### 10 Oct 14

E-Mailed andFedEx.

Docket Management Facility US Department ofTransportation 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) andwill explain in accordancewith FARPart 11, Section 81, as noted in the following.

(a) Yourname and mailing address and, if

### youwish, 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 CFRfrom which you seek an exemption.

FAR 60.7(a)(1)(2) and 60.7(b)(l)

Above FARrequires an approved FAR 142 Training Program for proficiency checks in the simulator. We are requesting the use ofthe simulator without an approved FAR 142 Training Program for all training and evaluations due to the reasons described below.



### -1-(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 oftheir 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 inthe 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 constructionprojects throughout the State ofWisconsin and this aircraft is used to ferry the individuals concerned to these construction sights. Notbeing able to use the aircraft would
not only slow down the completion ofthese projects; but, may also delay their openings at these expansions and mayjeopardize or at least delay many ofthese jobs. (2) Wishto be approved to progressively train flight crews onthe BA-4100 to the level ofthe Pilot Training Standards (PTS) for Type Rated Aircraft; as applicable, and to have the evaluation performed bythe FAA. SimCom Training Center in Orlando, FL has approved to lease the simulator for the BA-4100 to me under my company name ofJETCO Training ofWisconsin 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 ofinspection and/or repairs. (3) Not allowing this exemption and grant myrequest to continue the FAA supervised training ofthe BA-4100 aircraft will affectively beginthe termination ofthe use ofthis aircraft inthe United States.

-2-(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level ofsafety 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 bythe FAA would not adversely affect safety due to the fact that I amkeeping trained and maintaining proficiently in not onlythis aircraft, buttwo (2) other "Type Specific Aircraft". Currently operatingthe LearJet 20 & 30 Series Jet andjustreturned from training and will be operating the Cessna Citation III (CE-650), both aircrafttraining 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 ofthe 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 takeoffand landing; computations using Runway Analysis for each and every takeoff(far exceedingthe minimum requirements of Part 91 ofthe Regulations); and the use and implementation ofthe Operations Manual required Flight Risk Assessment Tool (FRAT) for each and every takeoff and landing. Included inthe FRAT is the consideration ofall aircraft performance issues, airport and weather situations with a risk analysis ofeach takeoffand landing. In accordance withthe Operations Manual, these leg-by-leg computations are kept for two (2) years. This manual exceeds all efficiency and safety requirements. Use ofthis offsight requirement and graded evaluations of the operations manual rivals that ofa licensed dispatcher for each leg ofour flight.

(2) With the cooperation ofSimCom Training Facility in Orlando, FL, I will be able to

### train pilot candidates for the Type Rating 

### inthe 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 bythe appropriately rated FAAInspector(s).

-3-

### (f) A summary we can publish in the FEDERAL REGISTER, stating, (1) The rule from which you seekthe exemption, and (2) A briefdescription ofthe nature ofthe exemption you seek.

Exemption from the requirements ofFAR 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-4100); 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 ONLYpreviously FAA FAR Part 142 approved source oftraining for use under FARParts 61 and 91 inthe British AeroSpace 4100 Series aircraft has been SimCom ofOrlando, FL. They informed me that they will no longerbe working onregaining FAArecertification inthis type specific aircraft. They have regained recertifications from the FAA ontheir othertype specific aircraft at their training facility. The fact that I can verify is that onthe afternoon of07 Oct 14, SimCom informed me that they were going to be sending me a letter explaining that they were NOT going to complete the FAArequirements for the recertification ofeithertheirFAR 142 Training Program inthe BA-4100 ortheir FAR 61.58 Approved Training Program inthe BA-4100. This situation is totally
out ofmy control and I have; on several past occasions, volunteered my services and/or aircraft in an effort to assist them inthe recertification process. In years past, I have allowed theirpast Training Center Evaluator (TCE); Mr. Andy Reeves, to cometo my location and actually fly my aircraft oneach leg ofthe days activities, to satisfy an apparently newregulation in FAR 142.

I am presently current intwo other Type Specific Aircraft; Lear Jet 20, 30 & 50 Series and Cessna Citation 650 Series, both training under FARPart 142, thru December of2014 at which time I will be returning to another FAR 142 Training Facility for myrecurrent training inthose aircraft.

-4-(b) If

### youwantto exercise the privileges ofyourexemption outside the United States, the reason whyyou need to do so.

Would also request approval to include operations inthe Bahamas.

# nP.L~

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