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. 9727 C

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 po werplant 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, an d again on May 9, 2014, and will expi re 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 a irframe and powerplant mechanics who w ant to become flight engineers

“ at least 5 hours of flight training in th e 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), an d 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 attache d 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 permit s Amerij et 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
moder n 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 class room. 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 resu lting 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 trainin g 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 t rain, Amerijet's use of simulators also permit s the carrier to benefit economically, another relevant public
inte rest factor. First, Amerijet benefit s through the more economical use of its capital expenditures. Every hour an aircraft flies, its useful lif e 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 th e tra inee 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

w hen compared to the cost of actual aircraft flight time.

According to the public interest standard governing the issuance of an exemption, the FAA also
consider s 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 con sume 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 t o 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 o f 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. E ach2800 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 th rough 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. Indee d, as noted, it is very likely that public safety has been

e nhanced 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 engine er 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 anticip ated 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 i n fact, safety has been enhanced, and it will continue t o 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 pilo ts holding a commercial pilot certificate with an
instrument r ating, and any delay in acting on this petition would be detrimental to the public and Amerijet.

Da ted: March 30, 2016

Respectfully submitted

,

/s/ Joan Canny

Joan Canny General Counsel Amerijet International, Inc.