AFS-10-357-E 

Oct 26 2010 

 Exemption No. 4416N 

 Regulatory Docket No. FAA-2002-12831 

Mr. Paul W. Railsback 

Director of Operations 

Air Transport Association of America, Inc. 

1301 Pennsylvania Avenue, NW., Suite 1100 

Washington, DC 20004 

Dear Mr. Railsback: 

This letter is to inform you that we have amended Exemption No. 4416, as amended. It 

transmits our decision, explains its basis, and gives you the conditions and limitations of the 

exemption, including the date it ends. 

The Basis for Our Decision 

The Federal Aviation Administration (FAA) is revising this exemption and its conditions and 

limitations to update the references to current Title 14, Code of Federal Regulations and to 

clarify in Condition No. 1 that each part 121 certificate holder desiring to use the provisions 

of this exemption must develop still and/or motion pictures providing distant and detailed 

closeup views of each passenger compartment and exterior preflight inspection item depicting 

normal and abnormal conditions. 

On August 5, 2010, the FAA revised the conditions and limitations of Exemption No. 4416, 

as amended. That exemption from the visual preflight inspection required in Appendix E 

item I(a) of part 121, as required under § 121.424 (a), allows ATA member airlines and other 

qualifying part 121 certificate holders 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. Currently, Appendix F item I(b) of 

part 121 allows for the use of an approved pictorial preflight inspection means. 
 2

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. 40113 and 44701, which the FAA 

Administrator has delegated to me, I grant your petition, subject to the following conditions 

and limitations. 

Conditions and Limitations 

1. Each part 121 certificate holder desiring to use the provisions of this exemption must 

develop still and/or motion pictures providing distant and detailed closeup 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 appropriate FAA 

Flight Standards District Office holding the operating certificate. 

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 

The termination date of Exemption No. 4416, as amended, remains September 30, 2012, 

sooner superseded or rescinded. 

Sincerely, 

/s/ 

John W. McGraw 

Acting Director, Flight Standards 

 Service