From: Thomas Miller [mailto:thomas.miller@gamaaviation.com] 

Sent: Tuesday, July 14, 2015 3:50 PM

To: Thompson, Mary (FAA)

Cc: Thomas Miller

Subject: RE: Petition for Exemption from 14 CFR Part 135.247

Good afternoon Ms. Thompson:

Thank you for taking the time to review Gama’s Petition on the above captioned 

matter. Gama believes that we would be operating with an enhanced level of 

safety, which would be in the public interest, through the approval of the subject 

petition for the following reasons:

1) Our FAA Approved FAR 135 pilot training program does not require that 

any of our simulator training be conducted in the night environment,

2) The night environment for simulator training is a much more demanding and 

difficult setting to operate an aircraft in, especially when transitioning from 

instrument to visual conditions in the night environment, 

3) The subject petition would require our pilots to successfully complete six (6) 

Takeoffs and six (6) Landings to a full stop in a full motion simulator in the 

night environment every six (6) months as well as maintain standard 90 day 

takeoff and landing currency, 

4) Pilots operating to this standard must have logged at least 1,500 hours of 

aeronautical experience as a pilot,

5) Pilots operating to this standard must have accomplished and logged at least 

15 hours of flight time within the preceding 90 days prior to the operation in 

the type of airplane described in this petition. 

Gama has successfully completed and has been registered as an FAA Level III 

FAA SMS Pilot Program participant. Our current Safety Management System and 

safety culture requires Gama to take advantage of any and all opportunities that 

could mitigate and manage risk. Items 2-5 above are currently not required of our 

air carrier operations and their inclusion would most definitely be a positive 

enhancement to our current level of system safety. Therefore, this enhancement to 

our safety management system would most definitely be in the public interest.

In summation said higher level of safety would be in the public interest and could 

be thought of as an excellent impetus to further define the safety aspects of this 

request/petition. 
Please advise me if you should have any questions or concerns with regard to the 

above statement.

Thank you for your consideration,

Thomas Miller

From: Mary.Thompson@faa.gov [mailto:Mary.Thompson@faa.gov] 

Sent: Tuesday, July 14, 2015 12:11 PM

To: Thomas Miller

Subject: Petition for Exemption from 14 CFR Part 135.247

Dear Mr. Miller:

This email is in follow-up to your January 22, 2015 petition for exemption from Title 14, Code of Federal 

Regulations part 135.247. Through your petition, Gama seeks relief to allow it to meet pilot in command 

recency of experience requirements through compliance with § 135.247 (a)(3)(i) and (ii) in an aircraft 

that is not type certificated for more than one flightcrew member. 

Title 14 CFR § 11.81 (d) states that a petition for exemption must include “the reasons why granting your 

request would be in the public interest; that is, how it would benefit the public as a whole.” In regard to 

public interest, Gama’s petition for exemption states:

“Gama believes that this exemption would permit it to respond to a growing demand for night 

operations and would permit Gama aircraft to be available to the general public which would 

not otherwise be available. To not allow Gama to extend the flexibility offered by the § 135.247 

night currency alternative described in paragraph (a)(3)(i) or (ii) to single pilot certified aircraft 

such as the BE300-B300 would impose an unreasonable burden to this operator. If granted, this 

exemption would be in the public interest while maintaining the desired level of safety.”

In addition to the information provided above regarding Gama’s resource considerations, please provide 

further information on how a grant of exemption would benefit the public as a whole. This will enable us 

to make a clear determination in your petition. 

If you have any questions or would like to discuss, don’t hesitiate to email or call at the number 

provided below.

Thanks,

Mary Thompson

Flight Standards, Air Transportation Division

Policy Integration Branch, AFS-270

(202) 267-7959