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

Recentflight experience: Pilot-in-command requirements as applicable to certain Gulfstream Large Cabin Airplanes
DearSiror Madam: Asprovided:in'·14CFR Section

### §11 .81 (b), JPMC herebypetitiohsfor relief from the ruleasdefinedbelowas it appliesto

### theGulfstream G550, G650/G650ER airplanes. In accordance with 14CFR §11 .81 (b)- The specific section(s} from which relief is sought: 14 CFR §61 .57 (a) General experience: (1) Exceptas 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 morethan one pilot flight crewmember unlessthat person has made at leastthree takeoffs and three landingswithin the preceding 90 days and- (i) The person acted asthe sole manipulatorofthe 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)

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14 CFR §11 .81 (c)- Extentand reason forseeking relief: The Gulfstream types, the G550 (G-V), G650ER (GVI), for which relief is sought is based on the extensive similarities ofthe aircraft

structure, systems, avionics, performance and flight characteristics of these airplanes. This relief is sought due to the ultra-long range nature of JPMCflight operations in both aircrafttypes. This results in reduced operational opportunities for accomplishing the required numberoftakeoffs and landings amongstthe JPMC pi!o.t,,Q(O\JP:

**.\~i,s,ex~r:rption**

**i~ r~quested**  to provide limited relieffrom a fundamentally redundant "general experience" reqci]Ye(l'!ent between \wo ?irplai)eitype_s with highlysimilarflight 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
14CFR §11.81 (d)- Public interest! benefit: G556 97x94x26 91,000 6,750 nm .885M 51,000feet 118 KCAS 75,300 2,770 feet Honeywell Primus Epic Planeview (ASC- 911)

## '' B50ER 100x 100x26 99,600 7,000 nm .925M 51,000feet 120 KCAS 83,500 3,000 feet Honeywell Primus Epic PlaneView II

Relief from the current requirements of 14CFR §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 ofthe airspace in and around theJPMC flightdepartment base of operations would benefit by reduced airspace congestion and noise. The general public will also benefitfrom a reduction in aircraft noise by eliminating any additional local airtraffic, currently required as training events, utilized to meetthe operational shortfall ofthe general experienceflight requirements for currency. 14CFR §11.81(e) -Information supporting this petition: The relief sought byJPMC would not compromise the minimum level ofsafety as intended bythe current rule as JPMC will applythe relief onlywithin the context ofthe following JPMC Conditions and Limitations: (1) This exemption applies onlyto JPMorgan Chase Corporate Aviation pilots who hold an FAA issued pilot certificate with atype rating in both the Gulfstream manufactured G550 and G650ER airplanes and onlywhile engaged in flight operations conducted on behalf ofJPMorgan Chase. (2) Each pilot in command (PIC) exercising the privileges of this relief must meet the requirements of §61.57(a) and (b) in atleastone ofthe 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 ofthe 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 forthe takeoff and landing maneuver ii. The takeoffs and landings must be accomplished underthe supervision of simulator instructorwho 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'svisual 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 ofthe preceding 12 calendar months, the pilot must accomplish 120 hours of pilot time, 60 hours of which must be in one of the G550 orG650ER airplanes; or (1) Since the beginning ofthe preceding 6 calendar months, the pilot mustaccomplish 60 hours of pilottime, 30 hours of which must be in one ofthe G550 or G650ER airplanes (5) A copyofthis exemption mustbe provided to each PIC who operates underthe terms ofthis exemption. (6) A copyofthis exemption must be presented to representatives of the Administrator upon request 14 CFR §11.81(f) Summary: JPMC requests relief to 14CFR §61.57 (a) General experience wherein it specifies the general experience be conducted within aircraft type. The relief requested to the recentflight 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/nighttraining flights. In consideration of the JPMC Conditions and Limitations, JPMCwill 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 bythe 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 everysix (6) months while alternating between the G550 and G650ER Level D FSI simulators, therebycompleting a pilot-in-command proficiencycheck: 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 proficiencycheck in the particulartype of aircraft in which that person will serve as pilot-in-command. This additional internal JPMC training requirementwill guarantee at a minimum 12 night takeoffs and landings annually in an aircraftthat is type certificated for more than one required pilot and a minimum of 6 nighttakeoffs and landings annually in each particulartype ofaircraft. 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 relieffrom 14 CFR §61.57 (a). We look forward tothe earliest possible disposition in orderto realize the values stated herein. Ifthere are anyquestions, or if I can be offurther assistance, please do not hesitate to contactJohn Donofrio at (914)289-4863 or john.i.donofrio@jpmchase.com



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# J'o~ J "' Chief Pilot, VP Corporate Aviation JPMorgan Chase