November 6, 2014 

Mr. Rodney C. Ennis 

Director of Operations 

Air Transport International, Inc. 

145 Hunter Drive 

MS-2061T 

Wilmington, OH 45177 

Dear Mr. Ennis: 

This is in response to your September 12, 2014, letter sent to the public docket (No. FAA2014-0718) petitioning the Federal Aviation Administration (FAA) on behalf of Air 

Transport International, Inc. (ATI) for an exemption from item I (b) of Appendix A of part 

61; §§ 61.157(a), 121.424(a)(1), (b)(3), and (d)(1); item I (a) of Appendix E to part 121; and 

item I (b) of Appendix F to part 121 of Title 14, Code of Federal Regulations (14 CFR). 

That exemption, if granted, would allow ATI to conduct training and checking of pilots on 

airplanes that require two flight crewmembers for the required preflight inspection, both 

interior and exterior, using approved advanced pictorial means. 

On August 25, 2014, the FAA granted Exemption No. 4416 (copy enclosed) to Airlines for 

America member airlines and other qualifying part 119 certificate holders conducting 

operations under part 121 for the same relief. 

Because the relief you seek is now covered under Exemption No. 4416, we will take no 

further action on your petition. 

Sincerely, 

/s/ 

Michelle Ferritto 

Manager, Airmen and 

 Airspace Rules Division 

Enclosure
AFS-14-378-E 

This letter corrects the August 25, 2014, letter we sent granting your petition for 

Exemption No. 4416. Corrections were made to reflect changes to paragraph designations in 

part 121 subpart O and to update Condition Nos. 1 and 3. Below is the amended Exemption 

No. 4416 that includes the aforementioned changes. We have made the correction in our 

records as of September 29, 2014. 

August 25, 2014 

 Exemption No. 4416P 

 Regulatory Docket No. FAA-2002-12831 

Mr. Donald R. Dillman 

Managing Director, Flight Operations 

Airlines for America 

1301 Pennsylvania Ave, NW 

Washington, DC 20004 

Dear Mr. Dillman: 

This letter is to inform you that we have granted your petition to extend Exemption No.4416, 

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

and limitations. 

The Basis for Our Decision 

By letter dated July 1, 2014, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Airlines for America (A4A) for an extension of Exemption No. 4416, as amended. 

That exemption from § 121.424(a)(1), (b)(3), and (d)(1); item I (a) of appendix E to part 121; 

and item I (b) of Appendix F to part 121 of Title 14, Code of Federal Regulations (14 CFR) 

allows A4A member airlines and other qualifying part 119 certificate holders conducting 

operations under part 121 to conduct training and checking of pilots on airplanes that require 

two flight crewmembers for the required preflight inspection, both interior and exterior, using 

approved advanced pictorial means. 

Corrected Copy 
 2

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 notes that certain CFR citations requested in your exemption have recently 

changed. The “Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers” 

final rule (78 FR 67799, November 12, 2013, effective March 12, 2014) revised § 121.424(a) 

to be § 121.424(a)(1), and § 121.424(b) to be § 121.424(b)(3), respectively. 

The FAA further notes that Appendix A to part 61 and the reference to Appendix A found in 

14 CFR 61.157(a) were removed from the Code of Federal Regulations as part of the “Pilot, 

Flight Instructor, Ground Instructor, and Pilot Schools Certification Rules” final rule (62 FR 

16220, April 4, 1997). Thus, as these sections no longer exist, exemptions are unnecessary. 

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

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to A4A member 

airlines. 

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 4416, 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, Airlines for America is hereby granted an extension that 

allows A4A member airlines and other qualifying part 119 certificate holders conducting 

operations under part 121 to conduct training and checking of pilots on airplanes that require 

two flight crewmembers for the required preflight inspection, both interior and exterior, using 

approved advanced pictorial means, subject to the following conditions and limitations. 

Conditions and Limitations 

1. Each certificate holder desiring to use the provisions of this exemption must develop 

still and/or motion pictures providing distant and detailed close-up views of each 

passenger compartment and exterior preflight inspection item depicting normal and 

abnormal conditions. 

2. The projection equipment must provide rapid and random access capability to any 

picture for training and checking purposes. 

3. The pictures and descriptions of the items must be approved by the FAA Principal 

Operations Inspector assigned to that certificate holder. 

4. Each pilot must receive training to proficiency and demonstrate proficiency on at least 

one complete visual inspection of the interior and exterior of a static airplane of the 

appropriate type. This training and demonstration of proficiency must be successfully 

completed and documented by a check airman before the completion of operating 

experience required by § 121.434. 
 3

5. Training devices used for the flight deck portion of the preflight visual inspection 

must be approved for that function, must accurately replicate the aircraft flight deck 

geography, and must simulate appropriate systems functions to include control, 

switch, instrument, and circuit breaker functions in regard to normal, abnormal, and 

emergency procedures. 

The Effect of Our Decision 

This exemption terminates on September 30, 2016, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John Barbagallo 

Acting Deputy Director, Flight Standards Service