2800 S. Andrews Avenue, Ft. Lauderdale, FL 33316 Phone: 954.320.5367 Fax: 305.423.3246 Email: jcanny@amerijet.com

UNITED STATES DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C. 20591

___________________________________

)

In the matter of the petition of ) 

) Exemption No. 9727

AMERIJET INTERNATIONAL, INC. )

) Regulatory Docket No. FAA-2007-29293

For an exemption from § 63.37(b)(1) )

And (2) and part 63 of ) March 30, 2016

Appendix C(a)(3)(iv)(a) of CFR Title 14 )

___________________________________) 

Petition for Extension of Exemption No. 9727C

Amerijet respectfully submits this petition to renew Exemption No. 9727 as amended, which 

granted an exemption from 14 Part 63.37(b) (1) and Appendix C to Part 63, to the extent necessary to 

allow it to continue to be permitted to train its airframe and powerplant mechanics under a program that 

allows it to satisfy all of the flight time requirement by reliance upon a Level C or D simulator. 

Exemption No. 9727 was first granted to Amerijet on July 19, 2008. It was renewed on April 29, 2010, 

May 16, 2012, and again on May 9, 2014, and will expire by its terms on July 31, 2016. 

Amerijet is a supplemental scheduled all-cargo air carrier providing service within the United 

States and between points in the United States and points outside the United States. It has been issued 

exemptions and certificates by the Department of Transportation authorizing these operations, and it 

conducts its business as a corporation in good standing under the laws of the State of Florida and in 

accordance with Part 121 of Title 14 of the Code of Federal Regulations. In support of its petition to 

renew, Amerijet submits the following evidence and argument:

In the absence of Exemption No. 9727, Amerijet would be required by Part 63 to include as part 

of its training program for its airframe and powerplant mechanics who want to become flight engineers 

“at least 5 hours of flight training in the duties of a flight engineer.” See Sections 63.37(b)(1), 63.37(b)(7) 

and Appendix C to Part 63, specifically paragraph (a)(3)(iv)(a)and (b), and that “flight training” would 

have to be conducted on an actual flight.

After the exemption was originally granted, Amerijet has performed its flight engineer training in 

accordance with Exemption No. 9727 where necessary, including the conditions attached thereto. Based 

on that experience, Amerijet is convinced that it is prudent for Amerijet to request FAA to issue this 

exemption and that FAA would act fully in accordance with the public interest in granting Amerijet's 

request. 
2800 S. Andrews Avenue, Ft. Lauderdale, FL 33316 Phone: 954.320.5367 Fax: 305.423.3246 Email: jcanny@amerijet.com

First, safety is enhanced and serious operational risks are eliminated through the effects of the 

exemption. Since one of the obvious benefits of simulator training as an alternative to actual operations is 

the elimination of operational risks, the exemption permits Amerijet to realize that benefit. In addition, the 

quality of Amerijet's training of its engineer candidates is significantly enhanced through reliance on a 

simulator compared to the training he or she would otherwise receive. One of the characteristics of 

modern simulation training is that simulation permits the trainee to experience and learn from a far wider 

range of operational situations than can possibly be taught using an operating aircraft in actual flight. An 

operating aircraft is simply not a good classroom. Only a limited number of experiences can be shared 

during actual flight, and it is altogether too unsafe to push the training envelope very far using an 

operating aircraft. These limitations are eliminated with modern simulator training, and the resulting 

training experience is significantly enhanced. As the FAA has recognized often, the quality and 

sophistication of simulator training has improved markedly since Exemption No. 9727 was first issued; 

accordingly, the added benefit of simulator training over actual flight training has been enhanced beyond 

what was contemplated when Amerijet first sought the exemption making renewal of the exemption even 

more compelling.

While providing a superior educational experience to those individuals it wants to train, 

Amerijet's use of simulators also permits the carrier to benefit economically, another relevant public 

interest factor. First, Amerijet benefits through the more economical use of its capital expenditures. Every 

hour an aircraft flies, its useful life is reduced, and part of the acquisition investment is expended. To the 

extent those flight hours are unnecessarily devoted to training time rather than the production of revenue, 

the capital cost of the aircraft is wasted, and the carrier suffers. On the other hand, the cost of modern 

simulators is far lower than the cost of an aircraft, making simulator training an economic benefit to the 

carrier. This remains a benefit going forward if this petition for renewal of the exemption is granted.

The economic benefit to Amerijet goes well beyond capital costs. As Amerijet contended in its 

original petition, for each hour of the five hours of flight training now required by Part 63, the air carrier 

must absorb the cost of the captain and copilot who accompany the trainee on the operating aircraft, the 

substantial fuel cost involved, and the periodic aircraft maintenance expenditure attributable to that flight 

time without earning any offsetting revenues. The operational cost involved in using a simulator pales 

when compared to the cost of actual aircraft flight time.

According to the public interest standard governing the issuance of an exemption, the FAA also 

considers the environmental benefits that are realized from using a training simulator and relieving the

carrier of the obligation to purchase and consume aviation fuel during the more than five hours of flight 

training otherwise required by Section 63. At the time it prepared its petition, Amerijet calculated that one 

of its jet transport aircraft would consume over 50,000 pounds of fossil fuel to train one flight engineer. 

At this rate, Amerijet anticipated that it could burn, with minimal training requirements, over a million 

pounds of fuel just to train its flight engineers in one year, a use equivalent to flying an Amerijet 727 

around the world--twice. These environmental benefits would be expected to continue under the extension 

of the exemption.

Another public interest benefit Amerijet anticipated and which would continue in the event of the 

extension of the exemption is the elimination of the unnecessary use of crowded air space by a training 

aircraft and the resulting reduction in the burden on the already burdened air traffic control system. Each 
2800 S. Andrews Avenue, Ft. Lauderdale, FL 33316 Phone: 954.320.5367 Fax: 305.423.3246 Email: jcanny@amerijet.com

time the FAA is able to reduce the use of the system through the elimination of an unnecessary operation,

the system benefits and FAA's operating costs decline.

Finally, Amerijet is also convinced that, as it anticipated, approval of the exemption has had and 

will have no adverse effect on public safety. Indeed, as noted, it is very likely that public safety has been 

enhanced by approval of Amerijet’s petition. Moreover, high public safety standards have been

maintained because following certification, flight engineers continue to be required under Part 121 to 

obtain operating experience under the supervision of a check engineer or other properly appointed flight 

engineer to insure that the training the trainee received satisfies the highest standards. As a condition to 

the exemption requested, the flight engineer trainee, after completing simulator training, was to be and 

has been issued a restricted certificate containing conditions which may be satisfied only following 

completion of a period of actual flight experience. In addition, the FAA has further assured that approval 

of Amerijet’s petition would not result in the degradation of safety standards through the imposition of 

several conditions which Amerijet accepted and with which it has complied.

In summary, all the positive benefits Amerijet anticipated when it sought Exemption No. 9727 

have been realized and there have been no deleterious consequences resulting from FAA grant of the 

exemption. That action by the FAA was clearly consistent with the public interest and continues to be 

consistent with the public interest, and so for the same reasons that FAA granted the exemption, FAA 

should act to permit the exemption to continue in effect. Safety has not been and it will not be 

compromised, and in fact, safety has been enhanced, and it will continue to be enhanced. For all these 

reasons, Amerijet respectfully requests that its petition for renewal and extension of Exemption No.9727, 

as amended, be approved.

To the extent necessary, Amerijet also requests that the FAA waive the requirement for Federal 

Register publication because the exemption, if continued in effect, will not set a precedent in the sense 

that no training reductions are contemplated by the exemption, only a substitution of training method 

comparable to that already in existence for pilots holding a commercial pilot certificate with an 

instrument rating, and any delay in acting on this petition would be detrimental to the public and 

Amerijet.

Dated: March 30, 2016

Respectfully submitted,

/s/ Joan Canny

Joan Canny

General Counsel

Amerijet International, Inc.