## PETITION FOR EXEMPTION TO 14 CFR July 24, 2012 US Department ofTransportation Docket Operations 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 

### 11800 Salem-Warren

### Road Ph330-337-1180 Salem, O.hio 44460 Fax330-337-1179 

### At SalemAirPark(38D) Cell330-277-3131



### Email: comiair@aol.comwww.ComiAir.com



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Pursuant to 14CFR 

### § 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, Ohio44460 Tel: 330-337-1180 corbiair@aol.com 

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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 equipmentto fly over specific pipelines in the U.S. An exemption will increase public safety and reduce pollution by allowing replacement ofour Cessna 206 fleet with S-LSA fixed wing aircraft. The exemption would benefitthe public as follows:
1. The use ofan S-LSA will increase the safety ofpeople 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 ofengine failure because oftheir short landing capabilities. Their slow speeds enable the pilotto land safely in areas that are unavailable to aCessna pilot.
2. Pipelines have many sharp turns that must be checked for leaks and incursions. The stow speed capability and nimble flight characteristics ofan S-LSA allowsthe pilotto follow the pipelines' sharp bends more accurately than is possible with larger, heavier and faster aircraft. Because ofthese capabilities, the 5-LSAs will increase public safety by improved and more accurate gas leak detection and pipeline integrity.
3. The use ofan S-LSA will benefitthe public by reducing noise pollution in the residential areas that frequently abut pipelines. At approximately SSdB, they are significantly less noisythan ourexisting aircraft.
4. The use ofan S-LSA will benefitthe public by creating less air pollution and reducing our carbon footprint. It consumes significantly less fuel and engine oil and is capable ofusing unleaded fuel instead ofthe heavily leaded fuel required by the Cessna.5. If it is felt that itshould be required, ourS-LSA can be equipped with a ballistic recovery parachute. No such system is available for a Cessna 206. The reasons why grantingthe exemption would notadversely affect safety, or howthe exemption would provide a level ofsafety at least equal to that provided bythe rule from which you seek the exemption are as follows: 

### 1. Our camera and leak detection equipment is light-weight and ofa size that would easily fit into an S-LSA. 2. Our camera and leak detection equipment is designed to allowthe flights to be completed at 1000foot AGL. Much safer over populated areas and no low altitude waivers required. 

### 3. Any changes to ouraircraft such as view ports, electrical connections and equipment mountswill be tested and approved by the aircraft manufacturer. 

### 4. OurS-LSA will not be changed in any way that affects its flight characteristics orweight and balance envelope. 

### 5. OurS-LSA will be maintained by an Airframe and Powerplant Mechanic and an A&P-IA will conduct 

### the 100hour and condition/annual inspections. 

### 6. OurS-LSA 

### will use certified engines and propellers. 

### 7. OurS-LSA will be equipped with 

### dual alternators. 

### 8. Ourflights will be conducted only during daylight hours butthe aircraft will be equipped with a 

### full night lighting package including Instrument, Navigation, Strobe, and Landing Lights. 

### 9. Ourflights will be conducted only in VFR conditions but the aircraft will be IFR equipped. 

### 10. Our pilots will have a minimum ofa 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 orderto use Special Light SportAircraft to detect incursions and leaks in natural gas pipelines in the US. Your expedient consideration ofthis request will help us to increase public safety by better detecting gas leaks, increasing the safety ofour pilots, reducing the hazards to people and structures over which we fly, and reducing the impact ofouroperations on the environment. Respectfully Submitted, 

### Ronald W 

### yrbi

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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