Corrected Copy

AFS-15-442-E

This letter corrects the May 15, 2015, letter we sent granting your petition for 

Exemption No. 11608. Corrections were made to the exemption to reflect the reference in 

Condition and Limitation No. 7 referring back to the data provided in numbers 6a through 6d. 

Below is the amended Exemption No. 11608 that includes the aforementioned changes. We 

have made the correction in our records as of June 17, 2015.

May 15, 2015

 Exemption No. 11608

 Regulatory Docket No. FAA-2015-0175

Victor H. Smith

Garofalo Goerlich Hainbach PC

On behalf of Tatonduk Outfitters Limited

1200 New Hampshire Avenue NW

Washington D.C. 20036

Dear Mr. Smith:

This letter is to inform you that we have granted your request for exemption. 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

By letter dated January 23, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Tatonduk Outfitters Limited (Tatonduk) for an exemption from §§ 91.303(f) and 

91.307(c) of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow 

Tatonduk to operate a specially modified Boeing 727 aircraft (B-727) under 14 CFR part 121 

on behalf of the Zero-Gravity Corporation (Zero G) in parabolic flight operations (1) when the

flight visibility is less than 3 statute miles, and (2) without each occupant of the aircraft 

wearing an approved parachute when the pilot executes an intentional maneuver that exceeds 

a nose-up or nose-down attitude of 30 degrees relative to the horizon.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Tatonduk.
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The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 8333 (copy enclosed), the FAA 

found that, for the reasons presented, the proposed exemption would be in the public interest. 

The FAA found that subject to compliance, with certain conditions and limitations, safe flight 

operations could be provided and that such flight operations under these conditions and 

limitations could provide an equivalent level of safety with other part 121 operations.

In drafting the current part 121 pilot training and qualification requirements, the type of 

operations proposed by Zero G were never considered. There are no requirements to 

demonstrate proficiency in the type of flight maneuvers that have been proposed, in order to 

be issued an FAA pilot certificate. Therefore, the FAA finds that the training and 

qualification requirements contained in the conditions and limitations of this document are 

essential. Furthermore, because visual meteorological conditions might not exist during the 

operations conducted under this exemption, each Tatonduk pilot who operates under this 

exemption must demonstrate proficiency in each maneuver by reference to only the flight 

instruments in the airplane. 

The FAA found that STC No. ST01051LA (STC) had been issued and because of the details 

of the specific maneuvers Tatonduk pilots perform, in order to satisfactorily provide a zero 

gravity experience, the FAA added condition and limitation requirements necessary in this 

exemption in order to ensure that Tatonduk pilots will not exceed any limitations contained in 

either the STC or the approved airplane flight manual.

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

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 8333;

• the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 8333 also 

apply to the situation you present; and 

• a grant of exemption is in the public interest.

Our Decision

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Tatonduk Outfitters Limited an exemption 

from 14 CFR §§ 91.303(f) and 91.307(c) to the extent necessary to operate a specially 

modified Boeing 727 aircraft (B-727) under 14 CFR part 121 on behalf of the Zero- Gravity 

Corporation (Zero G) in parabolic flight operations (1) when the flight visibility is less than 3 

statute miles and (2) without each occupant of the aircraft wearing an approved parachute 

when the pilot executes an intentional maneuver that exceeds a nose-up or nose-down attitude 

of 30 degrees relative to the horizon, subject to the conditions and limitations described

below.

Conditions and Limitations 

1. Tantonduk/Zero Gravity must comply with part 121 for these “for hire” parabolic 

flight operations.
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2. The Boeing 727 aircraft (B-727) for which STC No. ST01051LA has been issued must 

be included in Operations Specifications A003 paragraph a. authorizing the conduct of 

operations under the provisions of Title 14 CFR Part 121.

3. Prior to conducting any operation under this exemption, Tatonduk must obtain 

amended operations specifications (OpSpec) that:

a. authorize approval to operate under this exemption, and

b. include OpSpec A362 Parabolic Flight Operations (a copy of which is attached 

hereto). 

4. Tantonduk may not conduct operations under this exemption unless it complies with 

the provisions of operation specification paragraph A362 (attached hereto).

5. Prior to conducting any operation under this exemption, Tantonduk must develop, 

receive FAA approval of, and satisfactorily conduct the following pilot training and 

qualification

a. Enter into and recover from nose-up and nose-down attitudes of plus or minus 

30 degrees relative to the horizon,

b. Demonstration of proficiency in each maneuver must be shown by reference to 

the airplanes flight instruments only, and

c. All maneuvers must be performed in either the airplane, or in a flight simulator 

that the FAA finds has the capability to replicate the listed maneuvers.

6. Prior to conducting any operation under this exemption, Tantonduk must submit 

approved documentation to the FAA principal operations inspector (POI) assigned to 

Tantonduk describing the:

a. Maximum positive and maximum negative “g” forces,

b. Maximum positive and negative pitch attitudes,

c. Maximum airspeed, and

d. Maximum vertical velocity

that will be encountered during each maneuver.

7. Prior to conducting any operation under this exemption, the FAA principal 

maintenance inspector (PMI) assigned to Tantonduk must, after consultation with the 

POI, find that all data provided in numbers 6a through 6d above are approved in the 

STC and that no limitation in either the STC or the approved airplane flight manual 

will be exceeded.

8. Operations conducted under this exemption by Tantonduk are limited to only those 

conducted under the long-term operations agreement between Tantonduk and Zero 

Gravity.

9. Prior to conducting any operation under this exemption, Tantonduk must enter into 

and obtain an approved memorandum of agreement (MOA) with the FAA air traffic 

control (ATC) facility exercising control of the airspace in which each flight under this 
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exemption will be conducted. Tantonduk must describe to ATC’s satisfaction, 

descriptions of the maneuvers and procedures with which Tantonduk will comply and 

also any other information that ATC requests. In conjunction with the appropriate 

ATC facility, the proposed operations must be scheduled during off-peak travel times 

so as not to disrupt the use of the navigable airspace for other aircraft operations. The 

applicable ATC facility will determine the specific requirements, but ideally the 

proposed operations would be limited to one airport and would occur between 2 a.m. 

and 6 a.m. (local time), when there is minimal aircraft traffic. The FAA specifically 

notes that navigable airspace is a valuable and limited resource, and that it is neither 

practical nor desirable to restrict the general public’s use of the airspace in order to 

accommodate the private commercial enterprise of one user. Moreover, the 

performance of parabolic maneuvers amid more traditional aircraft operations could 

have an adverse impact on safety and would unfairly infringe upon other users. Thus, 

the FAA imposes the foregoing restrictions and limitations in order to ensure safety 

and to allocate the use of the navigable airspace fairly. 

10. Tantonduk must conduct each flight under this exemption in accordance with all 

requirements or prohibitions contained in the approved MOA with the FAA ATC 

exercising control of the airspace in which each flight under this exemption will be 

conducted.

11. Prior to each operation under this exemption, Tantonduk must file an instrument flight 

rules (IFR) flight plan and must conduct that flight in accordance with an IFR ATC 

clearance issued by the FAA ATC facility exercising control of the airspace in which 

each flight under this exemption will be conducted.

12. This exemption is not valid for operations outside of the United States.

This exemption terminates on May 30, 2017, unless sooner superseded or rescinded.

Sincerely,

//s//

John Barbagallo

Deputy Director, Flight Standards Service

Enclosure