10 Oct 14 

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 60.7(a)(1)(2) & (b)(1) 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. 

JohnP. 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 60.7(a)(1)(2) and 60.7(b)(l) 

Above FAR requires an approved FAR 142 Training Program for proficiency 

checks in the simulator. We are requesting the use of the simulator without an 

approved FAR 142 Training Program for all training and evaluations due to 

the reasons described below. 

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

Relief from the requirements of FAR 60.7(a)(1)(2) & (b)(l) due to the fact the 

ONLY JetStream 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 because they will not be 

applying for the renewal of their FAR 142 Certificate as it pertains to the BA4100. A review of the FAA's "National Resource" currently has one current 

and/or qualified inspector in the BA-4100 aircraft. 

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

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

(1) 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. 

(2) Wish to be approved to progressively train flight crews on the BA-4100 to the 

level of the Pilot Training Standards (PTS) for Type Rated Aircraft; as applicable, 

and to have the evaluation performed by the FAA. SimCom Training Center in 

Orlando, FL has approved to lease the simulator for the BA-41 00 to me under my 

company name of JETCO Training of Wisconsin for the training and FAA 

Evaluations. There are presently ten (10) BA-4100 aircraft in the country; of 

which 6 are airworthy and the balance are in various stages of inspection and/or 

repairs. 

(3) Not allowing this exemption and grant my request to continue the FAA 

supervised training of the BA-41 00 aircraft will affectively begin the termination 

of the use of this aircraft in the United States. 

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(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. 

(1) Granting this exemption for using the FAR 142 Training Facility; SimCom of 

Orlando FL, to regain training and progressive checks by the FAA would not 

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

proficiently in not only this aircraft, but 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 ICAOIIBAC, IS 

-BAO/AFSC/FAA Compliant SMS. The 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 ofthis off sight requirement and graded evaluations of 

the operations manual rivals that of a licensed dispatcher for each leg of our 

flight. 

(2) With the cooperation of SimCom Training Facility in Orlando, FL, I will be 

able to train pilot candidates for the Type Rating in the BA-4100; as applicable, 

using their appropriately rated and inspected simulator on a dry lease basis. Any 

and all progressive evaluations for said candidates will be conducted by the 

appropriately rated FAA Inspector(s). 

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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 60.7(a)(1)(2) & (b)(1) as long as there 

is no approved FAR 142 (or similarly FAA Approved) Training Facility in the 

exempted Type Specific Aircraft(BA-41 00); provided I remain qualified in 

accordance with FAR 61.58 using the same qualified and appropriately rated FAA 

Inspector( s) and simulators. 

(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 informed me that they will no longer be 

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

have regained recertifications from the FAA on their other type specific aircraft at 

their training facility. The fact that I can verify is that on the afternoon of 07 Oct 

14, SimCom informed me that they were going to be sending me a letter 

explaining that they were NOT going 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 is 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. 

I 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 of2014 at which time I will be returning to another FAR 142 Training 

Facility for my recurrent training in those aircraft. 

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(b) 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. 

nP.L~ 

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