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, especial ly 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 o perating 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 o ur 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 reg ard 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, 201 5 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 petiti on, 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 belie ves 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 whi le 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 B ranch, AFS

- 270 (202) 267

- 7959