12/2/2015

U .S. Department of Transportation

Docket Management System

1200 New Jersey Ave S.E.

Washington, D.C. 20590

R e: 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.

D ear Sir or Madam:

P ursuant 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 es tate photography. Specifically, petitioner seeks an exemption from the “FARs” liste d

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

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

A pproval of the exemption for petitioner will allow commercia l operation of the DJI Phantom 3 or similar

UA f or 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.), inclusi ve 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 conventio nal 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.

C ongress 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

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

granting the exemption.

F or 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

.

A rt Clark

CEO

eW alk Software Corporation

1Table 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. R egulations 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

previous ly

................................ ................................ ................................ .............................. 11

2I. 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. 4 09(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 l bs. (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 exempt ion 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 re quest. 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 s afety 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

Sant a Cruz, CA 95062

3III. Proposed Operations

A. The UA

The requested exemption will permit petition er to operate the DJI Phantom 3

Professional, and other similar Phantom Mode ls.

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 s pecifications.

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.

4B. 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 w ill be used to take real estate photography nationwide. It will be flown in Class

G airspace under 2 00 feet above ground level (“AGL”) and under contr olled 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 clou d, 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 p resent.

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 S ection 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 f light crew: a PIC and a VO. They

w ill follow standard, documented operational pro cedures 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

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

be bound when conducting commercial operations under a gr ant 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.

5Approval of the commercial operations outli ned 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 e ach 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 a ny 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

- build ing 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 b eyond 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.

612. 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.

Maintena nce, 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 servic e. 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 require s 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

operat ions.

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 GP S 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

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

flying off uncontrollably or landing at an unknown location.

721. 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 limitati ons 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 t he 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 require d 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 operation s

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 ai rspace 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 agree ment 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. Marking s 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 ov ersight agency requirements.

831. 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

w ill 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 ri sk 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 t o 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 ima ges 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.

9Satisfaction 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 commer cial operation of petitioner ’s UA for th e 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.

Th e 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 operat e such aircraft in

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

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

additional attention.

10VIII. 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

11FAR

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

12FAR

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