May 16, 2012

Docket FAA-2007-0001-0001

Federal Aviation Administration

Office of the Chief Counsel Attention: Regulatio ns Division (AGC-200) 800 Independence Ave., SW, Room 915G Washington, DC 20591

Re: Petition for Exemption

Dear Sir or Madam:

Comair, Inc, petitions pursuant to Secti ons 11.61 and 11.63 of the Federal Aviation Regulations (“FARs”) for an exemption from the regulatory requirement s of FARs 61.39(a) and (b) and 61.157(b) and (c) with regard s to applicants for (i) an aircra ft type rating to be added to an airline transport pilot certificate or (ii) a ty pe rating to be concurrently completed with an airline transport pilot certificate.

Currently, FAR 61.39(b)(1)(i) and (ii) provides for an exception from the requirements of FAR 61.39(a)(1) insofar as it allows the use of an expired knowledge test so long as the applicant is an employee of a Part 121, 125, or 135 certificat e holder and “has satisf actorily accomplished that operator’s approved pilot in command aircraft qualification training program and qualification training requirements for the certif icate and rating sought. ” FAR 61.39(b). In addition, FAR 61.157(c) provides for an excepti on from the requirements of FAR 61.157(b). Thus, an aircraft type rating ap plicant is exempt from ground a nd flight training, as well as practical test, on the areas of operation under 61.157(e) so long as the applicant is an employee of a Part 121 or 135 certificate holder and “present s a training record that shows completion of the certificate holder’s approved pilot in command tr aining program for the ai rcraft type rating.” FAR 61.157(c).

In contemplation of the fast-approaching August 2, 2013 deadline for compliance with the statutory requirement contained in the Airlin e Safety and Federal Aviation Administration Extension Act of 2010 (the “Act”) that all Part 121 flight cr ew members must hold an ATP certificate, Comair requests th at our pilots participating in our AQP approved second in command training program also be able to take advantage of the exceptio ns in FAR 61.39(b) and 61.157(c) , upon presenting a training record sh owing completion of the certificate holder’s approved second in command training program for the aircraft type rating. As a condition for accepting this relief, Comair will agree not to allo w our SICs to operate as PICs under their newFederal Aviation Administration

Office of the Chief Counsel Attention: Regulatio ns Division (AGC-200) May 16, 2012 Page 2

ATP certificate until they have completed Comai r’s approved PIC training program. To the extent necessary to receive the benefits of th e above-mentioned requests, Comair also seeks a parallel exemption under FAR 61.51. Approval of the exemption request ed herein is in the public in terest inasmuch as it would reduce unnecessary costs and facili tate compliance with the stat utory requirements of the Act and any corresponding regulatory provi sions that are adopted , to the extent a pplicable. The FAA has acknowledged in Notice N8900.184 that delays in the ATP certification process of SICs “could pose significant challenges” to air carriers and the FAA itself due to the number of SICs who currently only hold a commercial pilot certi ficate and the training hours and certification activities required to provide ATP certification. Granting this narrowly tailored exemption request would alleviate our concerns about meeting the complia nce deadline without compromising aviation safety.

Comair respectfully requests that the exemp tion be granted expeditiously. A delay in granting this exemption would result in hardship to our customer’s inasmuch as otherwise qualified SICs would not be able to perform th eir duties, causing a loss of revenue that would ultimately affect the pric e of air transportation.

Please do not hesitate to contact me if you have any qu estions or require additional information in order to act on this petition.

Respectfully submitted,

Captain Steven A. Briner Director, Corporate Training Comair, Inc.

82 Comair Blvd. Erlanger, Ky 41018 (859)-980-7631

SBriner@comair.com