and operating in close proximity to the 

ground, trees, infrastructure, and people. The seven factors Congress directed the 

FAA to consider when approving Section 333 exemption petitions - size, weight, 

speed, operational capability, proximity to airports, proximity to populated areas, and 

operation within visual line of sight – each support the request. In particular, the 

aircraft are small, and will operate at slow speeds, and close to the ground in order to 

more safely and efficiently conduct inspections that would otherwise involve a risk of 

death to the inspectors. The substantial increase of safety and decrease of risk to 

human life, coupled with the low risk use of UAs to conduct these operations, weigh 

heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

Art Clark

CEO

eWalk Software Corporation

1658 Woodrose Ave

Santa Cruz, CA 95062

3
III. Proposed Operations

A. The UA

The requested exemption will permit petitioner to operate the DJI Phantom 3 

Professional, and other similar Phantom Models.

Each UA proposed under this exemption has the ability to hover and move in the 

vertical and horizontal planes simultaneously. Please refer to the following chart detailing the 

technical specifications.

Airframe Phantom 3 Professional

Flight 

System

Includes Main Controller (MC), Internal Measurement Unit (IMU) with a 

built-in internal sensor, barometric altimeter (which measures attitude and 

altitude), and compass, GPS, GLONASS, radio receiver (Rx), and 

Electronic Speed Controllers (ESCs) to manage motor speed.

Max. 

Speed

16 m/s (ATTI mode, no wind)

Weight, w/ 

battery & 

propellers

1280 g

Transmitter 2.400 GHz – 2.483 GHz

Motors DJIP3-095 2312A

Propellers 4 x 9”

Video Link Lightbridge

Gimbal Zenmuse

Batteries 6000 mAh LiPo 25

OSD Lightbridge

No Fly Zones DJI software will not allow aircraft to take off in a no fly zone

Automatic 

Return to Home

Aircraft will automatically return to home if signal lost, or PIC pushes 

return to home button

Previously 

approved 

Exemption Nos.

11153; 11157; 11195; 11220; 11228; 11250; 11253; 11271; 11280; 

11289; 11297; 11302; 11306; 11315; 11318

The specific conditions of the proposed exemption that relate to the characteristics of the UAs are 

numbers 1, 5, 19, 20, 21, and 30 in Section V below. Each has been adopted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

4
B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC 

and VO will have been trained in operation of UA generally and received up-to-date 

information on the UA to be operated pursuant to this grant. The PIC will have completed, at a 

minimum, 20 hours of UA flight training with this specific UA prior to operations, and will be 

required to participate in annual training thereafter.

The specific conditions of the proposed exemption that relate to the training and characteristics 

of the crew are numbers 6-10 in Section V below. Each has been adopted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

C. Flight Conditions

The UA will be used to take real estate photography nationwide. It will be flown in Class 

G airspace under 200 feet above ground level (“AGL”) and under controlled conditions. 

Petitioner will work with the local FSDO when planning operations. Petitioner will only operate 

its UA in visual meteorological conditions (VMC). The UA will at all times be no less than 500 

feet below and no less than 2,000 feet horizontally from a cloud, and petitioner will not conduct 

operations unless visibility is at least 3 statute miles from the PIC. The flight crew will always 

make a safety assessment of the risk of every operation, and will only operate when it is 

determined that no hazards are present.

The specific conditions of the proposed exemption that relate to the flight conditions in 

which the UA will be operated are numbers 27, 28, 29, and 34 in Section V below. Each has 

been adopted or imposed by the FAA in numerous previous grants of Section 333 exemption 

petitions.

D. Flight Operations

The purpose of every UA flight will be to safely, accurately, and efficiently take aerial 

photography for real estate.

Every UA flight will use at minimum a two person flight crew: a PIC and a VO. They 

will follow standard, documented operational procedures for Pre-Flight Safety, UAS Routine 

Inspection and Maintenance, In-Flight Safety Operations, and Emergencies

The specific conditions of the proposed exemption that relate to flight operations are 

numbers 2, 3, 11-18, 22-24, 26, 32, 33, 35, and 36 in Section V below. Each has been accepted 

or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of safety at 

least equivalent to or higher than manned aircraft operations under the current regulatory 

structure. Section V below identifies the limitations and conditions to which petitioner agrees to 

be bound when conducting commercial operations under a grant of this petition. Section VIII

contains a matrix connecting (i) the specific proposed condition with (ii) the FAR provision for 

which it provides an equivalent level of safety and (iii) one or more recent Section 333

exemption grants in which the FAA recognized this equivalent level of safety.

5
Approval of the commercial operations outlined in this petition presents no national 

security issue. Petitioner is willing to require its PICs to undergo a background check, including 

the proposed Transportation Security Administration Vetting process, to ensure that no national 

security threat is present. Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg. 

9543 at 9572 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.).

V. Proposed Conditions of the Exemption

1. The UAs will weigh between 2.2 lbs. (1 kg) and 2.74 lbs. (1.24 kg.).

2. UA operations under this exemption will be limited to conducting operations for the purpose 

of commercial real estate photography.

3. Flights will be operated within line of sight of the PIC and VO.

4. Flights will be operated at an altitude of no more than 200 feet AGL, as indicated by the 

procedures specified in the operating documents. All altitudes reported to ATC must be in 

feet AGL.

5. The UA will not be flown at an indicated airspeed exceeding 30 knots.

6. Minimum flight crew for each operation will consist of the UA pilot in command (PIC) and a 

visual observer (VO).

7. The PIC will have, at minimum, 20 hours of training on the UA to be operated under this 

grant before accepting commercial operations.

8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification 

criteria and demonstrates the ability to safely operate the UA in a manner consistent with 

how the UA will be operated under this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner consistent

with 14 CFR § 61.51(b). A record of the PIC training will be documented and made available 

upon request by the Administrator. Training operations will only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations will be considered nonparticipants, and the PIC 

will operate the UA with appropriate distance from nonparticipants in accordance with 14 

CFR § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions, and will not be permitted to 

operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the 

functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UA operations prior to each day’s 

activities. It will be mandatory that all personnel who will be performing duties in connection 

with the operations be present for this briefing.

6
12. Prior to each flight, the PIC will inspect the UA, including the Ground Control Station, to 

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UA, the PIC will not operate the UA until the necessary maintenance 

has been performed and the UA is found to be in a condition for safe flight. All maintenance 

and alterations will be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or 

alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight 

critical component. The PIC who conducts the functional test flight will make an entry in the 

aircraft records.

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, 

in accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements set forth in the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul component parts 

will be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UA to service. The 

authorized person will make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses. PIC and VO will at all times be able to communicate verbally. They will 

not be permitted to use electronic messaging or texting to communicate during flight 

operations.

16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% battery 

reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles or 

emergencies.

19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will 

return to a pre-determined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

20. If the UA and its radio control link disconnect during flight, the system’s failsafe protection 

will be triggered and the multirotor will return to home and land automatically, rather than 

flying off uncontrollably or landing at an unknown location.

7
21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and

available to the PIC at the Ground Control Station of the UA any time the UA is operating. 

These documents will be made available to the Administrator or any law enforcement official 

upon request. If a discrepancy exists between the conditions and limitations in the exemption 

grant and the procedures outlined in the operating documents, the grant conditions and 

limitations will take precedence and will be followed. Otherwise, the petitioner will follow 

the procedures outlined in its operating documents. If it updates or revises its operating 

documents, it will present updated and revised documents to the Administrator upon request. 

If the petitioner determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the Petitioner will petition for an amendment to the grant 

of exemption.

22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents 

of the landowners over which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county or 

city jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies.

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights will not be 

conducted under special visual flight rules (SVFR).

25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. 

Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 48 hours prior to the operation. All operations will be conducted in accordance 

with airspace requirements in the ATO issued COA, including class of airspace, and altitude 

level.

26. The UA will not be operated within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management has been obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. Any letter of agreement with the airport 

management will be made available to the Administrator upon request.

27. The UA will not be operated less than 500 feet below, or less than 2,000 feet horizontally 

from, a cloud or when visibility is less than 3 statute miles from the PIC.

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO 

issued COA.

29. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum used 

for operation and control of the UA complies with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

8
31. The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times.

32. The UA will not be operated by the PIC from any moving device or vehicle.

33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The petitioner will ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, the PIC 

will ensure that flight operations cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA to the FAA's 

UA Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov.

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy because all

flights will occur over private property with the landowner’s/authorized agent’s permission. 

When the UA is being flown, the onboard cameras will be focused on the specific property and 

thus turned so as to be facing away from any occupied structures that may be in the area to 

minimize inadvertent video or still images of uninvolved persons.

VII. Public Interest and Safety

The planned UA use will increase ground safety for real estate photography. The 

enhanced safety and reduced environmental impact achieved using a UA with the specifications 

described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of 

significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UA operation enabled by this exemption is in the public interest.

9
Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, 

speed, operating capabilities, proximity to airports and populated areas and operation within visual 

line of sight and national security – provide more than adequate justification for the grant of the 

requested exemption allowing commercial operation of petitioner’s UA for the purposes of 

commercial real estate photography. The FAA has previously approved members of the DJI 

Phantom family for real estate photography in Exemption Nos. 11191, 11195, 11271, 11295, 

11300, and 11318.

The small weight of the Phantom UA family, ranging from 2.2 lbs. to 2.74 lbs. (1 kg. to

1.24 kg.), is less than the size envisioned in Section 334(c)(2)(C) of the FAA Modernization and 

Reform Act of 2012, which allows government agencies “to operate unmanned aircraft weighing

55 pounds or less, if operated, within the line of sight of the operator; less than 400 feet above the

ground; during daylight conditions; within Class G airspace; and outside of 5 statute miles from 

any airport, heliport, seaplane base, spaceport, or other location with aviation activities.”

Congress’s determination that government agencies should be allowed to operate such aircraft in 

these situations, with no further restrictions on location, population density, or pilot experience and 

training, indicates that Congress did not believe that aircraft of this size and weight warranted 

additional attention.

10
VIII. Regulations from Which Exemption is Requested. These are FARs as to which petitioner

wishes the same determination to be made as has been made previously.

FAR

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 16, 25, 28, 29, Nos. 11062, 11063, 11064, 11065, 11066, 11067,

33, 34 11080, 11109, 11111, 11110, 11114, 11136, 11138,

11150, 11153, 11156, 11157, 11166, 11167, 11170,

11171, 11172, 11174, 11176, 11177, 11178, 11184,

11185, 11188, 11189, 11191, 11192, 11193, 11195

43.7 13, 14 No. 11208

43.11 12 No. 11208

45.11 30 No. 11208

45.27 30 No. 11188

45.29 30 Nos. 11136, 11157, 11170, 11185, 11193

91.7(a) 12 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11177, 11178, 11184,

11185, 11188, 11189, 11191, 11192, 11193, 11195,

11204

91.9(b)(2) 22 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11111, 11112, 11114, 11136,

11138, 11150, 11153, 11156, 11157, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110,

11111, 11112, 11114, 11136, 11138, 11150, 11153,

11156, 11157, 11174, 11177, 11178, 11184, 11185,

11189, 11192, 11193, 11195

91.9(c) 30 Nos. 11136, 11170, 11171, 11174, 11185

91.103(b)(2) 3, 9, 16, 17, 18, 19, 20, 28 No. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11138, 11150, 11153, 11156, 11158,

11160, 11161, 11166, 11167, 11171, 11172, 11176,

11177, 11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.105 6 No. 11185

11
FAR

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

91.109 7, 8 Nos. 11062, 11063, 11064, 11065, 11066, 11067,

11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11166, 11167, 11170, 11171,

11174, 11177, 11184, 11185, 11189, 11191, 11192,

11193, 11194, 11195, 11206, 11208

91.113(b) 3, 32 No. 11238

91.119(c ) 4, 33 Nos. 11162, 11163, 11164, 11165, 11166, 111080,

111109, 11110, 11111, 11112, 11114, 11136,

11138, 11150, 11153, 11156, 11160 11161, 11166,

11167, 11170, 11171, 11172, 11174, 11176, 11178,

11185, 11188, 11189, 11190, 11193

91.121 4 Nos. 11162, 11163, 11164, 11165, 11166, 111080,

111109, 11136, 11138, 11150, 11153, 11156, 11160

11161, 11166, 11167, 11170, 11171, 11174, 11176,

11178, 11185, 11188, 11189, 11190, 11193

91.151(a) 17, 18 Nos. 11110, 11153, 11156, 11161; 111109, 11110,

11112, 11136, 11138, 11150, 11153, 11156, 11160

11161, 11166, 11167, 11170, 11171, 11172, 11174,

11176, 11178, 11185, 11188, 11189, 11190, 11193

91.203 (a) 22 Nos. 11062, 11063, 11064, 11065, 11066,

and (b) 11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11170, 11171, 11172, 11174, 11176,

11177, 11178, 11184, 11185, 11188, 11188,

11189, 11191, 11192, 11193, 11195

91.215 26, 27 No. 11185, 11195

91.403 12, 13, 14 No. 11185

91.405(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.407(a)(1) 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

12
FAR

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

91.409(a)(1) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.409(a)(2) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.417(a) 12, 13, 14 Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

91.417(b) 12, 13, 14 11067, 11080, 11109, 11110, 11111, 11112,

11114, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11160, 11161, 11166, 11167,

11170, 11171, 11172, 11174, 11176, 11177,

11178, 11184, 11185, 11188, 11188, 11189,

11191, 11192, 11193, 11195, 11204

13