:• .. , 

Flight Standards District Office 

7150 Republic Airport, Suite 235 .. 

Farmin~dale, New York 1'1735-1'583 · 

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' IJP~1U!WAt\ Cl:.ll\SE &Co. \ • • ' I ' c~· " ' - ,' 

Subject: ,JPMorgan.Chase & Co., N.A; (JPMC)- Petition for Exemption from 14 CFR Part'91.61 .57( a), 

.I 

Recent flight experience: Pilot-in-command requirements as applicable to certain Gulfstream Large Cabin Airplanes 

Dear Sir or Madam: 

As provided:in'·14 CFR Section §11 .81 (b), J PMC hereby petitiohs for relief from the rule as defined below as it applies to the Gulfstream 

G550, G650/G650ER airplanes. 

In accordance with 14 CFR §11 .81 (b)- The specific section(s} from which relief is sought: 

14 CFR §61 .57 (a) General experience: 

(1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an 

aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within 

the preceding 90 days and-

(i) The person acted as the sole manipulator of the flight controls; and 

(ii) The required iakeoffs and landings were performed in an aircraft-of the same category, class, and'type (if a type rating is 

required) ... 

14 CFR §11 .81 (c)- Extent and reason for seeking relief: 

The Gulfstream types, the G550 (G-V), G650ER (GVI), for which relief is sought is based on the extensive similarities of the aircraft 

structure, systems, avionics, performance and flight characteristics of these airplanes. This relief is sought due to the ultra-long range 

nature of JPMC flight operations in both aircraft types. This results in reduced operational opportunities for accomplishing the required 

number of takeoffs and landings amongst the JPMC pi!o.t,,Q(O\JP: .\~i,s,ex~r:rption i~ r~quested to provide limited relief from a 

fundamentally redundant "general experience" reqci]Ye(l'!ent between \wo ?irplai)eitype_s with highly similar flight characteristics. For 

reference, the following represent some similaritie$: · · 

Dimensions 

MTOW 

Range 

Max Operating Speed 

Max Operating Altitude 

Approach Speeds (6,000 #s remaining SL) 

Max Landing Weight 

Landing Distance 

Avionics 

14 CFR §11.81 (d)- Public interest! benefit: 

G556 

97x94x26 

91,000 

6,750 nm 

.885M 

51,000 feet 

118 KCAS 

75,300 

2,770 feet 

Honeywell Primus Epic 

Planeview (ASC- 911) 

'' 

B50ER 

100 x 100 x26 

99,600 

7,000 nm 

.925M 

51,000 feet 

120 KCAS 

83,500 

3,000 feet 

Honeywell Primus Epic PlaneView II 

Relief from the current requirements of 14 CFR §61 .57 (a) would be addressed operationally as outlined in JPMC Conditions and 

Limitations. JPMC believes that its internal training requirements, as noted in CFR §11.81 (g), combined with the attached conditions and 

limitations would provide an equivalent level of safety as required in this part of the rule. Users of the airspace in and around the JPMC 

flight department base of operations would benefit by reduced airspace congestion and noise. The general public will also benefit from a 

reduction in aircraft noise by eliminating any additional local air traffic, currently required as training events, utilized to meet the operational 

shortfall of the general experience flight requirements for currency. 

14 CFR §11.81 (e) -Information supporting this petition: 

The relief sought by JPMC would not compromise the minimum level of safety as intended by the current rule as JPMC will apply the relief 

only within the context of the following JPMC Conditions and Limitations: 

(1) This exemption applies only to JPMorgan Chase Corporate Aviation pilots who hold an FAA issued pilot certificate with a type rating 

in both the Gulfstream manufactured G550 and G650ER airplanes and only while engaged in flight operations 

conducted on behalf of JPMorgan Chase. 

(2) Each pilot in command (PIC) exercising the privileges of this relief must meet the requirements of §61.57(a) and (b) in at least one 

of the types of Gulfstream G550 or G650ER airplanes. 
(3) Each PIC exercising the privileges of this relief may meet the requirements of§ 61.57 (a) or (b) in a Level Cor level D 

simulator that is representative of the Gulfstream G550 and G650ER airplanes. Should a Level CorD simulator be used in 

meeting the requirements of§ 61.57 (a) and (b) the pilot must make three takeoffs and three landings to full stop, subject to the 

following requirements: 

The simulators used must be qualified and approved by the FAA for the takeoff and landing maneuver 

ii. The takeoffs and landings must be accomplished under the supervision of simulator instructor who certifies the pilot being 

observed is proficient in making takeoffs and landings 

iii. The pilot must be the sole manipulator of the flight controls 

iv. The flight simulator's visual system must be adjusted to display a visual scene representing the period of 1 hour after sunset 

until 1 hour before sunrise 

(4) Since the beginning of the preceding 12 calendar months, the pilot must accomplish 120 hours of pilot time, 60 hours of which must 

be in one of the G550 or G650ER airplanes; or 

(1) Since the beginning of the preceding 6 calendar months, the pilot must accomplish 60 hours of pilot time, 30 hours of 

which must be in one of the G550 or G650ER airplanes 

(5) A copy of this exemption must be provided to each PIC who operates under the terms of this exemption. 

(6) A copy of this exemption must be presented to representatives of the Administrator upon request 

14 CFR §11.81(f) Summary: 

JPMC requests relief to 14 CFR §61.57 (a) General experience wherein it specifies the general experience be conducted within aircraft 

type. The relief requested to the recent flight experience requirements, if granted to JPMC, will reduce the need for conducting local 

training flights as well as provide a reduction to local airspace congestion and noise issues associated with day/night training flights. In 

consideration of the JPMC Conditions and Limitations, JPMC will maintain a demanding set of recent flight experience requirements across 

two substantially similar airplane types. JPMC believes the conditions and limitations imposed on its pilots within this request maintain an 

equivalent level of safety as intended by the rule. 

14 CFR §11.81(g) Additional information: 

JPMC's internal14 CFR §61.58 training requirements are twice as restrictive as the currently legislated FAA requirements. Each JPMC 

pilot is required to successfully complete an approved 142 curriculum for §61.58 every six (6) months while alternating between the G550 

and G650ER Level D FSI simulators, thereby completing a pilot-in-command proficiency check: 

Within the preceding 6 calendar months in an aircraft that is type certificated for more than one required pilot flight crewmember 

or is turbojet-powered; and 

ii. Within the preceding 12 calendar months, completes a pilot-in command proficiency check in the particular type of aircraft in 

which that person will serve as pilot-in-command. 

This additional internal JPMC training requirement will guarantee at a minimum 12 night takeoffs and landings annually in an aircraft that is 

type certificated for more than one required pilot and a minimum of 6 night takeoffs and landings annually in each particular type of aircraft. 

This training combined with the JPMC Conditions and Limitations stated above provide for an equivalent level of safety as intended by the 

rule while eliminating redundant training and expense. 

JPMorgan Chase appreciates and thanks the FAA for its consideration in granting this petitioner relief from 14 CFR §61.57 (a). We look 

forward to the earliest possible disposition in order to realize the values stated herein. 

If there are any questions, or if I can be of further assistance, please do not hesitate to contact John Donofrio at (914)289-4863 or 

john.i.donofrio@jpmchase.com 

Sin~//~ 

J'o~ J "' 

Chief Pilot, VP 

Corporate Aviation 

JPMorgan Chase