AFS-16-10470-E

May 19, 2016

 Exemption No. 9704D

 Regulatory Docket No. FAA-2008-0332

Mr. Ian A. Shavitz

Counsel for Inter American University of Puerto Rico

Akin, Gump, Strauss, Hauer & Feld, LLP

1333 New Hampshire Avenue, NW.

Washington, DC 20036

Dear Mr. Shavitz:

This letter is to inform you that we have granted your petition to extend Exemption No. 9704, 

as amended. It explains the basis for our decision, describes its effect, lists the conditions and 

limitations, and includes the exemption’s expiration date.

The Basis for Our Decision

By letter dated March 14, 2016, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Inter American University of Puerto Rico (Inter American) for an extension of 

Exemption No. 9704, as amended. That exemption from § 61.129(a)(4) and part 141, 

appendix D, paragraph 5(a) of Title 14, Code of Federal Regulations allows Inter American’s 

commercial pilot students to satisfy their cross-country flight requirement of no less than 300 

nautical miles (nm) total distance, with landings at a minimum of three points, one of which is 

a straight-line distance of at least 150 nm rather than 250 nm as otherwise required under 

FAA regulation.

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

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

in the Federal Register. The requested extension of the exemption would not set a precedent, 

and any delay in acting on this petition would be detrimental to Inter American.
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Our Decision

The FAA has determined that the justification for the extension of Exemption No. 9704, 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. §§ 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, I grant Inter American University of Puerto Rico (Inter 

American) an exemption from 14 CFR § 61.129(a)(4)(i) and part 141, appendix D, paragraph 

5(a)(2) to the extent necessary to allow Inter American’s commercial pilot student applicants

to satisfy their cross-country flight requirement of no less than 300 nm total distance, with 

landings at a minimum of three points, one of which is a straight-line distance of at least 150 

nm from the original departure point rather than 250 nm as otherwise required under FAA 

regulation, subject to the conditions and limitations below.

Conditions and Limitations

1. This exemption applies to commercial pilot student flights performing cross-country 

flights in which the original point of departure and final landing point are from an 

airport (or airports) located within Puerto Rico. 

2. The commercial student’s logbook must be endorsed by the certificated flight 

instructor (CFI) as follows: “I certify that (INSERT STUDENT’S FIRST NAME, 

MIDDLE INITIAL, LAST NAME), (INSERT PILOT CERTIFICATE), (INSERT 

CERTIFICATE NUMBER), has satisfactorily completed the solo single-engine crosscountry flight in Puerto Rico in accordance with the provision of FAA Exemption 

No. 9704 on (INSERT DATE). S/S (INSERT DATE) (INSERT CFI NAME), 

(INSERT CFI CERTIFICATE NUMBER), EXPIRATION DATE (INSERT DATE).

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 9704, as amended, to May 31, 

2018, unless sooner superseded or rescinded. 

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service