October 07, 2014

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Subject: Petition for Exemption – Request to expand relief given to military and civilian 

personnel supporting the Armed Forces stationed outside the United States from 

knowledge test expiration to those supporting the Armed Forces who were 

stationed in the United States (61.39(a)(1)(i)(ii))

To whom it may concern:

The Air Line Pilots Association, International (ALPA) is the largest airline pilot union in the 

world and represents the interests of over 51,000 pilots who fly for 30 airlines in the U.S. and 

Canada. We are submitting this “Petition for Exemption” pursuant to 14 C.F.R. Sections 11.61 

and 11.63 requesting the FAA to expand the relief from the knowledge test expiration dates 

contained in 14 CFR 61.39(a)(1)(i)(ii) already granted to others. The additional relief sought is 

for those who served in a U.S. military or civilian capacity in support of the U.S. Armed Forces

that were stationed in the U.S.

There is a precedent for providing relief from the requirements that the knowledge test be taken 

within the designated times preceding the practical test contained in 14 CFR 61.39. Relief is 

already provided to those who served in a U.S. military or civilian capacity outside the U.S. in 

support of the U.S. Armed Forces by 14 CFR Part 61 SFAR 100-2. This relief recognizes the 

priority of military service and the logistical difficulty of having access to the practical test.

SFAR 100-2 only applies to those who were stationed outside the U.S. We request that relief to 

use an expired knowledge test also be made available to those who served in the U.S. ALPA 

feels that the same challenges to taking the knowledge test by members of the Armed Forces 

overseas can exist for all those in military service regardless of their duty location.

It is very possible that those stationed in the U.S. would not have the time or access to facilities

to pursue acquiring the required ground and flight training, build the required aeronautical 

experience and study in preparation to take the practical test while fulfilling their service duties.
In regards to the ATP knowledge test in particular, many who had already passed the ATP 

knowledge test but had not completed the practical test were pilots who had to go on leave 

from their respective airlines to serve. Not only those stationed outside the U.S., but even the 

pilots stationed in the U.S. would not have the opportunity to obtain their ATP through their 

employer while on leave. As you are aware, even pilots stationed at U.S. bases flew missions 

over other areas of the world from those bases either on board the aircraft or operating as a pilot 

of a UAS/RPA aircraft. These assignments and operations required considerable training 

preparation and focus, leaving little time for other non-military activities. Obtaining the ATP 

through their employer allows them to utilize the aircraft/simulator they are proficient on for 

the practical test. The time and cost for the pilot to reach an ATP proficiency skill level on a 

different aircraft would be excessively burdensome. These pilots should not be subject to 

retaking the ATP knowledge test with a prerequisite of first taking an ATP CTP course which 

would add a significant burden of time and expense. Therefore, pilots who served in a U.S. 

military or civilian capacity in support of the U.S. Armed Forces in the U.S. should also be 

provided relief so that they can use an expired knowledge test to take the practical test. 

Public Interest:

We believe an equivalent level of safety will be obtained by extending the knowledge test 

expiration relief to those who served and were stationed in the U.S. as it is for those stationed 

outside the U.S. In fact, in regards to the ATP knowledge test, an increased level of safety may 

be achieved. This is so because the airline pilots who were already proficient on their airline’s 

air transport category aircraft will not potentially be required to take an ATP CTP course on 

different equipment. Such training would be inconsistent with what they have already been 

taught by the air carrier and require the pilot to unlearn portions of what was taught by the air 

carrier to pass the ATP CTP course, and finally unlearn portions of what was taught at the ATP 

CTP course to transition back into the aircraft they fly for their airline. This confusing process 

would potentially impact safety in a negative way.

Thank you for considering this petition for exemption. If you have any questions please contact 

Mr. Kevin Comstock at 703-689-4176.

Sincerely,

Captain Sean Cassidy

National Safety Coordinator

cc: P. Gilligan, Assoc. Admin. for Aviation Safety, FAA

J. Duncan, Director, Flight Standards Service