# ~ CENTURION**G:£~rr:~~** March 27, 2013 Docket ManagerFacility US Department ofTransportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 RE: Exemption from FAR Dear Sir/Madam: 

### ] ;:.Prl - 8 P I: 5LJ

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 ofan FAA Inspectorto observe a qualifying pilot in command (PIC) while that PIC is performing prescribed duties during at least one flight that includes a takeoffand a landing when completing initial orupgrade 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 qualifyingpilotin commandis completing initial or upgrade training specifiedin FAR 121.424, be observedin theperformance of prescribedduties byan FAA Inspector during at least one flight legwhich includes a takeoff anda landing. " This petition requests relieffrom §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 ofauthorization.

- The requirement of§121.434(c)(I)(ii) will be considered fulfilled ifan FAA authorized CheckAirman performs the observation. The observation requirement will be documented in the qualifyingpilot's records.

- The authorized Check Airman would be one otherthan he who is conductingthe Operating Experience flights ofthe qualifyingpilot.

www.centurioncargo.com 4500 NW 36th Street., Bldg. 916, Miami, Fl33166 USA Tel: 305-871-0130- Fax: 305-871-0794

# ~ CENTURION

## cr:Rlli@(O) 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 ofthe rule, the airline industry has gathered more than 30 years ofexperience with basic and advanced simulation. The FAA has the authority to observe any pilot any time at the discretion ofthe 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 higherpriority safety concerns. Operational issues related with this request for exemption are listed below:

- The majority ofCenturion's flight operations are very often short notice and most always international in nature. Scheduling ofFAA Inspectors to observe a qualifying pilot in command on an international operation on such short notice and to destinations abroad is difficult, ifnot impossible. As a result ofthese issues, many ofourPIC candidates are serving in OE status in excess of the hours required for the completion ofthe qualification segment while awaiting FAA participation. This impacts our crew scheduling ability and places unnecessary financial burden on the company. Granting ofthis exemption is in the public interest and would allow the FAA to focus its inspection force on higherpriority safety issues. Itwould also provide for a higher level of PIC candidate scrutiny by using Centurion Check Airmen who are more familiar with company operatingpolicies and procedures while eliminating delays in the completion ofthe Operating Experienceprocess. 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 CheckAirman 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 anypilotat any time during line operations. Centurion Cargo has been previously granted this exemption and is also aware ofthe precedent in regards to previous exemptions granted to other Air Carriers for similar reliefas that which is soughtby the request. Therefore, since granting this exemption is not precedent setting, Centurion requests thatpublication ofthis 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 <C&ffi.OO

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 ofan FAA inspectorto observe a qualifying Pilot in Command (PIC) while that PIC is performing prescribed duties during at least one flight that includes a takeoffand a landing when completing Initial or Upgrade Training as specified in 

### §121.434. Should you have any questions orneed additional information, please contact me at 305-871- 0130 ext. 1482 orvcoulson@centurioncargo.com ·
Sincerely,



# . (fvtq:nL Valery Cauls n - Director ofOperations

www .centu rionca rgo .com 4500 NW 36th Street., Bldg. 916, Miami, Fl 33166 USA Tel: 305-871-0130- Fax: 305-871-0794