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CENTURION O^ffi© -vrjORTATION 

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January 27, 2011 

Docket Management Facility 

U$ Department of Transportation 

1200 ^4ew Jersey Avenue. SE 

West Building Ground Floor 

Room W12-140 

Wasiiington, DC 20590 

Re: Exemption from FAR 

Dear Sir/Madam: 

In accordance with §11.61 of Title 14, Code of Federal Regulations (14 CFR), Centurion Cargo petitions 

the Administrator for an exemption from §121.434{cX1K*i) to the extent necessary to substitute a 

qualified and authorized check atmnan in place of an FAA Inspector to observe a qualifying pilot in 

command (PIC) while that PIC is performing prescribed duties during at least one flight that includes a 

takeoff and a landing when completing initial or upgrade trainirig as specified in §121.434. 

The specific section 121.434(c)(1 )(ii) - OPERATING EXPERIENCE. OPERATING CYCLES, 

AND CONSOLIDATION OF KNOWLEDGE AND SKILLS reads in pertinent part: 

"In addition, if a qualifying pilot in command is completing initial or upgrade training specified 

in FAR 121.424. be observed in the performance of prescrit)ed duties by an FAA Inspector 

during at least one flight leg which includes a takeoff and a landing." 

This petition requests relief from §121.434<cX1 X") '^ those circumstances when an FAA Inspector is 

ur^availabte to observe a qualifying pilot in command during any operating experience flights. 

- Centurion Cargo will nominate qualified Check Airmen to perform these inltlat operating experience 

observati(xis. The FAA will approve the qualified check aimnen to conduct the observation flights through a 

letter of authorization. 

- The requirement of §121.434(c)(1 )(ii) will be considered fulfilled if an FAA authorized Check 

Airman performs the observation. The observation requirement will be documented in the 

qualifying pilot's records. 

- The authorized Check Airman would be one other than he who is conducting the Operating 

Experience flights of the qualifying pilot. 

The original intent of §121.434(cX1 Xii). issued in 1970, was to validate the training that a pitot received in a 

visual simulator. S;ince the adoption of the rule, the airline industry has gathered more than 30 years of 

experience with basic and advanced s'tmuiation. 

www.centurloncargo.co m 

1851 NW. 68th Ave., BIdg. 706 Suite 225, Miami, FL 33126 USA 

Tel: 305-871-0130 - Fax: 305-871-0118 
The FAA has the authority to observe any pilot any time at the discretion of the Administrator and continues 

to do so on a regular basis. However, the FAA conducts these routine obsen/ations on a schedule defined 

by the local CMC without the requisite burden of specifying a partk;ular flight or flight series necessitated by 

the carrier's training and service schedule. Relieving FAA Inspectors from §121.434(cX1 X'O will allow the 

FAA to focus the efforts on higher priority safety concerns. 

Operational issues related with this request for exemption are listed below: 

- The majority of Centurion's flight operations are very often short notice and most always Intematbnal in 

nature. Scheduling of FAA Inspectors to observe a qualifying pilot in command on an international 

operation on such short nottee and to destinations abroad, is difficult. If not impossible. 

As a result of these issues, many of our PIC candidates are sen/ing in OE status in excess of the hours 

required for the completion of the qualification segment while awaiting FAA participation. This impacts 

our crew scheduling ability and places unnecessary financial burden on the company. 

Granting of this exemption is in the public Interest and would allow the FAA to focus its inspection force on 

higher priority safety Issues. It would also provide for a higher level of PIC candidate scrutiny by using 

Centurion Check Ainnen w+io are more familiar with company operating policies and procedures while 

eliminating delays In the completion of the Operating Experience process. Additional benefits are realized 

in increased productivity and reducing unnecessary additional costs to the company. 

Granting and using this proposed exemption would have no significant impact upon safety. The authorized 

Check Airman will be highly trained, experienced, and qualified in the specific aircraft type. In addition, any 

Check Airman utilized must be approved by the FAA. Only Centurion qualified Check Almrien will be used 

to satisfy frie requirements of §121.434(cX1X'i) when a qualified FAA Inspector is not available. The FAA 

has the authority to observe any pilot at any time during line operations. 

Centurion Cargo is aware of the precedent with regards to previous exemptions granted to other Air 

Camers for similar relief as that which is sought by this request. Therefore, since granting this exemption is 

not precedent setting, Centurion requests that publication of this petition in the Federal Register be waived 

in accordance with Section 11.87(b). Any delay in granting this exemption will have an adverse impact 

upon Centurion Cargo operations. 

SUMMARY 

Centurion Cargo Petition for an Exemption to FAR 121.434(c)(1)(ii) 

Centurion Cargo petitions the Administrator for an exemption from §121.434(cX1X'i) to the extent 

necessary to sutistituta a qualified and authoriZBd Check Auman in place of an FAA Inspector to observe a 

qual?fyihg Pilot in Comifjand (PIC) whiTe Biat PIC is performing prescn"bed duties during at least one flight 

that Includes a takeoff and a landing when completing Initial or Upgrade Training as specified in §121.434. 

Should you have any questkxisor need addltronal information, please contact me at 305-871-0130 ext. 5508 

or cfrias@centurioncarao.com 

Sincerely, 

Carios E. Frias 

Director of Operations