**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 expla in 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. L ee 1635 Auburn Court Waukesha, WI53189 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; a**  **nd 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 JetStre am 4100 will not be able to train an y 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 compan y is currently deepl y involved with several construction projects throughout the State of Wisconsin and thi s aircraft is used to ferry the individuals concerned to the se constr uction sights. Not being able to use the aircraft would not only slow down the completion of these projects ; but, may also delay their opening s at these expansions and may jeopardize or at least delay man y of these jobs

. **(e) The reasons wh**  **y 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 Facilit y; 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 “ T yp e Specific A ircraft”. Currently operating the L ear Jet 20 & 30 Series Jet and just returned from training and will be operati n g the Cessna Citation III (CE

- 650) , both aircraft training completed at FAR 142 Training Facilities . Also operate all company aircraft in accordance with Safet y Management S ys t em (SMS) Certificate # 101832A. This Operations Manual requires; and I compl y with, the active implementation of the Safet y Management Sy stem (SMS), which is in accordance with I CAO/IBAC, IS

- BAO/AFSC/FAA

Compliant SMS. Operational Manual requires Weight and Balance for e ach and every take off and landing ; computations using Runway Anal ys is 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. In cluded in the FRAT is the consideration of all aircraft performance issues, airport and weather situations with a risk analy sis of each takeoff and landing. In accordance with the O perations Manual, these leg

- by

- leg computations are kept for two (2) ye ars. T his manual exceeds all efficiency and safet y 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 “Ty

pe 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 r equirements of FAR 61.58 (a)(2) as long as there is no ap proved FAR 142 (or similarly FAA Approved) Training Facili ty in the exempted Ty

pe Specific Aircraft; provided at least one other approved FAR 142 (or similarly

FAA Approved) Training Facilit y is used to keep trained, current and proficient in an additional Ty pe Specific Aircraft. Completion of training in the exe mpted Ty

pe 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 inform ing me that they have been working on regaining FAA recertification in this ty p e specific aircraft. They have been regaining certifications from the FAA on their other ty pe specific aircraft at their training facility . The onl y actual fact that I can verify is that on the afternoon of 04 Dec 13, SimCom informed me that they were NO T 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 m y control and I have; on sev eral past occasions, volunteered m y servi ces and/or aircraft in an effort to assist them in the recertification process. In y ears past, I have allowed their past Training Center Evaluator (TCE); Mr. Andy Reeves, to come to my location and actuall y fl y my aircraft on each leg of the day s activities, to satisfy an apparentl y 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 presentl y curre nt in two other Ty

pe 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 S yl labus.

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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 ope rations in the Bahamas. **Regards,**

**John P. Lee Certificate #315528579** 

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