CitationShares Management LLC

dba, CitationAir

Three American Lane

Greenwich, CT 06831

®

Michael Daigneault

Director, Flight Standards

mdaigneault@citationair.textron.com

12 February 2013

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Ave, S.E.

West Building Ground Floor, Room W12-140

Washington, DC 20590

Submitted via www.regulations.gov

Re: Petition for Exemption from § 61.3(a) and (c) of Title 14 Code of Federal Regulations 

Ladies/Gentlemen,

In accordance with 14 CFR Part 11, please consider CitationShares Management (CSM), LLC’s 

petition for exemption from § 61.3(a) and (c) of Title 14 Code of Federal Regulations.

Section 61.3(a) states, in pertinent part, that no person may serve as a required pilot flight 

crewmember of a civil aircraft of United States registry unless that person has in his physical possession 

or readily accessible in the aircraft a certificate issued to him under this part. This section also requires 

the crewmember to have in his physical possession or readily accessible in the aircraft a government 

issued photo identification which include a valid drivers license or official passport. Section 61.3(c) 

states the same possession requirement for an appropriate current medial certificate.

CSM requests to be permitted to temporarily issue confirmation of any required crewmember 

certificate by electronic means to its flight crewmembers. This confirmation would be based upon 

information that is currently maintained in CSM’s approved electronic record keeping system. CSM 

also requests to be permitted to issue to its flight crewmembers, via electronic means, a legible copy of 

his or her valid driver’s license or passport to fulfill the photo ID requirement as required to fully meet 

the requirements as specified in § 61.3(a)(2). 

The reason for this petition, including level of safety and public interest, would be identical to those 

presented by one air carrier, Netjets Aviation, Inc. which performs very similar flight operations under 

14 CFR Parts 91, 91K and 135. The grant of that air carrier’s petition can be found under Regulatory 

Docket No. FAA-2005-23002. Additionally, a similar petition request was granted to the Regional 

Airline Association (RAA). The information presented by RAA is found in Regulatory Docket No. 

FAA-2000-8180 and was the basis upon which the FAA issued Exemption No. 5560 to RAA members 

carriers operating under 14 CFR Part 135.
CSM’s flights are unscheduled and involve operations during all hours of the day and night. 

Considering the number of certificated airmen required to support these operations, it is not uncommon 

for a small percentage of this group to have his or her required certificate(s) and/or photo ID misplaced, 

lost, or destroyed. Occasionally, this may occur at a time and/or location where it is not possible to 

contact the FAA in Oklahoma City to request the appropriate confirmation in accordance with § 61.29. 

It may also be impractical to obtain a required photo ID at the time and/or location. Under the current 

rules, a flight must then be delayed or cancelled until the FAA certificate confirmation and/or photo ID 

can be received by the operating crew.

CSM, believes that the delay or cancellation should not be necessary because the certificate holder 

has a record of the airman’s certificates and a copy his or her passport and/or drivers license. However, 

to comply with the above rules, the flight must be delayed or in some cases cancelled simply because the 

FAA offices in Oklahoma are closed, because prompt transmittal capabilities may not be available at the 

airman’s location, or because there is no way to quickly acquire a replacement photo ID.

It is in the interest of public benefit to allow CSM to continue flight operations as normally 

scheduled in the event of a lost pilot or medical certificate. An equivalent level of safety will be 

maintained by procedures similar in respects to those found in the grant of the two aforementioned 

exemptions.

As supporting justification that the petition would establish a level of safety equivalent to the 

regulation, essentially the aforementioned similar petitions each proposed that an approved method be 

established as an alternative. That method would confirm the identity of the crewmember and provide 

the crewmember with a copy of the certificate(s) and/or photo ID. As with similar petitions CSM 

proposes that the operator-issued certificate confirmation be valid only until the airman is able to acquire 

FAA-issued certificate confirmation.

CSM also proposes an operator-issued copy of a current valid drivers license or official passport be 

valid (for FAA identification purposes only) until a replacement government photo ID can be acquired. 

This petition by CSM for an exemption from § 61.3(a) and (c), to issue to its flight crewmembers, 

on a temporary basis, confirmation of any required crewmember certificate by transmitting an electronic 

copy of the certificate is virtually identical to two existing exemptions and therefore would not set a 

precedent. Therefore, CSM requests that the requirement for publication and comment be waived.

Sincerely,

Michael J. Daigneault