Exemption No. 17157

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

 

In the matter of the petition of 

 

AMERIFLIGHT LLC Regulatory Docket No. FAA-2014-0278

 

for an exemption from § 135.243

of Title 14, Code of 

Federal Regulations 

 

FULL GRANT OF EXEMPTION

 By letter dated April 23, 2014, Mr. Andrew Lotter, President, Ameriflight, LLC 

(Ameriflight), 4700 Empire Ave., Hangar 1, Burbank, CA, 91505 petitioned the Federal 

Aviation Administration (FAA) on behalf of Ameriflight for an exemption from 

§ 135.243(c)(2) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, 

if granted, would allow an Ameriflight pilot to qualify as a pilot in command (PIC) of an 

airplane under Instrument Flight Rules (IFR) with reduced flight time while engaged in cargoonly part 135 operations in a propeller-powered airplane, which does not require a type rating. 

The petitioner requests relief from the following regulation:

Section 135.243(c)(2) states,

except as provided in paragraph (a) of this section, no certificate holder may use a person, nor 

may any person serve, as pilot in command of an aircraft under IFR unless that person - has 

had at least 1,200 hours of flight time as a pilot, including 500 hours of cross country flight 

time, 100 hours of night flight time, and 75 hours of actual or simulated instrument time at 

least 50 hours of which were in actual flight.

The petitioner supports its request with the following information:
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The petitioner seeks a reduction in the hours required to serve as a PIC in part 135 cargo-only 

IFR operations from 1, 200 to 1,000. The petitioner states that a grant of the petition would 

allow it to tap into the much larger supply of pilots who have at least 1,000 hours total time. 

The petitioner states that a 2010 study by Aviation Accreditation Board International (AABI) 

followed 2,156 new hire pilots. The petitioner states that board determined that those between 

500 and 1,000 hours total flight time had the fewest "additional training" requirements, fewer 

incompletes, and in general, better overall performance than, for example, the group with 

1,500 hours total time. The petitioner claims that based upon this study, it would be putting 

pilots into the air carrier operational environment at the peak of their performance and 

receptiveness to training and expanded responsibilities.

The petitioner asserts that it would maintain a level of safety equivalent to the regulation 

because pilots operating under the exemption will complete additional training, checking, and 

mentoring. The petitioner proposes the following limitations, if this exemption is granted:

1. PICs would be required to have at least 1,000 hours of total flight time, including 400 

hours of cross country flight time, 80 hours of night flight time, and 70 hours of actual 

or simulated instrument time at least 40 hours of which were in flight in airplanes.

2. Types of instrument approaches for which the PIC qualified in accordance with 

§ 135.297 and Ameriflight operations specifications would be approved, except night 

circling approaches would not be authorized.

3. Enroute and terminal area IFR operations would be authorized only if approved 

weather reports, forecasts, or any combination thereof indicate that instrument 

meteorological conditions (IMC) would not be encountered within 1,000 feet above 

the departure or arrival airport field elevation.

4. In the event that unforecast IMC below the limits in paragraph 3 above is encountered 

on approach, the flight would proceed to an alternate or return to the previous airport.

5. IFR alternate airports would be required to be forecast to have a minimum of 1,000 

foot ceiling (or no ceiling) and three miles visibility for the estimated time of arrival 

(ETA) at the alternate, or the minimum as provided in part 135 and the Ameriflight 

operations specifications, whichever is more restrictive.

The petitioner proposes that for pilots approaching the 1,000 hour threshold beyond which 

IFR flying would be authorized, if this exemption is granted, Ameriflight intends to provide 

the following additional training to further ensure a level of safety at least equal to that 

provided by § 135.243(c)(2): 
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1. Pilots would complete Ameriflight's FAA-approved Second in Command (SIC) 

training and checking program, which includes instrument procedures training, and 

airplane make-and-model-specific ground and "simulator" training as indicated below.

2. Pilots would undergo a minimum of 15 hours of training in an Ameriflight flight 

training device (FTD) make-and-model specific to the airplane in which pilot will 

serve as SIC, followed by in-flight training to proficiency.

3. Following satisfactory completion of an SIC checkride with an Ameriflight FAAdesignated Check Captain, the petitioner states that the pilot would complete 50 hours 

of SIC time in the Ameriflight airplane type for which the pilot was trained.

4. After completing the SIC experience requirement above, additional FTD and inflight 

training-to-proficiency as required in preparation for a PIC checkride.

5. Satisfactory completion of a full §135.293-297-299 check by either a FAA designated 

Ameriflight Check Captain or FAA Inspector, with no elements waived.

6. After passing the PIC checkride, pilots would accumulate a minimum of 10 hours 

Initial Operating Experience (IOE) as acting PIC in the aircraft in which they will 

serve as PIC, under the supervision of an Ameriflight Training Captain. 

7. Pilots would be mentored by an Ameriflight training captain during the first 50 hours 

of operation under this exemption.
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8. Additional §135.297 Line Checks by an Ameriflight FAA-designated Check Captain 

in the second and fourth month after qualifying as IFR PIC under this exemption to 

ensure performance is up to standard.

9. These pilots will also be subject to unannounced line checks by Ameriflight Check or 

Training Captains.

10. Until the pilot has reached all § 135.243(c)(2) experience requirements, a full 

§ 135.293-297-299 check by either an FAA-designated Ameriflight Check Captain or 

FAA Inspector, with no elements waived, will be conducted at six-month intervals 

[grace periods per § 135.301(a) allowed]. 

11. The requirements above would also apply to any other aircraft type into which the pilot 

transitioned, until all § 135.243(c)(2) prerequisites were met.

12. Unsatisfactory performance by a pilot operating under this exemption on any of the 

checkrides specified above would result in review by the Chief Pilot (CP) and Director 

of Operations, and at their discretion, either assignment of additional training followed 

by a full § 135.293-297-299 check by either an FAA-designated Ameriflight Check 

Captain or FAA Inspector, with no elements waived, or removal from assignment as 

PIC.

The petitioner also proposes to continuously measure the effectiveness of the program that 

would be authorized, if this exemption is granted, through additional monitoring as follows:

1. The IOE captain will provide a report of individual pilot performance during IOE to be 

reviewed by the CP and Director of Training (DT).

2. Outcomes of the § 135.293-297-299 checks to be reviewed by the CP and DT.

3. Outcomes of the § 135.299 line checks at the second and fourth month after initial PIC 

qualification, to be reviewed by the CP and DT.

4. Results of unannounced line checks will be reviewed by the CP and DT.

5. These results will be discussed on a monthly basis (or at other mutually-acceptable 

intervals) with Ameriflight’s Principal Operations Inspector (POI) and any adjustments 

to the training and checking protocols made as necessary.

The petitioner believes that any additional risk resulting from the approximately 20 percent 

reduction in flight hours proposed in the petition will be mitigated or eliminated as follows:

 The 2010 study by AABI indicates that pilots are reaching their “peak of performance” 

at 1,000 hours total time, so the petitioner is introducing these pilots to part 135 PIC 

responsibilities at an optimum point in their careers. 
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 The extra training, mentoring, monitoring, and checking in this program will act to 

offset any additional risk associated with the slight reduction in minimum flight hour 

requirements.

 Specific provisions are included to remove pilots from the program who do not 

continue to meet the performance requirements.

The petitioner believes that this additional training, monitoring, checking, and mentoring

exceeds current part 135 requirements in scope and specificity and will achieve and maintain a 

level of safety equal to or greater than that required by the current regulations. The petitioner 

also stated the exemption would only apply to “relatively simple, lower-speed, lessdemanding aircraft.”

The petitioner states that pilots whose VFR line flying experience begins at 500 hours, who 

then move to controlled IFR line operations at 1,000 hours, arrive at the 1,200 hour 

unrestricted threshold more thoroughly seasoned, with broader experience, and consequently 

better prepared to transition into larger, faster, more complex and demanding type-rated 

aircraft – resulting in a safer better qualified pilot at the point where the pilot qualifies for 

unrestricted part 135 operations.

The petitioner states a significant shortage of qualified pilots has developed in the United 

States, and the effects are being felt from the regional airline industry downward. In recent 

months, the petitioner states they have not been able to fill pilot training classes. The 

petitioner states that the inability to fill classes, combined with recent acceleration in attrition 

of their current pilot group toward jobs flying jets, has left the petitioner so short of pilots that 

they have to assign management pilots to regular trips, charter flights to other carriers, and, 

fail service for their contract customers, which include UPS, FedEx, and DHL.

The petitioner believes the grant of this petitions is in the public interest because it would fill 

the pilot supply pipeline with more mature aviators. The petitioner believes these pilots will 

enter passenger airline operations with experience that would satisfy the objectives of Public 

Law 111-216. The petitioner also believes this petition is in the public interest because it will 

allow Ameriflight to continue to provide express delivery freight to smaller communities in 

the United States, including pharmaceuticals, medical laboratory samples, high transport 

index limited half-life radionuclides used for cancer diagnosis and therapy and other high 

priority freight.

A summary of this petition was published in the Federal Register on August 18, 2015. No 

comments were received.

The FAA’s analysis is as follows:

The petitioner supports its request for reduction in flight hours by citing the 2010 Pilot Source 

Study by AABI and states the study indicates that pilots are reaching their “peak of 

performance” at 1,000 hours total time. The FAA notes that the third phase of the Pilot Source 
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Study in 2012 indicates that pilots with 1,001-1,500 total flight hours had more completions in 

training than any other group, including the group with 500–1,000 total flight hours. 

Considering the findings of the third phase of the study, the FAA supports reducing the 

minimum total flight time to 1,000 hours provided the additional conditions and limitations 

outlined herein are met. 

The FAA also notes that the Pilot Source Study only examined total flight hours and not the 

other specific categories of flight time, such as cross-country time, night time, and instrument 

time. Since the Pilot Source Study only examined total flight hours, the FAA is not persuaded 

that a reduction in cross country time, night time, or instrument time is appropriate because 

the FAA believes that these specific categories represent quality flight time that provides 

critical experience before serving as PIC in part 135 IFR operations. (See condition and 

limitation number 2.) 

The petitioner proposed that PICs operating under this exemption be authorized to conduct 

enroute and terminal area IFR operations if approved weather reports, forecasts, or any 

combination thereof indicate that IMC will not be encountered within 1,000 feet above the 

departure or arrival airport field elevation.1In most situations, this would preclude the PIC 

from operating in low IFR during departure and arrival.2The FAA agrees that it is appropriate 

to limit these pilots from operating in low IFR during departure and arrival. However, to 

achieve that objective, the FAA determined more specific weather restrictions are necessary. 

Due to obstacles and terrain, the lowest applicable approach minima at a particular airport 

may be equal to or greater than 1,000 feet above the airport field elevation. Therefore, the 

FAA believes the ceiling requirement for pilots operating under this exemption must be at 

least 1,000 feet above the airport elevation or 500 feet above the lowest applicable approach 

minima for the airport, whichever is higher. Additionally, a minimum visibility requirement of 

3 miles or 1⁄2 mile greater than the lowest applicable approach minima for the airport, 

whichever is higher, is appropriate. Further, the FAA believes risk assessment and mitigation 

must be conducted for operations in known or forecast icing conditions. (See condition and 

limitation numbers 11, 12 and 13.)

The petitioner proposed that before operating under this exemption, pilots would accumulate a 

minimum of 10 hours of IOE as acting PIC under the supervision of an Ameriflight training 

captain. However, the term “training captain” is not used in part 135, and the petitioner did 

not specify the minimum requirements for a person to serve as a training captain. Therefore, 

the FAA determined it is necessary for the person supervising the operating experience to be a 

check pilot (aircraft) who meets the applicable requirements of §§ 135.337 and 135.339. (See 

condition and limitation number 3.)

 

1

IMC is not defined in 14 CFR; however the Pilot/Controller Glossary in the FAA Aeronautical Information 

Manual (AIM) defines IMC as meteorological conditions less than the minima for conducting flight under visual 

flight rules (VFR). The weather minimums for flight under VFR are specified in 14 CFR § 91.155 and vary 

depending on altitude and class of airspace. (AIM dated April 4, 2014)

2 The FAA AIM, Chapter 7, paragraph 7-1-7 defines low IFR as a ceiling of less than 500 feet and/or visibility 

less than 1 mile. (AIM dated April 4, 2014)
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The petitioner proposed that pilots operating under this exemption receive mentoring by an 

Ameriflight training captain during the first 50 hours of operation under the exemption. The 

petitioner did not specify the minimum requirements for a mentor training captain. For 

mentoring to be effective, the FAA believes that the mentor must have a minimum level of 

experience and knowledge of Ameriflight operations. Therefore, the FAA has determined that 

to serve as a mentor, a person must have been fully qualified to serve as PIC during IFR 

operations, including all requirements of § 135.243(c)(2), for Ameriflight for at least the 

previous 6 calendar months. Further, whenever possible, the mentor should be a PIC on the 

same airplane type as the protégé. Additionally, the FAA has determined that the mentoring 

timeframe should not be based on flight hours alone. A PIC must participate in the 

Mentorship Program for at least the first 50 hours operating under this exemption. However, 

some PICs may benefit from additional mentoring. Therefore, the protégé must continue in the 

Mentorship Program until the DT, mentor, and protégé all agree that the PIC is prepared to 

operate without daily briefings with the mentor. This may require the protégé to remain in the 

Mentorship Program beyond the first 50 flight hours. (See condition and limitation number 8.)

The petitioner proposed specific procedures to continuously measure the effectiveness of the 

training, checking, and mentoring for pilots operating under this exemption. The procedures 

included review of the results of the proposed testing and checking and the reports provided 

by the check pilots supervising OE by the CP and DT. The petitioner also proposed that these 

results would be discussed with Ameriflight’s POI on a monthly basis and adjustments to the 

training and checking made as necessary. The FAA agrees with the proposed procedures with 

some modifications. The petitioner proposed that the pilots operating under this exemption 

would be subject to unannounced line checks. The FAA agrees that unannounced line checks 

would provide valuable data; therefore the FAA has determined that it is appropriate to 

require a minimum number of unannounced line checks be conducted by the petitioner every 

6 months. The FAA believes reports from the mentors are also a valuable component to 

measure the effectiveness of the training and checking for these pilots. Therefore, FAA has 

determined that the mentors must submit weekly reports on the progress of the protégés. The 

mentor reports and the results of the unannounced line checks must also be reviewed by the 

CP and DT and de-identified summaries provided to the POI on a monthly basis. (See 

condition and limitation numbers 6, 7, 8, 9, and 10.) 

The FAA has also determined that to ensure understanding and correct application of this 

exemption, Ameriflight must include procedures for operating under this exemption in its 

manual and all affected PICs, check pilots, and mentors must be trained on the conditions and 

limitations of this exemption. (See condition and limitation numbers 14, 15, 16, and 17). 

In summary, the FAA agrees that quality integrated training, checking, and mentoring can 

provide a safety benefit that may not be obtained by simply meeting a flight time requirement 

alone. Therefore, the FAA agrees that an equivalent level of safety can be maintained in part 

135 cargo-only operations in propeller-powered airplanes that do not require a type rating if 

the PIC has at least 1,000 hours total time, completes additional training, checking, and 
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mentoring, and is restricted to IFR operations with higher minimum weather requirements for 

departure and arrival. In addition, the FAA finds that the safety benefit provided by this 

quality training, checking, and mentoring is in the public interest. (See condition and 

limitation numbers 2, 4, 5, and 18.)

The FAA’s Decision

In consideration of the foregoing, I find that a full grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, 

delegated to me by the Administrator, Ameriflight and pilots employed by Ameriflight are 

granted an exemption from 14 CFR § 135.243(c)(2) to the extent necessary to allow an 

Ameriflight pilot to qualify as a Pilot In Command (PIC) of an aircraft under Instrument 

Flight Rules (IFR) with reduced flight time while engaged in cargo-only operations under 14 

CFR part 135, subject to the conditions and limitations listed below.

Conditions and Limitations

1. This exemption may only be used during part 135 cargo-only operations in 

propeller-powered airplanes that do not require a type rating.

2. The PIC must have at least 1,000 hours total flight time, including at least 500 

hours of cross country flight time, 100 hours of night flight time, and 75 hours of 

actual or simulated instrument time of which at least 50 hours were acquired in 

actual flight in airplanes. 

3. The PIC must have previously completed the following:

a. Satisfactory completion of an Ameriflight approved second in command 

(SIC) training curriculum, including at least 15 hours in an Ameriflight 

flight training device (FTD) that is make-and-model specific to the airplane 

in which pilot will serve as SIC, followed by in-flight training to 

proficiency. 

b. Satisfactory completion of the testing requirements specified in § 135.293 as 

an SIC. 

c. At least 50 hours of SIC flight time in the airplane type for which the pilot 

was trained and tested. 

d. Satisfactory completion of an Ameriflight approved PIC training 

curriculum, including training in an FTD that is make-and-model specific to 

the airplane in which pilot will serve as PIC, followed by in-flight training 

to proficiency.
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e. Satisfactory completion of the testing requirements specified in § 135.293, 

the instrument proficiency check requirements specified in § 135.297, and 

the line check requirements specified in § 135.299 as a PIC. No maneuvers 

or procedures may be waived during the conduct of these tests and checks.

f. At least 10 flight hours of operating experience (OE) during IFR operations 

acting as PIC, in the airplane in which the pilot will serve as PIC, under the 

supervision of a check pilot (aircraft) who meets the applicable requirements 

of §§ 135.337 and 135.339.

4. The PIC must satisfactorily complete two additional § 135.299 line checks. The 

first additional line check must be completed 30 to 60 days after completion of the 

OE required by paragraph 3.f. The second additional line check must be completed 

90 to 120 days after completion of the OE required by paragraph 3.f. These checks 

must be conducted during IFR operations by a check pilot (aircraft) who meets the 

applicable requirements of § 135.337 and § 135.339. The FAA will not provide 

inspectors to conduct these additional checks.

5. The PIC must satisfactorily complete the testing requirements specified in 

§ 135.293, the instrument proficiency check requirements specified in § 135.297, 

and the line check requirements specified in § 135.299 as a PIC every 6 calendar 

months (§ 135.301(a) provisions apply). No maneuvers or procedures may be 

waived during the conduct of these tests and checks.

6. All PICs operating under this exemption are subject to unannounced § 135.299 line 

checks conducted by a check pilot (aircraft) who meets the applicable requirements 

of §§ 135.337 and 135.339. Ameriflight must conduct unannounced line checks of 

at least 10% of the pilots operating under this exemption every 6 calendar months. 

7. The check pilot(s) who supervise the OE required by paragraph 3.f. must submit a 

report of the PIC’s performance to the Chief Pilot (CP) and Director of Training 

(DT).

8. After completing the OE required by paragraph 3.f., the PIC must participate in the 

Ameriflight Mentorship Program for at least the first 50 flight hours operating 

under this exemption. The minimum requirements for the Mentorship Program are 

as follows:

a. Mentors must be designated by Ameriflight. To serve as a mentor, a pilot 

must have been fully qualified to serve as PIC during IFR operations, 

including all requirements of § 135.243(c)(2), for Ameriflight for at least the 

previous 6 calendar months. Whenever possible, the mentor should be a PIC 

on the same airplane type as the protégé.
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b. Prior to the first flight of the day, the Mentor and the protégé must conduct a 

briefing including personal preparedness, all known weather factors, airport 

factors, equipment factors, and active and latent threats to the flights the 

protégé is assigned that day. The Mentor must also discuss with the protégé 

strategies to determine the appropriate course of action in the event of 

unanticipated events, such as unforecast weather, mechanical difficulties, or 

changes to the assigned flights. This briefing is duty with Ameriflight and 

must be included in duty period for the Mentor and the protégé and may not 

be conducted during a required rest period.

c. After the last flight of the day, the Mentor and protégé must conduct another 

briefing to discuss the outcome of the flights, unanticipated events and 

protégés actions as a result, and any questions or concerns. This briefing is 

duty with Ameriflight and must be included in the duty period for the 

Mentor and the protégé and may not be conducted during a required rest 

period. If this briefing cannot be completed after the last flight of the day 

due to duty period or rest limitations, it must be completed before the 

protégé’s next flight.

d. Mentors must submit a weekly report to the DT regarding the protégé’s 

progress. 

e. The protégé must continue in the Mentorship Program until the mentor, 

protégé and the DT agree that the protégé is prepared to operate without 

daily briefings with the mentor. This may require the protégé to remain in 

the Mentorship Program beyond the first 50 flight hours.

9. The CP and DT must review the results of the testing and checking specified in this 

exemption, the reports provided by the check pilots supervising OE, and the reports 

provided by the mentors. For any unsatisfactory performance, the CP and DT must 

determine whether to give the pilot additional training followed by the required 

checks or remove the pilot from assignment as a PIC.

10. Ameriflight must submit de-identified summaries of (1) the results of the testing 

and checking specified in this exemption, (2) the reports provided by the check 

pilots supervising OE, and (3) the reports provided by the mentors to the 

Ameriflight Principal Operations Inspector (POI) at least monthly. If the 

de-identified summaries indicate insufficient training, testing, checking, or 

mentoring of pilots operating under this exemption, Ameriflight must make 

amendments to improve the training, testing, checking, or mentoring, as 

appropriate.

11. Enroute and terminal area IFR operations may only be conducted under the 

following weather requirements:
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a. The approved weather report when takeoff commences indicates a ceiling of 

at least a 1,000 feet above the departure airport elevation or 500 feet above 

the lowest applicable approach minima for the departure airport, whichever 

is higher, and a visibility of at least 3 statute miles or 1⁄2 mile greater than the 

lowest applicable approach minima for the departure airport, whichever is 

higher. 

b. Approved weather reports, forecasts, or any combination thereof indicates 

that at the estimated time of arrival, the ceiling will be at least 1,000 feet 

above the arrival airport elevation or 500 feet above the lowest applicable 

approach minima for the arrival airport, whichever is higher, and the 

visibility will be at least 3 statute miles or 1⁄2 mile greater than the lowest 

applicable approach minima for the arrival airport, whichever is higher. 

c. The pilot may only begin and continue an instrument approach at the arrival 

airport if the approved weather report indicates the ceiling is at least 1,000 

feet above the airport elevation or 500 feet above the lowest applicable 

approach minima, whichever is higher, and the visibility is at least 3 statute 

miles or 1⁄2 mile greater than the lowest applicable approach minima for the 

airport, whichever is higher.

d. The pilot may not conduct circling approaches at night. 

e. If an alternate airport is required in accordance with § 135.223, then an 

airport may only be designated as the alternate airport if approved weather 

reports, forecasts, or any combination thereof indicates that at the estimated 

time of arrival, the ceiling will be at least 1,000 feet above the alternate 

airport elevation or 500 feet above the lowest applicable approach minima 

for the alternate airport, whichever is higher, and the visibility will be at 

least 3 statute miles or 1⁄2 mile greater than the lowest applicable approach 

minima for the alternate airport, whichever is higher.

12. Ameriflight must submit a report detailing all instances during which unforecast 

weather required a pilot to conduct an instrument approach at the alternate airport 

below the weather minimums specified in paragraph 11.e, including the 

circumstances surrounding each event, to the Ameriflight POI at least monthly. If 

the report indicates insufficient flight planning, Ameriflight must make 

amendments to the flight planning policies or procedures to improve the flight 

planning.

13. Prior to utilizing this exemption, Ameriflight must develop procedures for risk 

assessment and mitigation for operations in known or forecast icing conditions. 

These procedures must be approved by the FAA Principal Operations Inspector 

assigned to Ameriflight.
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14. Ameriflight must include procedures for operating under this exemption in the 

manual required by § 135.21.

15. The approved PIC training curriculum, for PICs who will operate under this 

exemption, must include ground training on the conditions and limitations of this 

exemption and the Ameriflight Mentorship Program.

16. Check pilots who will supervise OE or conduct tests or checks of PICs who will 

operate under this exemption must complete the approved check pilot training 

curriculum, which must include ground training on the conditions and limitations of 

this exemption. 

17. Prior to serving as a mentor, Ameriflight must provide ground training to mentors

on the Ameriflight Mentorship Program and the conditions and limitations of this 

exemption, with emphasis on the weather requirements specified in paragraphs 11 

and 13. 

18. Each § 135.293(a) written or oral test for a PIC who will operate under this 

exemption, must include testing on the pilot’s knowledge of the weather 

requirements specified in paragraph 11.

19. Ameriflight must maintain, at the principal base of operations (or location agreed to 

by the POI), a current list of PICs operating flights under this exemption.

20. This exemption may only be used in operations conducted entirely within the 

United States. 

This exemption terminates on December 31, 2018, unless sooner superseded or rescinded.

Issued in Washington, D.C., on 28 November, 2016.

/s/

John S. Duncan

Director, Flight Standards Service

.