Nov ember 3 0 , 2015

Aaron Wypyszynski Wyp Aviation , LLC
138 Lexie Ln Meridianville, AL 35759

U.S. Department of Transportation Docket Operations 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code of Federal Regulations Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112

- 95) Regarding Commercial Employment of Unmanned Aircraft Systems (UAS)

Dear Sir/Madam,

Pursuant to Section 33 3 of Public Law 112

- 95

, commonly known as the “333 Exemption

, ” Wyp Aviation

, LLC (“Wyp Aviation”) hereby applies for authorization to conduct commercial unmanned aircraft systems (UAS) operations within the United States National Airspace System ( NAS) for the purpose of

a erial data collection

. Federal Register Summary

Pursuant to 14 CFR §11.81, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Wyp Aviation seeks exemption from 14 CFR Part 21, Subpart H; 14 CFR Part 23; 14 CFR Part 27;
14 CFR 45.23 (a) (b); 14 CFR 61.113(a)(b); 14 CFR 61.133(a)(i)(ii); 14 CFR 91.7(a); 14 CFR 91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151(a);

14 CFR 91.203(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); CFR 91.409(a)(1) and (a)(2); 14 CFR 91.417(a)(b) to allow commercial employment of Unmanned Aircraft Systems (UAS) in support
of a erial d ata collection. This exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent
work with conventional aircraft and rotorcraft.

The name and address of the applicant is:

Aa ron Wypyszynski Wyp Aviation , LLC
138 Lexie Lane Meridianville, AL 35759

aa ron@WypAviation.com

### INTRODUCTION AND INTEREST OF THE PETITIONER

The use of small unmanned aerial systems (sUAS ) in commercial and science applications is now widespread and transforming aerial data collection. These devices are used regularly t o reduce costs
and increase safety. Wyp Aviation’s operators pos s es s over a decade of experience in operations of sUAS p latforms both in the hobby and Department of Defense fields

, as well as being FAA

- certified and current pilots with several hundred hours of flight experience . Wyp Aviation wishes to extend this knowledge and experience to sUAS commercial operations to provide low

- cost aerial data to our

customers with a low environmental impact . Operations may consist of:

 Aerial imagery acquisition for local business es, such as developers and realtors

 Search and rescue support for local first responder organizations

 Carrying of third party sensors to provide data collection and sensor evaluation

 Provid ing airborne platforms for evaluation of ground

- based sensor performance

 Provid ing training to Wyp Aviation employees in support of sUAS opera tions

UAS are developing as a legitimate and robust means of conducting aerial data collection that heretofore have been possible only from manned aircraft. Such traditional techniques are expensive, incur substantial risk to personnel

, and produce lower q uality data. Our work addresses these issues through UAS applications to the benefit of society at large.



### OVERVIEW CHARACTERISTICS OF PROPOSED UAS

Platform 3DR IRIS+ DJI Phantom 3 DJI Spreading Wings S1000 3DR Aero

Aircraft Type Quadcopter Quadcopter Octocopter Fixed

- wing Aircraft Weight (lbs) 2.8 2.7 9 6
Max Takeoff Weight (lbs) 4 3 22 8

Dimensions (in) 22x22x8 15x15x10 41x41x18 51x74x12
Max Flight Time approx. (min) 25 25 40 45

Max Airspeed (kts) 35 35 25 50

Autopilot Pixhawk DJI WooKong

- M /
Pixhawk Pixhawk

Propulsion Brushless Motor Brushless Motor Brushless Motor Brushless Motor

Power 11.1V lithium polymer battery 14.8V lithium

polymer battery 22.2V lithium

polymer battery 14.8V lithium

polymer battery

Payload Camera / Sensor up to 1 lbs Included Camera Camera / Sensor up to 12 lbs Camera / Sensor

up to 2 lbs

### QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; ( 3 ) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the same pur pose.

The UAS s planned to be operated are both rotorcraft and fixed wing , each weighing typically less than

15 pounds , and always less than 55 pounds , including payload. They would operate, under normal conditions, at a speed of no more than 5 0 knots. Th e principal construction material of the UAS aircraft
would primarily be foam, carbon fiber, aluminum

, and/or plastic. Operations will be performed by a qualified UAS Pilot in Command (PIC), as outlined below, to e nsure that the UAS will “ not create a hazard to users of the national airspace system or the public. ” Given the small size of the UAS aircraft involved and the pre

- planned environment within which they will operate, the applicant believes that these operations fall squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also, due to the size of the UAS and the pre

- defined, restricted area in which the UAS will
operate
, approval of the application presents no national security issue. The operation of UAS by knowledgeable professionals will serve to enhance safety, add to the public benefit, and reduce environmental impacts related to current methods of manned air craft flight operations. The limitations and conditions to which the operator, or its employees acting as UAS PIC s , agrees to be bound when conducting commercial operations under a n FAA

- issued exemption include :

1. Operations authorized by this grant of exe mption are limited to the following aircraft: 3DR IRIS+, DJI Phantom, DJI Spreading Wings S1000, 3DR AERO

2. UA S (aircraft and payload) will weigh less than 55 lbs.

3. UA S will be operated at altitudes not greater than 4 00 feet above ground level ( AGL ) . Altitud es reported to Air Traffic Control ( ATC ) will be in feet AGL.

4. UA S will be flown at ground speeds not greater than 5 0 knots.

5. The UAS PIC will hold either an airline transport, commercial, private, recreational

, or sport pilot
certificate. The PIC must als o hold a current FAA airman medical certificate or a valid U.S driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the recent flight experience requirement stated in 14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56.

6. In addition to holding an FAA

- issued airman certificate, UAS PIC must complete a Wyp Aviation UAS Training Program. This training will include detailed review of manufactur er operating manuals and practical demonstration of ability to safely operate UAS in a manner consistent with how the UAS will be operated under this exemption (to include evasive and emergency maneuvers and maintaining appropriate distances from persons, vehicles, vessels

, and structures). PIC qualification will have a currency requirement of at least three take offs and landings within the preceding 90 days. PIC qualification flight hours will be logged in a manner consistent with 14 CFR § 61.51.

7. UA S wil l not be operated within 5 nautical miles (NM) of an airport having an operational control tower, or within 3 NM of an airport with a published instrument flight procedure but notan operational control tower, or within 2 NM of an airport without a published instrument flight

procedure or operational control tower, or within 2 NM of a heliport with a published instrument flight procedure. Flights will be operated in Class G airspace whenever possible. If operation in oth er airspace is required, the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required, any necessary permission obtained

. 8. UAS flights will operate within visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR).

9. UAS operations will not be conducted during night, as defined within 14 CFR § 1.1.

10. UA S flights over land will not be operated by the PIC from any moving vehicle or device. UA S flights conducted entirely over water may be operated from a suitable vessel.

11. UA S will not be operated from a raised platform.

12. The UA S will remain clear of and yield right of way to manned aviation operations.

13. UA S will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision unaided by device other than corrective lenses as specified on PIC’s FAA medical
certificate or driver ’ s license.

14. UAS operations will employ a visua l observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC maintains VLOS capability. The VO and PIC must be able to communicate verbally for the duration of the flight. Electronic messaging or texting is not allowed during flig ht operations.

15. The VO will perform no duties other than assisting the PIC see and avoid other aircraft, obstacles, persons

, or property.
16. UAS will be equipped with an autopilot system. The UAS will utilize GPS navigation, failsafes,

return

- to

- home (RTH)

, and flight abort safety features.

17. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. Checklists developed from manufacturer operating documents will be the basis for this inspection. If the inspection reveals a condition that affects safe operation of the UAS, the aircraft is prohibited from operating until necessary maintenance has been performed and the UAS is found to be in a safe condition for flight. The Ground Control Station must be included in the pref light inspection.

18. All UAS operations will be conducted over sole use property. Permission for flight will be obtained in advance from property owners or controlling agency. A Ground Station will be connected by radio communication to the UAS during the en tire flight, which will give the PIC flight information such as GPS p osition, a ltitude, a ir speed, b attery r emaining, and other telemetry information.

19. Flight boundaries will be established for each flight and such boundaries will be designed such
that the UA S will pass no closer than 500 feet from nonparticipating persons, vehicles

, or
structures.
20. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined location within the established flight boundary and land or be recove red in accordance with manufacturer operations documents.

21. The PIC will abort any flight in the event of unpredicted obstacles, occurrence of adverse
weather

, or loss of UAS flight control capability in accordance with manufacturer operations
documents.22. T he PIC is prohibited from beginning a flight unless (considering wind and forecast conditions)

there is enough power to fly the planned route to the intended landing point and land the UAS with 25% of battery capacity remaining.

23. Documents required by 14 C FR § 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS whenever the aircraft is operating. These documents will be made available to the Administrator or any law enforcement official upon request.

24. Before conducting flig ht operations, the radio frequency spectrum used for operation and
control of the UA S must comply with Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

25. A Flight Operations and Maintenance Log will be m aintained for each UAS. Cumulative flight hours, maintenance activities, repairs, alterations and inspections will be noted.

26. Any UAS maintenance or alterations that affect UAS operation or flight characteristics, e.g. replacement of a flight critical comp onent, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the Flight Operations and Maintenance Log.



### SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS EXEMPTION OR REL IE F

14 CFR Part 21, Subpart H

– Airworthiness Certificates and 14 CFR § 91.203(a)(1)
The FAA has stated that no exemption is needed from this section if a finding is made under Part 11 and Section 333 of the Reform Act that the UAS selected provides an equiv alent level of safety when compared to civil aircraft normally used for the same application. The petitioner submits that given the small size of the UAS, the limited operating areas and procedures defined within the training and operations section of the petition, an equivalent level of safety is obtained and exemption is not required (see Grant of Exemption to Astraeus Aerial, Docket No.
FAA

- 2014

- 0352). If however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

14 CFR Part 23 and 27

– Airworthiness Standards: Normal Category Aircraft and Rotorcraft

14 CFR Part s 23 and 27 sets forth the procedural requirements for airworthiness certification of normal category aircraft and rotorcraft. To the extent petitioner’s UAS would otherwise require certification under Part s 23 and 27, petitioner seeks exemption for the same reaso ns identified in the request for exemption from 14 CFR Part 21, Subpart H.

14 CFR § 45.23 (a)(b) and 91.9 (c)

– Marking of the Aircraft

Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the Ro man capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” a nd the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot stati on, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.Regulation 91.9 (c) provides: No person may operate a U.S.

- registered civil aircraft unless that

aircraft is identified in accordance with part 45 of this chapter.

The UAS has no entrance to the cabin, cockpit or pilot station on which markings can be placed. Given the small size of the UAS, two

- inch lettering will not be possible. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N

- Number) markings in accordance with 14 CFR
Part 4 5, Subpart C if the markings are as large as practicable.” The petitioner additionally proposes to place all required markings, placards, flight envelope restrictions, cautionary notices in an easily visible location at the UAS Ground Control Station. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 8738, 10167, 10167A and 10700.

14 CFR § 91.9(b)(2)

– Aircraft Flight Manual in the Aircraft

Regulation 91.9 stipulates (b) No person may operate a U.S.

- registered civil aircraft

— (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any com bination thereof.
Given the size of the UAS, they have no place or ability to carry a flight manual aboard the aircraft. An equivalent level of safety will be achieved by keeping the flight manual at the Ground Control Station where the pilot operating t he UAS will have immediate access to it. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 10167, 10602, 32827 and 10700.

14 CFR § 61.113 (a)(b) and 61.133(a)(i)(ii)

– Private and Commercia l Pilot Privilege and
Limitations
Regulation 61.113 stipulates (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.
(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employm ent if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or
hire.
Regulation 61.133 stipulates (a) Privileges

— (1) General. A person who holds a commercial pilot

c ertificate may act as pilot in command of an aircraft

— (i) Carrying persons or property for compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the operation; and
(ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the operation.
Unlike a conventional aircraft that carry pilot, passengers and cargo, the proposed U AS are remotely controlled and carry no persons or cargo. The UAS are capable of a high degree of flight automation and employ technical capabilities that limit the potential for operation in an unintended manner. It is the petitioner’s belief that given t he size, weight, speed, operating environment and operating capabilities of the UAS, an equivalent level of safety may beobtained by stipulating the UAS PIC must hold either an airline transport, commercial, private,

recreational, or sport pilot certifica te. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review

re quirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11284, 11281, 11282 and 11296.

14 CFR § 91.7(a)

– Civil Aircraf t Airworthiness
Regulation 91.7 stipulates (a) No person may operate a civil aircraft unless it is in an airworthy
condition.
Should this exemption be granted allowing commercial operation of UAS without an airworthiness certificate, no FAA regulatory standard will exist for airworthiness of the UAS. An equivalent level of safety will be obtained by ensuring compliance with UAS o perator and maintenance manuals and safety checklists prior to each flight.

14 CFR § 91.121

– Altimeter Settings
Regulation 91.121 requires that (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is n o station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport o r an appropriate altimeter setting available before departure.
Conventional aircraft are provided altitude data by a barometric altimeter that is most commonly set to a local barometric pressure and therefore reports altitude relative to MSL (Mean Sea Le vel). UAS operations are restricted to altitudes no greater than 200 feet AGL (Above Ground Level). For those UAS with a barometric sensor, greater utility and an equivalent level of safety will be obtained by setting the altimeter to read “zero altitude” when the UAS is on the ground prior to takeoff thus providing an AGL altitude readout. If no barometric sensor is aboard the UAS, a GPS derived altitude similarly set to zero at the takeoff point will provide an equivalent level of safety. The FAA has issu ed several exemptions to this regulation: see Exemptions Nos. 11066, 11065, 11062 and 11063.

14 CFR § 91.151

– Fuel Requirements for Flight in VFR Conditions

Regulation 91.151 stipulates that (a) No person may begin a flight in an airplane under VFR

co nditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cru ising speed, to fly after that for at least 20 minutes.
This regulation is written based on the capabilities of traditional civil aircraft which typically have flight times with full fuel of several hours. For the majority of UAS which have flight timesof an hour, or much less, this regulation would effectively deny an ability for the UAS to operate.

The petitioner submits that an equivalent level of safety will be obtained by requiring that no UAS flight will begin unless (considering wind and forecast conditions) there is enough fuel (battery) to fly the planned route to the first point of intended landing and land with 25% of battery capacity in reserve. This restriction would be more than adequate to return the sUAS to its planned landing zone from an ywhere in its limited operating area.
The FAA has issued several exemptions to this regulation: see Exemptions Nos. 2689F, 5745, 10673 and 10808.

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b)

– Maintenance Inspections
Regulation 91 .405 (a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in Subpart E of this Part, and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as pre scribed in Part 43 of this chapter...” Regulation 91.407 (a)(1) similarly makes reference to requirements in Part 43. Regulation 91.409( a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Regulation 91.417( a) and (b) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.
Exemption from these regulation s is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate. An equivalent level of safety will be obtained by requirement that each UAS will have a flight and maintenance log. Maintenance and inspections will be accomplished in accordance with manufacturer recommendations. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065.

14 CFR § 91.103

– Preflight Action

Regulation 91.103 stipulates e ach pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and foreca sts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civi l aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.
The petitioner seeks exemption to the extent that an FAA

- approved Flight Manual is required. An equivalent level of safety will be provided by following the Operations Manual provided by the manufacturer. Additionally, the PIC will cond uct preflight actions, to include performing all required checklists, reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, before initiation of flight.14 CFR § 91.109

– Flight Instruction

Regulation 91.109 stipulates, in part, that (a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.
UAS by their design do not have fully functional dual controls. Flight control i s accomplished through the use of a control interface that communicates with the aircraft via radio. Given the size, speed and limited operational parameters of the UAS, an equivalent level of safe training can be performed without dual controls. The FAA h as issued several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065.

14 CFR § 91.119

– Minimum Safe Altitudes

Regulation 91.119 stipulates, in part, that, Except when necessary for takeoff or landing, no

person may opera te an aircraft below the following altitudes: (a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
An exemption to 91.119(c) is required because UAS operations will be conducted at altitudes no

gr eater than 4 00 feet above the surface. The size, speed, weight and limited operational parameters of the UAS allow for an equivalent level of safety.



### WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST

As introduced above, the requested exemption would authorize the Applicant to perform commercial operations with sUAS that will provide significant benefits to the public interest:

1. The commercial use of sUAS to perform aerial data collection activities wil l provide a public service through use of data collection in support of land surveying as well as the ability to use these assets in support of local s earch and r escue organizations.
2. A significant reduction in costs to conduct data collection and training programs. At present, such programs that use aerial platforms can cost thousands of dollars. By incorporating sUAS into these programs we can incur significant savings and more efficiently conduct data collection with more rapid response than traditional m ethods.

3. The use of sUAS will decrease congestion in the National Airspace System along with reducing the noise and air pollution generated during traditional manned aircraft flight operations.

4. When using UAS to complement field personnel, they reduce safet y concerns when gathering
data from locations difficult to reach by personnel

. 5. Operation of sUAS will substantially reduce the risk to life and property in the air and on the ground, which is commonly associated with traditional manned aircraft flight oper ations

. 6. Similar to the current manned aircraft flight operations that have been conducted for many decades, sUAS used for similar tasks will not generate any new privacy issues.

### Approval of this exemption would thereby enhance safety and fulfill the Secret ary of

Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system." Approval of this exemption will allow for safer, more efficient

, and less costly aerial data collection missions, and produce much higher data quality.



### SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS EXEMPTION OR RELIEF

14 CFR Part 21, Subpart H 14 CFR Part 23
14 CFR Part 27
14 CFR 45.23 (a) (b) 14 CFR 61.113(a)(b) 14 CFR 61.133(a)(i)(ii) 14 CFR 91.7(a) 14 CFR 91.9(b)(2)(c)
14 CFR 91.103 14 CFR 91.109(a)
14 CFR 91.119
14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203(a) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) CFR 91.409(a)(1) and (a)(2)
14 CFR 91.417(a)(b)