CENTURION 

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March 27, 2013 

Docket Manager Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

RE: Exemption from FAR 

Dear Sir/Madam: 

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In accordance with §11.61 ofTitle 14, Code ofFederal Regulations (14 CFR), Centurion 

Cargo petitions the Administrator for an exemption from § 121.434( c )(1 )(ii) to the extent 

necessary to substitute a qualified and authorized Check Airman in place of an FAA 

Inspector to observe a qualifying pilot in command (PIC) while that PIC is performing 

prescribed duties during at least one flight that includes a takeoff and a landing when 

completing initial or upgrade training as specified in § 121.434. 

The specific section 121.434(c)(l )(ii)- OPERATING EXPERIENCE, OPERATING 

CYCLES, AND CONSOLIDATION OF KNOWLEDGE AND SKILLS reads in pertinent 

part: 

"In addition, if a qualifying pilot in command is completing initial or upgrade training 

specified in FAR 121.424, be observed in the performance of prescribed duties by an FAA 

Inspector during at least one flight leg which includes a takeoff and a landing. " 

This petition requests relief from §121.434(c)(l)(ii) in those circumstances when an FAA 

Inspector is unavailable to observe a qualifying pilot in command during any operating 

experience flights. 

- Centurion Cargo will nominate qualified Check Airmen to perform these initial operating 

experience observations. The FAA will approve the qualified Check Airmen to conduct the 

observation flights through a letter of authorization. 

- The requirement of§ 121.434( c )(I )(ii) will be considered fulfilled if an FAA authorized 

Check Airman performs the observation. The observation requirement will be documented in 

the qualifying pilot's records. 

- The authorized Check Airman would be one other than he who is conducting the Operating 

Experience flights of the qualifying pilot. 

www.centurioncargo.com 

4500 NW 36th Street., Bldg. 916, Miami, Fl33166 USA 

Tel: 305-871-0130- Fax: 305-871-0794 
CENTURION 

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The original intent of §121.434(c)(l)(ii), issued in 1970, was to validate the training that a 

pitot received in a visual simulator. Since the adoption of the rule, the airline industry has 

gathered more than 30 years of experience with basic and advanced simulation. 

The FAA has the authority to observe any pilot any time at the discretion of the 

Administrator and continues to do so on a regular basis. However, the FAA conducts these 

routine observations on a schedule defined by the local CMO without the requisite burden of 

specifying a particular flight or flight series necessitated by the carrier's training and service 

schedule. Relieving FAA Inspectors from § 121.434( c )(1 )(ii) will allow the FAA to focus the 

efforts on higher priority safety concerns. 

Operational issues related with this request for exemption are listed below: 

- The majority of Centurion's flight operations are very often short notice and most always 

international in nature. Scheduling of FAA Inspectors to observe a qualifying pilot in 

command on an international operation on such short notice and to destinations abroad is 

difficult, if not impossible. 

As a result of these issues, many of our PIC candidates are serving in OE status in excess of 

the hours required for the completion of the qualification segment while awaiting FAA 

participation. This impacts our crew scheduling ability and places unnecessary financial 

burden on the company. 

Granting of this exemption is in the public interest and would allow the FAA to focus its 

inspection force on higher priority safety issues. It would also provide for a higher level of 

PIC candidate scrutiny by using Centurion Check Airmen who are more familiar with 

company operating policies and procedures while eliminating delays in the completion of the 

Operating Experience process. Additional benefits are realized in increased productivity and 

reducing unnecessary additional costs to the company. 

Granting and using this proposed exemption would have no significant impact upon safety. 

The authorized Check Airman will be highly trained, experienced, and qualified in the 

specific aircraft type. In addition, any Check Airman utilized must be approved by the FAA. 

Only Centurion qualified Check Airmen will be used to satisfy the requirements of 

§121.434(cX1X'i) when a qualified FAA Inspector is not available. The FAA has the 

authority to observe any pilot at any time during line operations. 

Centurion Cargo has been previously granted this exemption and is also aware of the 

precedent in regards to previous exemptions granted to other Air Carriers for similar relief as 

that which is sought by the request. Therefore, since granting this exemption is not precedent 

setting, Centurion requests that publication of this petition in the Federal Register be waived 

in accordance with Section 11.87(b ). Any delay in granting this exemption will have an 

adverse impact upon Centurion Cargo operations. 

www.centurion:::argo.com 

4500 NW 36th Street., Bldg. 916, Miami, Fl33166 USA 

Tel: 305-871-0130- Fax: 305-871-0794 
CENTURION 

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SUMMARY 

Centurion Cargo Petition for an Exemption to FAR 121.434( c )(1 )(ii) 

Centurion Cargo petitions the Administrator for an exemption from § 121.434 ( c )(1 )(ii) to the 

extent necessary to substitute a qualified and authorized Check Airman in place of an FAA 

inspector to observe a qualifying Pilot in Command (PIC) while that PIC is performing 

prescribed duties during at least one flight that includes a takeoff and a landing when 

completing Initial or Upgrade Training as specified in § 121.434. 

Should you have any questions or need additional information, please contact me at 305-871-

0130 ext. 1482 or vcoulson@centurioncargo.com · 

Sincerely, 

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Valery Cauls n -

Director of Operations 

www .centu rionca rgo .com 

4500 NW 36th Street., Bldg. 916, Miami, Fl 33166 USA 

Tel: 305-871-0130- Fax: 305-871-0794