05 Dec 13

E-Mailed and FedEx.

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue

SE West Building

Ground Floor

W12-140

Washington, DC 20590

Dear Sirs,

I wish to request an Exemption from FAR 61.58 (a)(2) and will explain in 

accordance with FAR Part 11, Section 81, as noted in the following.

(a) Your name and mailing address and, if you wish, other contact information 

such as fax number, telephone number, or e-mail address.

John P. Lee

1635 Auburn Court

Waukesha, WI 53189

Cert. # 315528579

262.549.0230 Office

262.549.0156 FAX

414.750.6293 Cell

jpl@fabco.com

(b) The specific section or sections of 14 CFR from which you seek an exemption.

FAR 61.58 (a) (2)

(c) The extent of relief you seek; and the reason you seek relief.

Relief from the requirements of FAR 61.58(a)(2) for 24 months due to the fact the 

ONLY training facility in the world has informed me that their training programs; 

FAR 61.58 and FAR Part 142 for the British AeroSpace JetStream 4100 will not 

be able to train any flight crew members. A review of the FAA’s “National 

Resource” currently has no one current and/or qualified in the BA-4100 aircraft.

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(d) The reason why granting your request would be in the public interest; that

is, how would it benefit the public as a whole.

Our company is currently deeply involved with several construction projects 

 throughout the State of Wisconsin and this aircraft is used to ferry the individuals

 concerned to these construction sights. Not being able to use the aircraft would

 not only slow down the completion of these projects; but, may also delay their

 openings at these expansions and may jeopardize or at least delay many of these

 jobs.

(e) The reasons why granting the exemption would not adversely affect safety, or

 how the exemption would provide a level of safety at least equal to that

 provided by the rule from which you seek exemption.

Granting this extension for the time required for the ONLY FAR 142 Training

Facility; SimCom of Orlando FL, to regain certification would not adversely

affect safety due to the fact that I am keeping trained and maintaining proficiently

in two (2) other “Type Specific Aircraft”. Currently operating the Lear Jet 20 & 

30 Series Jet and just returned from training and will be operating the Cessna

Citation III (CE-650), both aircraft training completed at FAR 142 Training 

Facilities. Also operate all company aircraft in accordance with Safety

Management System (SMS) Certificate # 101832A. This Operations Manual

requires; and I comply with, the active implementation of the Safety Management

System (SMS), which is in accordance with ICAO/IBAC, IS-BAO/AFSC/FAACompliant SMS. Operational Manual requires Weight and Balance for each and

every takeoff and landing; computations using Runway Analysis for each and 

every takeoff (Far exceeding the minimum requirements of Part 91 of the 

Regulations); and the use and implementation of the Operations Manual required

Flight Risk Assessment Tool (FRAT) for each and every takeoff and landing. 

Included in the FRAT is the consideration of all aircraft performance issues, 

airport and weather situations with a risk analysis of each takeoff and landing. In 

accordance with the Operations Manual, these leg-by-leg computations are kept 

for two (2) years. This manual exceeds all efficiency and safety requirements.

Use of this off sight requirement and graded evaluations of the operations manual 

rivals that of a licensed dispatcher for each leg of our flight. I will also keep 

trained and proficient using approved FAR 142 Training Facilities in both 

additional “Type Specific Aircraft” throughout the duration of the exemption.

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(f) A summary we can publish in the FEDERAL REGISTER, stating,

(1) The rule from which you seek the exemption, and

(2) A brief description of the nature of the exemption you seek.

Exemption from the requirements of FAR 61.58 (a)(2) as long as there is no 

approved FAR 142 (or similarly FAA Approved) Training Facility in the 

exempted Type Specific Aircraft; provided at least one other approved FAR 142 

(or similarly FAA Approved) Training Facility is used to keep trained, current 

and proficient in an additional Type Specific Aircraft. Completion of training in 

the exempted Type Specific Aircraft will be completed immediately upon 

recertification of the FAR 142 (or similarly FAA Approved) Training Facility.

(g) Any additional information, views or arguments available to support your

request;

The world’s ONLY previously FAA FAR Part 142 approved source of training

for use under FAR Parts 61 and 91 in the British AeroSpace 4100 Series aircraft

has been SimCom of Orlando, FL. They have been informing me that they have

been working on regaining FAA recertification in this type specific aircraft. They

have been regaining certifications from the FAA on their other type specific

aircraft at their training facility. The only actual fact that I can verify is that on

the afternoon of 04 Dec 13, SimCom informed me that they were NOT going to

be able to complete the FAA requirements for the recertification of either their

FAR 142 Training Program in the BA-4100 or their FAR 61.58 Approved

Training Program in the BA-4100. This situation it totally out of my control and

I have; on several past occasions, volunteered my services and/or aircraft in an

effort to assist them in the recertification process. In years past, I have allowed 

their past Training Center Evaluator (TCE); Mr. Andy Reeves, to come to my

location and actually fly my aircraft on each leg of the days activities, to satisfy an 

apparently new regulation in FAR 142. 

My due date for the currency under FAR Part 61.58 (a)(2) in the British 

AeroSpace 4100 Series Aircraft is the month of December, 2013 and am presently 

current in two other Type Specific Aircraft; Lear Jet 20, 30 & 50 Series and 

Cessna Citation 650 Series, both training under FAR Part 142, thru December of 

2014. I am only requesting relief on one aircraft; the British AeroSpace 4100 

Series for 24 months or immediately re-qualify upon recertification of their FAR 

142 Training Syllabus.

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(h) If you want to exercise the privileges of your exemption outside the United

States, the reason why you need to do so.

Would also request approval to include operations in the Bahamas.

Regards,

John P. Lee

Certificate #315528579

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