UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. ___________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF

GUS CHRISTOPHER TOULATOS

SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.39, 61.17, AND 61.156

CONCERNING HIS APPLICATION FOR AN

AIRLINE TRANSPORT PILOT CERTIFICATE

WITH AN AIRPLANE CATEGORY MULTIENGINE CLASS RATING

Submitted on March 12, 2015

GREGORY S. WINTON, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner
2

TABLE OF CONTENTS

 Page

GLOSSARY OF ABBREVIATIONS............................................................................3

SUMMARY....................................................................................................................4

INTRODUCTION AND INTERESTS OF THE PETITIONER....................................4

BACKGROUND.............................................................................................................5

BASIS FOR PETITION..................................................................................................8

NAME AND ADDRESS OF THE PETITIONER................................................10

THE SPECIFIC SECTIONS OF 14 C.F.R FROM WHICH GUS CHRISTOPHER 

TOULATOS SEEKS EXEMPTION.....................................................................10

THE EXTENT OF RELIEF GUS CHRISTOPHER TOULATOS SEEKS AND 

THE REASON HE SEEKS THE RELIEF............................................................12

THE REASONS WHY GRANTING GUS CHRISTOPHER TOULATOS’ 

REQUEST WOULD BE IN THE PUBLIC INTEREST......................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY.......................................................................15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...16

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT GUS CHRISTOPHER TOULATOS’ 

REQUEST.............................................................................................................17

CONCLUSION.............................................................................................................17
3

GLOSSARY OF ABBREVIATIONS

ATP Airline Transport Pilot

C.F.R. Code of Federal Regulations

FAA Federal Aviation Administration

FSTD Flight Simulator Training Device

IACRA Integrated Airman Certification and Rating Application

PIC Pilot in Command
4

SUMMARY

Gus Christopher Toulatos (hereinafter “Mr. Toulatos”), Petitioner herein, hereby seeks an 

exemption from the requirements of 14 C.F.R § 61.39, § 61.17 or, in the alternative, § 61.156, 

concerning his successful completion of the practical test for an Airline Transport Pilot (ATP) 

Certificate with an expired knowledge test report on June 10, 2014. Relief is requested to the 

extent necessary to validate the results of his practical test for an ATP certificate, which was 

satisfactorily completed on June 10, 2014, and in order to reinstate his expired Temporary 

Airman Certificate (No. 3105427), so that he may obtain his permanent certificate with an 

airplane category multiengine class rating. In the alternative, Mr. Toulatos seeks relief from 14 

C.F.R. § 61.156 to the extent necessary for him to take the Airman Knowledge Test for an ATP 

Certificate with multiengine class rating, without the need to present a graduation certificate

from an authorized training provider under 14 C.F.R. part 121, 135, 141, or 142, certifying that 

he has completed training in a course approved by the Administrator.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Mr. Toulatos has been flying as a commercial pilot since 2009, and is currently employed 

as a pilot-in-command (PIC) by Axis Aviation Group, Inc. (“Axis”), which operates aircraft

during on-demand lifeguard flight operations pursuant to 14 C.F.R. part 135. Axis transports

organ transplant teams and medical staff across Northern California and Nevada, in addition to 

transporting doctors to outreach clinics located in rural areas.

Mr. Toulatos holds a valid Commercial Pilot Certificate with Airplane Single Engine 

Land, Airplane Multiengine Land, and Instrument ratings. He has logged approximately 3,300 

total flight hours as of the date of this Petition.
5

As explained more fully below, by obtaining an ATP Certificate, Mr. Toulatos will be 

able to act as the PIC of eligible on-demand lifeguard flights, which he is otherwise not qualified 

with only a Commercial Pilot Certificate. Accordingly, by obtaining an ATP Certificate, Mr. 

Toulatos may rapidly transport, as PIC, time-sensitive and life critical organs scheduled for 

transplant. 

BACKGROUND

On June 10, 2014, Mr. Toulatos successfully completed a 14 C.F.R. Part 135 airman 

competency/proficiency check, and simultaneously successfully completed a practical test for an 

ATP certificate with an expired airman knowledge test report. The ATP practical test for an 

airplane category multiengine class rating was conducted in a Beech King Air C90 aircraft, 

registration number N158J, with Aviation Safety Inspector Richard Jean Michel Conte of the 

Sacramento, California Flight Standards District Office (WP25). 

At the time of the ATP practical test, Mr. Toulatos presented Inspector Conte with an

airman knowledge test report that had expired on October 31, 2012. Nevertheless, on June 10, 

2014, Inspector Conte approved Mr. Toulatos’ use of the expired ATP knowledge test report 

pursuant to 14 C.F.R. § 61.39(b). After Mr. Toulatos successfully completed the oral and 

practical tests, Inspector Conte approved his Integrated Airman Certification and Rating 

Application (“IACRA”) and issued a Temporary ATP Certificate with an airplane category 

multiengine class rating.

Thereafter, on August 21, 2014, more than two months after receiving his Temporary 

ATP Certificate, Mr. Toulatos was verbally informed by Inspector Conte that his ATP Certificate 

IACRA had not been processed by the FAA because Inspector Conte erroneously accepted the

expired ATP knowledge test report. The temporary ATP Certificate, which was issued on June 
6

10, 2014, expired after 120 days pursuant to 14 C.F.R. § 61.17, entitled Temporary certificate,

which states the following:

(a) A temporary pilot, flight instructor, or ground instructor certificate or rating is issued 

for up to 120 days, at which time a permanent certificate will be issued to a person whom 

the Administrator finds qualified under this part.

(b) A temporary pilot, flight instructor, or ground instructor certificate or rating expires:

(1) On the expiration date shown on the certificate;

(2) Upon receipt of the permanent certificate; or

(3) Upon receipt of a notice that the certificate or rating sought is denied or 

revoked.

Notably, Mr. Toulatos never received written notice that his ATP certificate was either

denied or revoked. Regardless, he has never received a permanent certificate pursuant to 14 

C.F.R. § 61.17.

Unfortunately, since Mr. Toulatos was not advised by Inspector Conte until August 21, 

2014, that his expired knowledge test report was inadequate for the ATP Certificate application,

at the time he was informed he could not use his expired airman knowledge test report, Mr. 

Toulatos was no longer eligible to take the airman knowledge test for an airline transport pilot 

certificate with an airplane category multiengine class rating pursuant to 14 C.F.R. §61.156, 

which states the following, in part:

After July 31, 2014, a person who applies for the knowledge test for an airline transport 

pilot certificate with an airplane category multiengine class rating must present a 

graduation certificate from an authorized training provider under part 121, 135, 141, or 

142 of this chapter certifying the applicant has completed the following training in a 

course approved by the Administrator.

(a) Academic training. The applicant for the knowledge test must receive at least 30 

hours of classroom instruction that includes the following:
7

(1) At least 8 hours of instruction on aerodynamics including high altitude 

operations;

(2) At least 2 hours of instruction on meteorology, including adverse weather 

phenomena and weather detection systems; and

(3) At least 14 hours of instruction on air carrier operations, including the 

following areas:

(i) Physiology;

(ii) Communications;

(iii) Checklist philosophy;

(iv) Operational control;

(v) Minimum equipment list/configuration deviation list;

(vi) Ground operations;

(vii) Turbine engines;

(viii) Transport category aircraft performance;

(ix) Automation, navigation, and flight path warning systems.

(4) At least 6 hours of instruction on leadership, professional development, crew 

resource management, and safety culture.

See 14 C.F.R. § 61.156 (emphasis added).

If Mr. Toulatos had been advised by Inspector Conte on June 10, 2014, that it was 

necessary to retake the airman knowledge test, he could have complied without the necessity of 

presenting a graduation certificate from an authorized training provider required by 14 C.F.R. 

§61.156(a), which became effective on July 31, 2014 (i.e., one month and 20 days after obtaining 

the temporary ATP Certificate). However, merely because Inspector Conte waited until after 

August 1, 2014 to advise Mr. Toulatos that he was required to retake the knowledge test for an 

ATP Certificate with an airplane category multiengine class rating, Mr. Toulatos must now 

present a graduation certificate from an authorized training provider under 14 C.F.R. part 

121, 135, 141, or 142, certifying the applicant has completed training in a course approved by the 

Administrator, in order to take the test.

Clearly, at the time Mr. Toulatos passed the practical test for his ATP certificate with 
8

airplane category multiengine class rating on June 10, 2014, the presentation of a graduation 

certificate from an authorized training provider was not required, because the amendment to 14 

C.F.R. § 61.156 did not become effective until August 1, 2014.

Significantly, if Mr. Toulatos had been informed prior to the effective date of the 

amendment to 14 C.F.R. § 61.156, that he was required to retake the ATP airman knowledge 

test, he would have been able to do so without completing the additional training as now required 

by the amended regulation. 

BASIS FOR PETITION

Petitioner, Gus Christopher Toulatos, by and through undersigned counsel, pursuant to 

the provisions of the Federal Aviation Regulations (14 C.F.R. §§ 11.61 and 11.63), hereby 

petitions the Administrator to grant him an Airline Transport Pilot Certificate with an airplane 

category multiengine class rating based upon the issuance of his Temporary Airman Certificate 

(No. 3105427), issued on June 10, 2014, following the successful completion of the practical 

test for an ATP Certificate with an airplane category multiengine class rating.

Relief from the requirements of Section 61.39, entitled Prerequisites for Practical 

Tests, is requested by Mr. Toulatos to the extent necessary to validate his Integrated Airman 

Certification and Rating Application (IACRA) for the issuance of an ATP Certificate with an 

airplane category multiengine class rating. Mr. Toulatos submits that an equivalent level of 

safety will be met by allowing his use of an expired airman knowledge test report in support of 

his IACRA for an ATP Certificate submitted on June 10, 2014.

Additionally, Mr. Toulatos seeks an exemption from the requirements of 14 C.F.R. §

61.17, entitled Temporary Certificate, since he has never received a permanent certificate, and 

because his temporary airman certificate expired after 120 days following its issuance on June 
9

10, 2014. Mr. Toulatos should be issued a permanent certificate pursuant to 14 C.F.R. § 

61.17(a), because he never received written notice that his ATP Certificate was either denied or 

revoked pursuant to 14 C.F.R. § 61.17(b)(3).

Mr. Toulatos submits that an equivalent level of safety will be met by issuing him a 

permanent ATP Certificate with an airplane category multiengine class rating based upon his 

successful completion of the practical test on June 10, 2014.

In the alternative, Mr. Toulatos seeks an exemption from the requirements of 14 C.F.R. 

§ 61.156 to the extent that, in the event he is not issued a permanent ATP Certificate with an 

airplane category multiengine class rating consistent with the issuance of his Temporary Airman 

Certificate, then he should be permitted to take the Airman Knowledge Test for an ATP 

Certificate with an airplane category multiengine class rating, without the need to present a 

graduation certificate from an authorized training provider, which is now required pursuant to

an amendment to 14 C.F.R. § 61.156, which became effective on August 1, 2014, nearly 2

months following the issuance of his Temporary ATP Certificate.

Mr. Toulatos submits that an equivalent level of safety will be met granting him an 

exemption from the requirement to present a graduation certificate from an authorized training 

provider, as a prerequisite to taking the Airman Knowledge Test, because he had already been 

issued an ATP Certificate with an airplane category multiengine class rating prior to an 

amendment to the regulation, which now requires him to present a graduation certificate from 

an authorized training provider.

In accordance with 14 C.F.R. § 11.81, Mr. Toulatos provides the following information 

in support of his petition for exemption:
10

A. Name and Address of the Petitioner.

The name and address of the Petitioner is: 

Gus Christopher Toulatos

1703 E. Wasatch Drive

Ogden, Utah 84403

The point of contact for this Petition and specific contact information is as follows: 

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com

B. The Specific Sections of 14 C.F.R. From Which Gus Christopher Toulatos Seeks 

Exemption.

1. Gus Christopher Toulatos Seeks Exemption From the Requirements of 14 

C.F.R. § 61.39.

14 C.F.R. § 61.39, entitled Prerequisites for Practical Tests, subsection (b) prescribes the 

following, in relevant part:

(b) An applicant for an airline transport pilot certificate with an airplane category 

multiengine class rating or an airline transport pilot certificate with an airplane 

type rating may take the practical test with an expired knowledge test only if the 

applicant passed the knowledge test after July 31, 2014, and is employed:

(1) As a flightcrew member by a part 119 certificate holder conducting 

operations under parts 125 or 135 of this chapter at the time of the 

practical test and has satisfactorily accomplished that operator's approved 

pilot-in-command training or checking program.

2. Gus Christopher Toulatos Seeks Exemption from the Requirements of 

14 C.F.R. § 61.17.

14 C.F.R. § 61.17, entitled Temporary Certificate, prescribes the following, in relevant 

part:

(b)A temporary pilot, flight instructor, or ground instructor certificate or rating expires:

(1) On the expiration date shown on the certificate;
11

(3) Upon receipt of a notice that the certificate or rating sought is denied or 

revoked.

3. Gus Christopher Toulatos Seeks Exemption from the Requirements of 

14 C.F.R. § 61.156.

14 C.F.R. § 61.156, entitled Training requirements: Airplane category—multiengine 

class rating or airplane type rating concurrently with airline transport pilot certificate, 

prescribes the following:

After July 31, 2014, a person who applies for the knowledge test for an airline transport 

pilot certificate with an airplane category multiengine class rating must present a 

graduation certificate from an authorized training provider under part 121, 135, 141, or 

142 of this chapter certifying the applicant has completed the following training in a 

course approved by the Administrator.

(a) Academic training. The applicant for the knowledge test must receive at least 30 

hours of classroom instruction that includes the following:

(1) At least 8 hours of instruction on aerodynamics including high altitude 

operations;

(2) At least 2 hours of instruction on meteorology, including adverse weather 

phenomena and weather detection systems; and

(3) At least 14 hours of instruction on air carrier operations, including the 

following areas:

(i) Physiology;

(ii) Communications;

(iii) Checklist philosophy;

(iv) Operational control;

(v) Minimum equipment list/configuration deviation list;

(vi) Ground operations;

(vii) Turbine engines;

(viii) Transport category aircraft performance;

(ix) Automation, navigation, and flight path warning systems.

(4) At least 6 hours of instruction on leadership, professional development, crew 

resource management, and safety culture.

(b) FSTD training. The applicant for the knowledge test must receive at least 10 

hours of training in a flight simulation training device qualified under part 60 of 
12

this chapter that represents a multiengine turbine airplane. The training must 

include the following:

(1) At least 6 hours of training in a Level C or higher full flight simulator 

qualified under part 60 of this chapter that represents a multiengine turbine 

airplane with a maximum takeoff weight of 40,000 pounds or greater. The 

training must include the following areas:

(i) Low energy states/stalls;

(ii) Upset recovery techniques; and

(iii) Adverse weather conditions, including icing, thunderstorms, and 

crosswinds with gusts.

(2) The remaining FSTD training may be completed in a Level 4 or higher flight 

simulation training device. The training must include the following areas:

(i) Navigation including flight management systems; and

(ii) Automation including autoflight.

(c) Deviation authority. The Administrator may issue deviation authority from the 

weight requirement in paragraph (b)(1) of this section upon a determination that 

the objectives of the training can be met in an alternative device.

C. The Extent Of Relief Gus Christopher Toulatos Seeks And The Reason For The 

Relief Sought.

1. Extent of Relief Gus Christopher Toulatos Seeks And The Reason He Seeks 

Relief From 14 C.F.R. § 61.39.

Relief from 14 C.F.R. § 61.39, entitled Prerequisites for Practical Tests, is requested to

the extent necessary to validate Mr. Toulatos’ application and subsequent successful completion 

of the practical test for an ATP Certificate with an airplane category multiengine class rating on 

June 10, 2014. 

This relief is requested since the limitations set forth in 14 C.F.R. § 61.39(b) state that in 

order to take the practical test for an Airline Transport Pilot Certificate with airplane category 

multiengine class rating with expired knowledge test results, an applicant must: (1) have passed 

the knowledge test after July 31, 2014; and (2) as a flightcrew member of a Part 119 certificate 

holder conducting Part 135 operations at the time of the practical test, have satisfactorily passed 
13

the operator’s approved pilot-in-command training or checking program.

Mr. Toulatos submits that an equivalent level of safety will be maintained because at the 

time he was issued a Temporary ATP Certificate on June 10, 2014, he had passed the knowledge 

test prior to July 31, 2014; and (2) as a flightcrew member of a Part 119 certificate holder 

conducting Part 135 operations at the time of the practical test, he had satisfactorily passed the 

operator’s approved pilot-in-command training or checking program.

2. Extent of Relief Gus Christopher Toulatos Seeks And The Reason He

Seeks Relief From 14 C.F.R. § 61.17.

Relief from 14 C.F.R. § 61.17, entitled Temporary Certificate, is requested to the extent 

required to reinstate the Temporary ATP Certificate Mr. Toulatos was issued on June 10, 2014,

so that he can receive a permanent ATP Certificate pursuant to 14 C.F.R. § 61.17(a).

Mr. Toulatos seeks the requested relief because his Temporary ATP Certificate was not 

made permanent within 120 days pursuant to 14 C.F.R. § 61.17(a), and because he has never

received notice that his ATP certificate had been denied or revoked pursuant to 14 C.F.R. § 

61.17(b).

Mr. Toulatos submits that safety will not be affected since his Temporary ATP Certificate 

should have been replaced with a permanent certificate because he successfully completed the 

practical test and never received notice that the certificate was denied or revoked in accordance 

with 14 C.F.R. § 61.17(b)(3).

3. Extent of Relief Gus Christopher Toulatos Seeks and the Reason He Seeks 

Relief From 14 C.F.R. § 61.156.

Relief from 14 C.F.R. § 61.156, entitled Training requirements: Airplane category—

multiengine class rating or airplane type rating concurrently with airline transport pilot 

certificate, is sought to the extent necessary to allow Mr. Toulatos to take the ATP Airman 
14

Knowledge Test without first graduating from an authorized preliminary training course.

Mr. Toulatos seeks the requested relief because he was not advised that his expired 

airman knowledge test records were insufficient until after an amendment to 14 C.F.R. § 61.156

became effective on August 1, 2014.

Mr. Toulatos submits that safety will not be affected because he would have been eligible 

to retake the Airman Knowledge Test without first graduating from an authorized preliminary 

training course if Inspector Conte had informed him that he needed to do so prior to August 1, 

2014.

D. The Reasons Why Granting Gus Christopher Toulatos’ Request Would Be In The 

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Mr. Toulatos to 

safely act as the PIC of aircraft operated during eligible on-demand flight operations pursuant to 

14 C.F.R. Part 135 for his employer Axis.1 As a major part of these on-demand flight operations, 

Mr. Toulatos will be transporting doctors and support staff to rural areas and outreach clinics in 

order to provide quality healthcare to those who may otherwise not have such critical care 

readily available. Additionally, Mr. Toulatos will be transporting organs for transplants that are 

 

1

14 C.F.R. § 135.4, entitled Applicability of rules for eligible on-demand operations, states the following, in 

relevant part:

(a) An “eligible on-demand operation” is an on-demand operation conducted under this part that meets the 

following requirements:

(1) Two-pilot crew. The flightcrew must consist of at least two qualified pilots employed or 

contracted by the certificate holder.

(2) Flight crew experience. The crewmembers must have met the applicable requirements of 

part 61 of this chapter and have the following experience and ratings:

(i) Total flight time for all pilots:

(A) Pilot in command—A minimum of 1,500 hours.

(B) Second in command—A minimum of 500 hours.

(ii) For multi-engine turbine-powered fixed-wing and powered-lift aircraft, the following FAA 

certification and ratings requirements:

(A) Pilot in command—Airline transport pilot and applicable type ratings.

Emphasis added.
15

critical for the life of the expectant recipients. As an ATP with an airplane category multiengine 

class rating, Mr. Toulatos may act as the PIC during the above-described life critical on-demand 

flight operations, which he would not otherwise be approved if he only held a Commercial Pilot 

Certificate. Granting this Petition will help ensure that there is minimal delay in making certain

that Mr. Toulatos can fulfill the role of a qualified pilot capable of conducting these important 

life critical flights. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A level Of Safety At Lease Equal To That 

Provided By The Rule From Which Gus Christopher Toulatos Seeks Exemption.

1. Reasons Why Granting Exemption From The Requirements Of 14 C.F.R. §

61.39 Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule.

The equivalent level of safety established by 14 C.F.R. § 61.39 will be maintained 

because of the extensive ground and flight training received by Mr. Toulatos, specific to the 

aircraft type and 14 C.F.R. part 135 operations in which the he will be serving. The 

comprehensive nature of this training provides sufficient assurance that the pilot’s knowledge 

has been adequately checked prior to the certification evaluation for the ATP Certificate.

Additionally, the FAA has previously granted relief from 14 C.F.R. § 61.39(b) in similar 

circumstances to those presented herein (e.g., Exemption Nos. 10930, 10937, 10938). 

2. Reasons Why An Exemption From The Requirements Of 14 C.F.R. §

61.17 Would Not Adversely Affect Safety.

The level of safety established by 14 C.F.R. § 61.17 will be assured because, as provided 

in 14 C.F.R. § 61.17(a), a temporary pilot certificate or rating is issued for up to 120 days, at 

which time a permanent certificate will be issued to a person whom the Administrator finds 

qualified under 14 C.F.R. part 61. The granting of an exemption from the requirements of §

61.17 would warrant the reinstatement of Mr. Toulatos’ Temporary ATP Certificate, which 
16

could then be made permanent pursuant to 14 C.F.R. § 61.17(a).

Mr. Toulatos submits that the reasons why an exemption from the requirements of 14 

C.F.R. § 61.17 would not adversely affect safety because his Temporary ATP Certificate should 

have been replaced with a permanent certificate since he successfully completed the practical test 

and never received notice that the certificate was denied or revoked in accordance with 14 C.F.R. 

§ 61.17(b)(3).

3. Reasons Why An Exemption From The Requirements Of 14 C.F.R. § 61.156 

Would Not Adversely Affect Safety.

The level of safety established by 14 C.F.R. § 61.156 will be maintained because Mr. 

Toulatos would have been able to retake the Airman Knowledge Test between June 10, 2014,

and July 31, 2014, without first graduating from an authorized preliminary training course. Mr. 

Toulatos submits that the reason why an exemption from the requirements of 14 C.F.R. § 61.156 

would not adversely affect safety is because the relief sought would merely put him in the same 

position that he would have been in on June 10, 2014, when he successfully completed the ATP 

practical test.

F. A Summary That Can Be Published In The Federal Register, Stating: The Rules 

From Which Gus Christopher Toulatos Seeks Exemption And A Brief Description 

Of The Nature Of The Exemption He Seeks.

Pursuant to 14 C.F.R. § 11.87, Mr. Toulatos respectfully requests that the FAA not 

publish a summary of his Petition for exemption and request comments, because good cause

exists why the FAA should not delay action on his Petition. The factors to be considered in 

deciding not to request comment include:

(a) Granting Mr. Toulatos’ Petition would not set a precedent.

(b) The relief requested is similar to exemptions granted previously (e.g., Exemption Nos. 

10930, 10937, 10938).
17

(c) Delaying action on Mr. Toulatos’ Petition would affect him adversely.

(d) Mr. Toulatos filed his Petition in a timely manner.

G. Any Additional Information, Views, Or Arguments Available To Support Gus 

Christopher Toulatos’ Request.

On June 10, 2014, Gus Christopher Toulatos met all of the eligibility requirements for 

ATP certification as required by 14 C.F.R. §§ 61.153, 61.157, and 61.159. Additionally, he 

successfully completed the ATP practical test for an airplane category multiengine class rating

with an expired knowledge test report prior to the effective date of the amendment to 14 C.F.R. § 

61.156 on August 1, 2014. The amendment required that after July 31, 2014, a person who 

applies for the knowledge test for an airline transport pilot certificate with an airplane category 

multiengine class rating must present a graduation certificate from an authorized training 

provider under 14 C.F.R. part 121, 135, 141, or 142, certifying that the applicant has completed 

the training in a course approved by the Administrator. 

Since Mr. Toulatos qualified for his ATP certificate prior to the effective date of the new 

regulatory requirements, he should be exempt for the requirement and be issued his permanent 

ATP Certificate because his certificate has never been denied or revoked.

CONCLUSION

As set forth herein, Gus Christopher Toulatos seeks an exemption from the requirements 

of 14 C.F.R § 61.39, § 61.17 or, in the alternative, § 61.156, concerning his successful 

completion of the practical test for an Airline Transport Pilot (ATP) Certificate with an expired 

knowledge test report on June 10, 2014. Relief is requested to the extent necessary to validate 

the results of his practical test for an ATP certificate, which was satisfactorily completed on June 

10, 2014, and in order to reinstate his expired Temporary Airman Certificate (No. 3105427), so 

that he may obtain his permanent certificate with an airplane category multiengine class rating. 
18

In the alternative, Mr. Toulatos seeks relief from 14 C.F.R. § 61.156 to the extent necessary for

him to take the Airman Knowledge Test for an ATP Certificate with multiengine class rating, 

without the need to present a graduation certificate from an authorized training provider under 14 

C.F.R. part 121, 135, 141, or 142, certifying that he has completed training in a course approved 

by the Administrator.

By granting this Petition, the FAA Administrator will advance the interests of the public

by allowing Mr. Toulatos to safely act as PIC during critical on-demand lifeguard flight 

operations conducted pursuant to 14 C.F.R. part 135, which will benefit public health.

WHEREFORE, Petitioner, Gus Christopher Toulatos, respectfully requests that the 

Administrator grant this Petition for an exemption from the regulatory requirements of 14 C.F.R. 

§§ 61.39 and 61.17, or 14 C.F.R. § 61.156, and issue him a permanent ATP Certificate for the 

purpose of conducting on-demand lifeguard flight operations pursuant to 14 C.F.R. part 135 or, 

in the alternative, to permit Mr. Toulatos to take the ATP Airman Knowledge Test without first 

graduating from an authorized preliminary training course as required by 14 C.F.R. § 61.156.

Dated: March 12, 2015

Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

Gregory S. Winton, Esq.

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorney for Petitioner