1 July 2013 

The Administrator 

Federal Aviation Administration 

United States of America

Subject: Exemption request for Part 141 provisional certificate graduation requirements 

Dear Inspector, 

GT Aviation, LLC is currently operating under provisional certificate # 27GS055L. This provisional 

certificate is set to expire on 31 Jul 2013. We have submitted for a certificate renewal via FAA 

Form 8420-8 dated 5 Jun 2013. We have been informed by Principal Operations Inspector Mark 

Fair of the Washington FSDO our certificate cannot be renewed due to the provision in 14 CFR 

141.5(e) requiring a provisional school to have graduated ten different students from approved TCOs 

during the 24 months prior to certificate expiration. 

We were not able to meet this requirement and respectfully request a waiver or exemption of the ten 

graduates element of 14 CFR 141.5(e) for reasons I will elaborate herein.

GT Aviation, LLC has graduated one student in the required timeframe. That student, David French, 

completed the Instrument Rating approved TCO and passed his check ride on 14 Apr 2013.

A second student, Megan Mosenson, completed the majority of the required training under the 

approved Instrument Rating TCO but then transferred to another school in Virginia due to a change 

in work location.

We currently have five students already enrolled and actively flying in approved Part 141 TCOs. I 

have attached copies of their enrollment certificates for your review. They are:

Roger Marcellus, Instrument Rating, enrolled 23 Sep 2012

Winston Brown, Commercial Pilot, enrolled 20 Feb 2013

David Salvagnini, Flight Instructor Airplane, enrolled 20 May 2013

Sean Payne, Instrument Rating, enrolled 26 June 2013

Peter Rawlings, Instrument Rating, enrolled 9 July 2013

We have two potential students interested in enrolling in our program soon as well. Rodney Wood 

and Simon Anderson have both indicated heavy interest in beginning flight training under Part 141 

at our flight school in the near future.
Very few students in the Washington, DC area fly in a full time capacity where they can take full 

advantage of Part 141 accelerated instruction. Issues we deal with due to our location in the Flight 

Restricted Zone / Special Flight Rules Area further complicate student training. 

Once we received our provisional certificate, we later applied to the Veterans Administration for VA 

Approval as a training center that can accept VA / GI Bill benefits. We felt that would increase the 

potential customer base of our school, and by extension help meet the 10 graduate requirement.

Despite submitting our application to the VA on 15 Mar 2012, the request was not approved until 24 

Oct 2012, just 8 short months ago. 

To further broaden our ability to offer Part 141 instruction to the public, we have partnered with the 

Community College of Baltimore County as a training provider in their Aviation degree program. I 

have attached a letter confirming this relationship has been established allowing us to start providing 

training during the Fall 2013 semester.

GT Aviation has made significant investments in equipment and infrastructure to support our Part 

141 and Part 61 training offerings via our in house training and the CCBC relationship mentioned 

above. Chief among these improvements was the expansion to twice the administrative space 

occupied when the provisional certificate was first issued. This new space now accommodates a 

formal isolated classroom environment and a dedicated space for our latest investment – a Redbird 

LD AATD simulator. This simulator came at considerable expense (close to $50,000) but was 

chosen due to its ability to be integrated seamlessly into the Part 141 curriculum.

As you can see from the above, GT Aviation has worked hard to expand our business and do so in a 

manner to meet FAA requirements under the provisional certificate. Those efforts took some time 

to hit their stride but we are now at a point of having five (soon seven) 14 CFR 141 students active 

in the school. If our certificate would be revoked at the end of this month, it would be detrimental to 

these students and would be a major setback for our small business. 

We respectfully request relief from the ten graduate requirement in 14 CFR 141.5(e) for the many 

reasons listed above. 

Thank you for your time and attention to this matter.

Regards,

Timothy Poole

President

GT Aviation, LLC