March 1, 2010 

To: 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Petition for Exemption; 

From: 

Daniel Waters 

Falcon Aviation Academy (PFC Aviation, Inc) 

95 East Aviation Way 

New/nan, Georgia 30263 

770-486-5561 

Section of Relief: 

Falcon Aviatior) Academy is seeking relief from the requirements of FAR Part 61, subpart G as a basis for 

enrollment and graduation from the Airline Transport Pilot Certification Course conducted under its FAR 

141 TCO. 

BgcKflTQurKl: 

Falcon Aviation Academy (PFC Aviation. Inc) Is the holder of pBot school certificate U4PS for the following 

courses: Private Pilot. Comrnerdal POot. Instrument Rating, Additional Category and Class Ratings, 

Airline Transport Pilot, Certified FHght Instructor, and Special Courses. 

The school received its initKri Agency Certific^e approval in 2003. The school was developed by Daniel 

Waters, as a pnsfessionai flight school for airman for local regional airlines as weH as international airlines. 

Mr. Waters is an experienced airUne manager spaciaiizing in airline training standards on regional 

aircraft for over 25 years. Mr. Waters has developed aB courses and curriculum as serves as the Chief 

instructor for the sc^iool. 
The Falcon Aviation Academy TCO for ATP requires an enrollment and graduation prerequisite for the 

applicant to meet the aeronautical experience of FAR Part 61.159. 

61.159 Aeronautical experience: Airplane category rating. 

FAR Part 61.159 states in part: 

(a) Except as provided in paragraphs (b), (c), and (d) of this section, a person who is applying for an 

airline transport pilot certificate with an airplane category and class rating must have at least 1,500 hours 

of total time as a pilot that includes at least: 

FAR 141 Appendix E states in part: 

Appendix E to Part 141—^Airline Transport Pilot Certification Course 

Eligibility for enrollment. Before completing the flight portion of the airline transport pilot certification 

course, a person must meet the aeronautical experience requirements for an airline transport pilot 

certificate under part 61, subpart G of this chapter that is appropriate to the aircraft category and class 

rating for which the course applies, and: 

Specific Relief comments: 

The requirement for the applicant to meet the requirements for FAR 61 aeronautical experience negates 

any need for an applicant to attend a FAR 141 ATP course of training. Falcon Aviation believes that if it 

could offer pilots without the aeronautical experience of Part 61 that it could provide a higher level of ATP 

training than is normally given to general aviation pilots. The ATP 141 course offers knowledge and skill 

training elements that are typically missing in general aviation training. Pilots do not receive this kind of 

training in general aviation until they are either employed as a Part 135 pilot, a Part 121 new hire or in 

some cases an FAR part 91 subpart K pilot. Falcon has long believed that if it could enroll pilots with less 

aeronautical total hours in its ATP course that it could have a benefit on the overall quality of pilots who 

will eventually attain employment as a regional airline FAR 121 initial new hire. With the cun-ent 

requirements for a pilot to already meet FAR 61 aeronautical experience requirements, there is no 

incentive, either for career advancements or economically to attend an FAR 141 ATP course. 

Therefore. Falcon Aviation is requesting relief from FAR 141 appendix E enrollment requirements for the 

ATP course as follows; 

Enrollment requirements: a pilot may be enrolled in the Falcon Aviation Academy FAR Part 141 ATP 

course under FAR 141 Appendix E if that person is the holder of a Commercial Pilot Certificate with an 

Instalment Rating and the appropriate category and class rating. After successful completion of the 

course, the person will receive a graduation certificate stating successful completion of the ATP Course. 

A person will not be eligible for the ATP Certificate until that person meets the requirements of FAR Part 

61 subpart G. 

Industry Benefit: 

The request would benefit the public by flAowing advanced trair ^ to airman at an earlier stage of their 

development. This is a missing component in aviation today as has been noted by the NTSB in recent 

accident investigations. By allowing a person to enroll and complete an ATP course with certificate of 
completion, will demonstrate that the applicant has received more training than is normally required. It 

will additionally provide real training for the applicant to eventually obtain the ATP after meeting the flight 

hour's experience. The training required by FAR 141 is missing in any Part 61 training for a small aircraft 

not requiring a type rating. Under Part 61, no flight training or endorsement of such training is required. 

FAR Part 141 offers the public the benefit of providing a more highly trained pilot. By receiving the 

training under FAR Part 141 appendix E at an early development stage, the pilot will be better prepared 

with the proper habits, skills and knowledge for safely gaining aeronautical experience. The person will 

be better prepared for advancement into air carrier operations. Therefore, it is in the public interest to 

allow a better training program to a person at an earlier stage in their development. 

Summary: 

Falcon Aviation Academy is requesting relief from FAR 141 appendix E by allowing a person to complete 

the FAR 141 ATP course without first meeting the aeronautical experience of FAR Part 61.159. The 

requested exemption would not allow the person to apply for the ATP Practical Test until meeting the 

requirements of FAR Part 61.159. An equivalent level of safety is established, and in this case an 

improved level of safety is established for the following reasons: 

1. The structured and disciplined manner of the Falcon Aviation Academy ATP TCO offers the person an 

advanced level of training. 

2. The TCO requires 40 hours of class room academic instruction on air carrier and advanced knowledge 

topics. 

3.The flight curriculum requires 25 hours of advance instruction in instrument and commercial operations. 

4. The graduate is allowed to hold the FAR 141 Graduation Certificate displaying an advanced level of 

training. 

Finally, the FAR141 ATP course is seldom used in industry since pilots already meeting the Part 61 ATP 

experience requires have no reason for spending the time or money on an advanced course. This 

exemption would offer the course as an enhancement of safety and have only positive application to 

safety throughout the aviation community. 

Sincerely, 

Daniel Waters 

Chief Instructor 

Falcon Aviation Academy, LLC 

PFC Aviation, Inc)