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Drone/UAS Practice Group 35 E Wacker Drive 

Suite 1875 

Chicago, IL 60601 

Tel. 312.201.8310 

 Jeffrey@Antonelli-Law.com

U.S. Department of Transportation November 2, 2015 

Docket Management System

1200 New Jersey Ave S.E. 

Washington, D.C. 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 

2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.

PIKA International, Inc.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Antonelli Law files this petition for exemption on behalf of PIKA 

International, Inc. (“PIKA”) an operator of Small Unmanned Aircraft Systems (“UAs”) for the 

commercial purposes of observation and inspections of explosives and munitions. Specifically, 

petitioner seeks an exemption from the Federal Aviation Regulations (“FARs”) listed in Appendix 

A to allow commercial operation of its UAs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA in a grant of this petition. 

This request is substantially similar to other data collection petitions previously approved, and 

should be considered under the expedited summary grant procedure. 

Approval of the exemption for petitioner will allow operation of the DJI Flame Wheel F550 

for the proposed uses in Class G airspace nationwide, or as otherwise prescribed by an Air Traffic 

Organization (ATO) issued COA. The Flame Wheel family has been previously approved for the 

proposed uses in the exemption grants identified in Section VII of the petition. The UA covered 

by this petition is a small battery-powered craft, weighing no greater than 15 lbs. (6.8 kg), inclusive 

of battery and payload. Operation of the UA under the strict conditions proposed below will 

provide an equivalent level of safety, as Congress intended, while still allowing commercial 

operations. Operations using this UA are far safer than conventional operations conducted with 

helicopters and fixed-wing aircraft that weigh thousands of pounds, carry large amounts of highly 

flammable fuel, and operate in close proximity to the ground, trees, infrastructure, and people. 

Congress directed the FAA to consider seven factors in deciding whether to approve 

Section 333 exemption petitions - size, weight, speed, operational capability, proximity to airports, 

proximity to populated areas, and operation within visual line of sight. In this case, each factor 

supports the exemption request. In particular, the UA is small, and will operate at slow speeds and 

close to the ground. It will be able to more safely and efficiently conduct operations that would 

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Table of Contents

I. Publishable Summary............................................................................................................ 5

II. Petitioner’s Contact Information ........................................................................................... 5

III. Proposed Operations.............................................................................................................. 6

A. The UA........................................................................................................................... 6

B. The Crew ........................................................................................................................ 6

C. Flight Conditions............................................................................................................ 7

D. Flight Operations............................................................................................................ 7

IV. Aircraft and Equivalent Level of Safety................................................................................ 8

VI. Proposed Conditions of the Exemption................................................................................. 8

VI. Privacy................................................................................................................................. 11

VII. Public Interest and Safety...................................................................................................... 11

VIII. Regulations from Which Exemption is Requested.............................................................. 12

Appendix A: FARs as to which PIKA wishes the same determination to be made as has 

been made previously............................................................................................................ 13
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Exhibit List

Exhibit 1: PIKA International, Inc.’s Flight Operations Manual......................................................

................................................................................................Submitted Confidentially to the FAA

The UA

Exhibit 2: DJI Flame Wheel F550 User Manual ..............................................................................

.................................................................................Submitted separately due to upload constraints

Exhibit 3: DJI A2 Quick Start Guide......................Submitted separately due to upload constraints

Exhibit 4: Spektrum DX9 Transmitter User Manual 

.................................................................................Submitted separately due to upload constraints

Exhibits 1 has been submitted to the FAA confidentially and is not available to the public.

Exhibits 2-4 have been uploaded to Regulations.gov separately due to size constraints.
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I. Publishable Summary

Pursuant to 14 C.F.R. §11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules: 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 

45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 

C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R. 91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 

C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 

91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) 

to operate commercially small unmanned aircraft systems (UAs) (15 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation of the 

Flame Wheel F550 for the purposes of observation and inspections of explosives and munitions in 

Class G airspace nationwide, unless otherwise prescribed by an ATO-issued COA. The requested 

exemption should be granted because operation of small UAs weighing no greater than 15 lbs. (6.8

kg), inclusive of battery and payload, conducted in the strict conditions outlined below, will 

provide an equivalent level of safety, while still allowing commercial operations. The lightweight 

aircraft covered by the exemption are far safer than conventional operations conducted with 

helicopters and fixed-wing aircraft weighing thousands of pounds and carrying large amounts of

highly flammable fuel, and operating in close proximity to the ground and people. The seven 

factors Congress directed the FAA to consider when approving Section 333 exemption petitions -

size, weight, speed, operational capability, proximity to airports, proximity to populated areas, and 

operation within visual line of sight – each support the request. In particular, the aircraft are small, 

and will operate at slow speeds, and close to the ground. The substantial increase of safety and 

decrease of risk to human life, coupled with the low risk use of UAs to conduct these operations, 

weigh heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

Michelle Burton

Manager, Corporate Affairs

PIKA International, Inc.

12723 Capricorn Drive

Stafford, TX 77477

Counsel for Petitioner:

Antonelli Law

35 E Wacker Drive, Suite 1875

Chicago, IL 60601

Tel: 312-201-8310

Email: jeffrey@antonelli-law.com
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III. Proposed Operations

A. The UA

The requested exemption will permit petitioner to operate the Flame Wheel F550. The 

Flame Wheel family has been previously approved for commercial operation in, among others, the 

exemption grants identified in Section VII below.

The specific conditions of the proposed exemption that relate to the characteristics of the 

UA are numbers 1, 5, and 16-20 in Section V below. Each has been adopted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

The Flame Wheel F550 has the ability to hover and move in the vertical and horizontal 

planes simultaneously. The UA will have the following specifications or equivalent:

Airframe DJI Flame Wheel F550

Control System DJI A2 flight control system. This includes the main controller 

(MC), which receives the battery voltage, capacity, and current, 

the internal measurement unit (IMU), which receives telemetry 

data, compass, and GPS.

Maximum Operating Speed 29.2 knots

Maximum Flight Time 15 minutes

Maximum Weight 15 lbs. inclusive of payload

Transmitter Spektrum DX8

Receiver 5.8 GHz receiver

Motor 960 rpm/V motors

Propellers 6 x 4” propellers

Data Link 2.4 GHz data link

Video Link DJI AVL58

Gimbal DJI 3-axis gimbal

Batteries 6600 mAh Lithium Polymer 4S batteries

Telemetric Display Telemetric data is displayed through the dedicated ground 

control system device.

Automatic Return to Home If Tx signal is lost for more than three seconds and the UA is 

under 65 ft. (20 m.) AGL, the UA will rise to 65 ft. AGL, travel 

horizontally to the pre-designated home spot, hover for 15 

seconds, then land. If the UA is above 65 ft. AGL, travel 

horizontally to the pre-designated home spot, hover for 15 

seconds, then land.

Please refer to Exhibits 2-4 for more information regarding this UA.

B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC 

and VO will have been trained in operation of UAs generally and received up-to-date information 

on the UAs to be operated pursuant to this grant. The PIC will have, at a minimum, a sport pilot 

license and either a third class medical certificate or a U.S. driver’s license
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Prior to commercial operations, the PIC will have a minimum of 25 hours of general UA 

training and 10 hours of training on the DJI Flame Wheel F550.

The specific conditions of the proposed exemption that relate to the training and 

characteristics of the crew are numbers 3 and 6-9 in Section V below. Each has been adopted or 

imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding the flight crew and training, please refer to the Personnel 

Qualifications subsection of Exhibit 1: Standard Operating Procedures and Guidelines for UAV 

Operations.

C. Flight Conditions

The UAs will be used for observation and inspections of explosives and munitions in Class 

G airspace (unless otherwise prescribed by an ATO-issued COA) under 400 feet above ground 

level (“AGL”) and under controlled conditions over property that is closed off to individuals not 

involved in the flight operations. Petitioner will work with the local FSDO when planning 

operations. Petitioner will only operate the UAs in visual meteorological conditions (VMC). The 

UAs will at all times be no less than 500 feet below and no less than 2,000 feet horizontally from 

a cloud, and petitioner will not conduct operations unless visibility is at least 3 statute miles from 

the PIC. The flight crew will always make a safety assessment of the risk of every operation, and 

will only operate when it is determined that no hazards are present.

The specific conditions of the proposed exemption that relate to the flight conditions in 

which the UA will be operated are numbers 2, 4, 16, and 28-29 in Section V below. Each has been 

adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding flight conditions, please refer to the Mission Flights 

subsection of Exhibit 1: Standard Operating Procedures and Guidelines for UAV Operations.

D. Flight Operations

The purpose of the UA flights for which exemption is requested will be for observation 

and inspections of explosives and munitions. Every UA flight will use at minimum a two person 

flight crew: a PIC and a VO. 

The specific conditions of the proposed exemption that relate to flight operations are

numbers 11-12, 17-25, and 32-34 in Section V below. Each has been accepted or imposed by the 

FAA in numerous previous grants of Section 333 exemption petitions.

For more information regarding flight operations, please refer to the following sections of 

Exhibit 1: Standard Operating Procedures and Guidelines for UAV Operations:

Launch and Landing Zones

Landing Site & Alternate Landing Sites

Preflight, Takeoff, and Post Flight Checklists

Appendix A: Flight Specific Checklist.
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IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have the characteristics and that 

operate with the limitations proposed herein. These limitations provide for a level of safety at least 

equivalent to or higher than manned aircraft operations under the current regulatory structure. 

Section V below identifies the limitations and conditions to which petitioner agrees to be bound 

when conducting commercial operations under a grant of this petition. Appendix A contains a 

matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it 

provides an equivalent level of safety and (iii) one or more recent Section 333 exemption grants 

in which the FAA recognized this equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security 

issue. The PIC will possess, at minimum, a sport pilot’s certificate, so he or she will have been 

subject to security screenings by the Department of Homeland Security.

V. Proposed Conditions of the Exemption

1. The UAs, including battery and technical payload, will weigh no more than approximately 15 

lbs. (6.8 kg).

2. UA operations under this exemption will be limited to conducting operations for the purpose 

of observation and inspections of explosives and munitions in Class G airspace nationwide, 

unless otherwise prescribed by an ATO issued COA.

3. Flights will be operated within line of sight of a PIC and VO.

4. Flights will be operated at an altitude of no more than 400 feet AGL, as indicated by the 

procedures specified in the operating documents. All altitudes reported to ATC must be in feet 

AGL.

5. The UAs will not be flown at an indicated airspeed exceeding 29.2 knots. 

6. Minimum flight crew for each operation will consist of the UA PIC and a VO.

7. The PIC will possess, at a minimum, a sport pilot license and either a third class medical 

certificate or a U.S. driver’s license.

8. The petitioner will not permit any PIC to operate the UA unless the PIC meets its qualification 

criteria and demonstrates the ability to safely operate the UAs in a manner consistent with how 

the UAs will be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency will be logged in a manner consistent with 14 CFR 

§61.51(b). A record of the PIC training will be documented and made available upon request 

by the Administrator. Training operations will only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential 

for flight operations will be considered nonparticipants, and the PIC will operate the UAs with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding 
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other air traffic and other ground based obstacles/obstructions, and will not be permitted to 

operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her 

designation for the duration of the flight. The PIC will ensure that the VO can perform the 

functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UA operations prior to each day’s 

activities. It will be mandatory that all personnel performing duties in connection with the 

operations be present for this briefing. 

12. Prior to each flight, the PIC will inspect the UAs, including the Ground Control Station, to 

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAs, the PIC will not operate the UAs until the necessary maintenance 

has been performed and the UAs are found to be in a condition for safe flight. All maintenance 

and alterations will be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or 

alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight 

critical component. The PIC who conducts the functional test flight will make an entry in the 

aircraft records. 

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements set forth in the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul component parts will 

be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UA to service. The 

authorized person will make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not 

be permitted to use electronic messaging or texting to communicate during flight operations. 

16. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there 

is enough power to fly at normal cruising speed to the intended landing point and prepare to 

land with at least 30% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 30% battery 

reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles or 

emergencies. 

19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will 

return to a pre-determined location within the planned operating area and land or be recovered 

in accordance with the operating documents
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20. If the UA and its radio control link disconnect during flight, the system’s failsafe protection 

will be triggered and the multirotor will return to home and land automatically, rather than 

flying off uncontrollably or landing at an unknown location. 

21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and 

available to the PIC at the Ground Control Station of the UA any time the UAs are operating. 

These documents will be made available to the Administrator or any law enforcement official 

upon request. If a discrepancy exists between the conditions and limitations in the exemption 

grant and the procedures outlined in the operating documents, the grant conditions and 

limitations will take precedence and will be followed. Otherwise, the petitioner will follow the 

procedures outlined in its operating documents. If it updates or revises its operating documents, 

it will present updated and revised documents to the Administrator upon request. If the 

petitioner determines that any update or revision would affect the basis upon which the FAA 

granted the exemption, then the Petitioner will petition for an amendment to the grant of 

exemption. 

22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of 

the landowners over which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental 

agencies. 

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations 

will be conducted under visual meteorological conditions (VMC). Flights will not be 

conducted under special visual flight rules (SVFR). 

25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. 

Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but 

not less than 24 hours prior to the operation. All operations will be conducted in accordance 

with airspace requirements in the ATO issued COA, including class of airspace, altitude level 

and potential transponder requirements. 

26. The UA will not be operated within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management has been obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. Any letter of agreement with the airport management will 

be made available to the Administrator upon request. 

27. The UA will not be operated less than 500 feet below, or less than 2,000 feet horizontally from, 

a cloud or when visibility is less than 3 statute miles from the PIC. 

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO 

issued COA. 

29. All aircraft operated in accordance with this exemption will be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings 
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in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. 

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum used 

for operation and control of the UA complies with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

31. The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

32. The UA will not be operated by the PIC from any moving device or vehicle. 

33. Petitioner will conduct all flight operations at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UAs and/or debris in the event of an accident. The petitioner will ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UAs, the PIC 

will ensure that flight operations cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Petitioner will report accidents to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov.

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy. All flights 

will occur over either (a) public rights of way where there is no expectation of privacy; or (b) over 

private property with permission of the landowner/authorized agent and consent of participating 

individuals.

If data collected is made available for public view, all images containing uninvolved 

persons will be blurred or blacked-out. No attempt will be made to identify any individuals filmed 

during the flights except in cases where they are trespassing upon or damaging customer property, 

or interfering with the petitioner’s or its customers’ operations.

VII. Public Interest and Safety

The planned UA use will increase safety during observation and inspections of explosives 

and munitions. This type of data collection has previously been done by manned aircraft or by 

individuals on the ground. Both are more time consuming, more expensive and more dangerous 

than using UAs. Use of manned aircraft poses enhanced risk to the pilot and onboard crew, who 
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would be several hundred feet in the air. Use of individuals on the ground can place them at risk 

and in close proximity to dangerous explosives and munitions.

In addition, the enhanced safety and reduced environmental impact achieved using UAs

and carrying no passengers or crew, rather than a manned aircraft of significantly greater mass, 

carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UA

operation enabled by this exemption is in the public interest.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation 

within visual line of sight and national security – provide more than adequate justification for the 

grant of the requested exemption allowing commercial operation of petitioner’s UA for

observation and inspections of explosives and munitions pursuant to PIKA’s rules of operation.

Please refer to Exhibit 1, Section 3 for petitioner’s Safety Management System and Exhibit 1, 

Appendix A for petitioner’s Risk Management Tool.

The Flame Wheel family has been previously approved for inspection purposes in the 

following Exemption Nos.:

11690 (Flame Wheel F450 and F550, inspections ... in the electrical power supply and 

distribution industry);

11691 (Flame Wheel F450 and F550, inspections in the insurance industry);

11731 (Flame Wheel F550, inspections of industrial complexes);

12135 (Flame Wheel F450, inspections);

12652 (Flame Wheel F550, industrial inspections);

12668 (Flame Wheel F450 and F550, inspections);

12779 (Flame Wheel F450, inspections); and

12842 (Flame Wheel F550, oil and gas industry infrastructure inspections).
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Regulations from Which Exemption is Requested

Appendix A: FARs as to which PIKA wishes the same determination to be made as has been 

made previously.

FAR 

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

21(h) 1, 2, 3, 4, 5, 16, 25, 28, 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

43.7 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

43.11 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

45.11 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

45.27 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

45.29 29 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.7(a) 12 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.9(b)(2) 22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.9(c) 30 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.103(b)(2) 3, 9, 15, 16, 17, 18, 19, 20 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.105 6 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.109 7, 8 Nos. 11252, 11467, 11745, 11797, 11905, 11945, 

12040, 12068, 12422, 12474

91.113(b) 3, 31 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.119(c ) 4, 33 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.121 4 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.151(a) 16, 17 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.203 (a) 

and (b)

22 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.215 25, 26 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.403 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.405(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474
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FAR 

Provision

Applicable condition(s) in 

Section 5 of petition

FAA Exemption Decision

91.407(a)(1) 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.409(a)(1) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.409(a)(2) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.417(a) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474

91.417(b) 12, 13, 14 Nos. 11252, 11396, 11467, 11745, 11797, 11905, 

11945, 12040, 12068, 12080, 12107, 12422, 12474