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

SECTION S 61.39

, 61.17

, AND 6 1.156

CONCERNING HIS APPL ICATION FOR AN

AIRLINE TRANSPORT PILOT CERTIFICATE

WITH AN AIRPLANE CATEGORY MULTIENGINE CLASS RATING

Submitted on March 1 2 , 2015

G REGORY S. W INTON

, E SQ

. T HE A VIATION L AW F IRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294

- 8550

Fax: (866) 568

- 9886

Attorney for Petitioner2 TABLE OF CONTENTS

Page

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

. ........... ........3

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

INTRODUCTION AND INTERESTS OF THE PETIT IONER....................................4

BACKGROUND..............................................................................

............................... 5

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

...... ......................... 8

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

THE SPECIFIC SE C TIONS 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

.................................................. .......... 1 2

THE REASONS WHY GRANTING GUS CHRISTOPHER TOULATOS’

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

....................... . ...... 1 4

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY........................................... ............................1 5

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL RE GISTER...1 6

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT GUS CHRISTOPHER TOULATOS’

REQUEST............................................................................... ..............................1 7

CONCLUSION............................................................................... ..............................1 73 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 Command4 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)

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

extent necessary to validate the results of his pract ical 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 c lass 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 Grou p, Inc

. ( “ Axis ” ) , which operates aircraft

during on

- demand lifeguard flight operations pursuant to 14 C.F.R. part 135. Axis transport s

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

tr ansporting doctors to outreach clinics located in rural areas

.

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

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

total flight hours as of the date of this P etition.5

As explained more fully below, b y obtaining an ATP Certificate, Mr. Toulatos w ill 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 complete d 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 a n

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

a irman k nowledge t est r eport 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 complet ed the oral and

practical tests

, Inspector Conte approved his Integrated Airman Certification and Rating

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

multiengine class rating

.

Thereafter, o n August 21, 2014, more than two months after receiving his T emporary

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 June6

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 rece ipt 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 nev er 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 fo r 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, in cluding 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).

I f 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 compl ied 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 Cer ti ficate ). However, merely because Inspector Conte waited until after

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

ATP C ertificate 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 t he

Administrator , in order to take the test

.

Clearly, a t the time Mr. Toulatos passed the practical test for his ATP certificate with8

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

amend ment to 14 C.F.R. § 61.156

, that he was required to retake the ATP a irman k nowledge

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

by the am ended 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 a n 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 complet ion 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 C ertificate 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 a irman k nowledge t est 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 t emporary airman certificate e xpired after 120 days following its issuance on June9

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 C ertificate 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.

I n 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 pur s ua n t 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 Certifi cate with an airplane category multiengine class rating prior to an

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

an authorized training provider

.

In accordance with 14 C.F.R. § 11.81, M r

. 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

- 988 6

Ema il: 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 F rom the Requirements of 14

C.F.R. § 61.3 9

.

1 4 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 clas s 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 accomplis hed that operator's approved

pilot

- in

- command training or checking program

.

2. Gus Christopher Toulatos Seeks Exemp tion from the Requirements of

14 C.F.R. § 61.17

.

14 C.F.R. § 61.17, entitled Temporary Certificate

, prescribe s 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 certificat e or rating sought is denie d 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 multien gine class rating must present a

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

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

course approved by the Administrator.

(a) Academic training. The applicant for the kn owledge 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, in cluding 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 of12

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 T oulatos Seeks And The Reason He Seeks

Relief From 14 C.F.R. § 61.39

.

Relief f r o m 1 4 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 1 4 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 re sults

, 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 passed13

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 AT P Certificate on June 10, 2014

, he had passed the knowledge

test prior to J uly 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 traini ng or checking program.

2. Extent of Relief Gus Christopher T oulatos 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 t o reinstate the Temporary ATP Certificate Mr. Toulatos was issued on June 10, 2014

,

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

.

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

made permanent withi n 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 su ccessfully 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. § 61.15 6 , 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 Airman14

Knowledge Test without first graduating from an a uthorized 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 tha t he needed to do so prior to August 1,

2014

.

D. The Reasons Why Granting Gus Christop her 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 PI C of aircraft operated during eligible on

- demand flight operation s 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 healthca re 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 t h e 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 req uirements 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 recipient s

. A s an ATP with an airplane ca tegory multiengine

class rating , Mr. Toulatos may act as the PIC during the above

- described life critical on

- demand

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

C ertificate

. 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 Exempt ion Would Not Adversely Affect Safety, Or

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

Provided By The R ule From Which Gus Christopher Toulatos Seeks Exemption.

1. Reasons Why Granting Exempt ion From The Requirements O f 14 C.F.R. §

61.39 Would Provide A Level Of Safety At Leas t 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 operation s in which the h e 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, which16

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

.

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

C.F.R. § 61.17 would n ot 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.

Toul atos 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

publis h a summary of his P etition for exemption and request comments

, because good cause

exists why the FAA should not delay action on his P etition. The factors to be consider ed in

deciding not to request comment include:

(a) G ranting Mr. Toulatos’ P etition would not set a precedent.

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

10930, 10937, 10938).17

(c) D elaying action on Mr. Toulatos’ P etition would affect him adversely.

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

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

Christopher Toulatos’ Request.

On June 10, 2014

, Gus Christopher Toulatos met all of the eligibility requi rements for

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

successfully completed the ATP practica l 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 a fter July 31, 2014, a person who

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

multien gine class rating must present a graduation certificate from an authorized training

provide r under 14 C.F.R. part 12 1, 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 t h e effective date of the new

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

ATP C ertificate 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) C ertificat e 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 t o 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 tr aining 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

operation s conducted pursuant to 14 C.F.R. p art 135 , which will benefit public health.

WHEREFORE

, P etitioner

, 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. p art 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 1 2 , 2015

Respectfully sub mitted,

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