PETITION FOR EXEMPTION TO 14 CFR 

July 24, 2012 

US Department of Transportation 

Docket Operations 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

11800 Salem-Warren Road Ph 330-337-1180 

Salem, O.hio 44460 Fax 330-337-1179 

At Salem Air Park (38D) Cell330-277 -3131 

Email: comiair@aol.com www.ComiAir .com 

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Pursuant to 14 CFR § 11.81 the following information is provided in support of petition for an exemption: 

This petition for exemption is made by: 

Ronald W. Corbi 

President 

Corbi Air Inc. 

11800 Salem Warren Road 

Salem, Ohio 44460 

Tel: 330-337-1180 

corbiair@aol.com 

. . , 

Corbi Air Inc. seeks an exemption from 14 CFR 91.327 (a) and 61.113 (a). 

... 

Currently Corbi Air Inc. uses a Cessna 206 fitted with gas leak detection and high-resolution video camera equipment to 

fly over specific pipelines in the U.S. An exemption will increase public safety and reduce pollution by allowing 

replacement of our Cessna 206 fleet with S-LSA fixed wing aircraft. The exemption would benefit the public as follows: 

1. The use of an S-LSA will increase the safety of people and structures on the ground because they are smaller, 

lighter, slower, and more agile. S-LSAs are much less likely to cause injury or damage on the ground in the 

event of engine failure because of their short landing capabilities. Their slow speeds enable the pilot to land 

safely in areas that are unavailable to a Cessna pilot. 

2. Pipelines have many sharp turns that must be checked for leaks and incursions. The stow speed capability and 

nimble flight characteristics of an S-LSA allows the pilot to follow the pipelines' sharp bends more accurately 

than is possible with larger, heavier and faster aircraft. Because of these capabilities, the 5-LSAs will increase 

public safety by improved and more accurate gas leak detection and pipeline integrity. 

3. The use of an S-LSA will benefit the public by reducing noise pollution in the residential areas that frequently 

abut pipelines. At approximately SSdB, they are significantly less noisy than our existing aircraft. 

4. The use of an S-LSA will benefit the public by creating less air pollution and reducing our carbon footprint. It 

consumes significantly less fuel and engine oil and is capable of using unleaded fuel instead of the heavily leaded 

fuel required by the Cessna. 
5. If it is felt that it should be required, our S-LSA can be equipped with a ballistic recovery parachute. No such 

system is available for a Cessna 206. 

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level 

of safety at least equal to that provided by the rule from which you seek the exemption are as follows: 

1. Our camera and leak detection equipment is light-weight and of a size that would easily fit into an S-LSA. 

2. Our camera and leak detection equipment is designed to allow the flights to be completed at 1000 foot AGL. 

Much safer over populated areas and no low altitude waivers required. 

3. Any changes to our aircraft such as view ports, electrical connections and equipment mounts will be tested and 

approved by the aircraft manufacturer. 

4. Our S-LSA will not be changed in any way that affects its flight characteristics or weight and balance envelope. 

5. Our S-LSA will be maintained by an Airframe and Powerplant Mechanic and an A&P-IA will conduct the 100hour 

and condition/annual inspections. 

6. Our S-LSA will use certified engines and propellers. 

7. Our S-LSA will be equipped with dual alternators. 

8. Our flights will be conducted only during daylight hours but the aircraft will be equipped with a full night lighting 

package including Instrument, Navigation, Strobe, and Landing Lights. 

9. Our flights will be conducted only in VFR conditions but the aircraft will be IFR equipped. 

10. Our pilots will have a minimum of a Commercial Pilots License and an Instrument Rating. 

11. Our pilots will complete an extensive training program. 

Corbi Air Inc. requests an exemption from 14 CFR 91.327 (a) and 61.113 (a) in order to use Special Light Sport Aircraft to 

detect incursions and leaks in natural gas pipelines in the US. Your expedient consideration of this request will help us 

to increase public safety by better detecting gas leaks, increasing the safety of our pilots, reducing the hazards to people 

and structures over which we fly, and reducing the impact of our operations on the environment. 

Respectfully Submitted, 

Ronald W yrbi - , a 

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President ·~ 

Corbi Air Inc. 

www.CorbiAir.com 

CorbiAir@aol.com 

877-267-2424 Toll Free 

330-337-1180 Office 

330-277-3131 Cell