December 28, 2011 

Mr. Ronald Allen Kreienkamp 

12689 Dorff Beach Road 

Audubon, MN 56511 

Dear Mr. Kreienkamp: 

This letter is to inform you that we are unable to process your request for an exemption to 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can’t process your 

request, gives you some important information about how we have handled similar requests, 

and tells you what you should do in the next 30 days. 

Why We Can’t Process Your Request

We entered your October 11, 2011, exemption request into the public docket 

(No. FAA-2011-1112), but we are unable to process your request any further. The 

information you sent doesn’t comply with the requirements of 14 CFR 11.81 (copy enclosed). 

For us to consider the request any further, you must send us all of the following: 

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief. 

 The reasons granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

 The reasons the exemption wouldn’t 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 an 

exemption. 

 Any more information, views, or arguments available to support your request. 

How We Have Handled Similar Requests 

Your request for exemption concerns placing 3-inch high registration markings on your Flight 

Design CTLS Special Light Sport Aircraft (S-LSA) (N190EM). 

It is important for you to know that we have issued denials of exemption in circumstances 

similar to those presented in your petition. We are enclosing for your review examples of 
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these denials, Exemption Nos. 7760, 9771, and 9919. As noted in these denials, the FAA has 

determined the petitioner is not unique from the general class of regulated persons who are 

subject to the requirements of § 45.29(b)(1). The display of 12-inch registration marks on an 

aircraft may detract from its aesthetics; however, the FAA has determined that installation of 

distinctive paint schemes, insignias, and logos does not appropriately substitute for the 

12-inch registration marks. 

In granting any exemption to the provisions of § 45.29, the FAA must consider the primary 

reason why amending part 45 was necessary (Amendment 45-13, November 2, 1981). It now 

requires at least 12-inch high marks, or as high as practicable, on fixed-wing aircraft, instead 

of the smaller marks previously allowed by the regulation. The 12-inch high marks on the 

vertical tail surface or the fuselage surface provide better visual identification of aircraft. The 

rule intends to discourage flight violations and provide for better air traffic control and flow at 

airports (visual identification of aircraft). 

The FAA determined that allowing 3-inch-high registration marks in place of the required 

12-inch-high marks to maintain appearance is not in the public interest and would not provide 

a level of safety equivalent to that provided by the regulation. 

Because the previous denials of exemption dealt with circumstances similar to those 

presented in your petition, there is little reason to believe that we would grant your petition 

for exemption. 

What You Should Do 

 Before we commit agency resources to process and analyze your exemption request, we 

suggest that you review the enclosed denials of exemption. 

 If, after that review, you still want the agency to process your petition, you must tell us 

how the facts and circumstances of your particular situation are significantly different 

from the previous denials of exemption. 

 Send the information about your particular situation, and the information we requested 

earlier in this letter that will enable us to process your request, to reach us within 30 days. 

We will consider the docket on your request open for that period. 
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If We Don’t Hear From You 

If we don’t hear from you within 30 days, we will close the docket without further contact. 

If you have any questions or need more time, you may call (202) 267-4059. 

Sincerely, 

/s/ 

James M. Crotty 

Acting Manager, Aircraft and 

 Airports Rules Division

Enclosures