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 pro visional 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 Was hington 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 m eet this requirement and respectfully request a waiver or exemption of the ten graduates element of 14 CFR 141.5(e) for reasons Iwill 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 Virgin ia due to a change in work location. We currentl y have five students alread y enrolled and activel y fl yi ng in approved Part 141 TCOs. I have attached copies of their enrollment certificates for your review. They are: Roger Marcellus, Instrument Rating, e nrolled 23 Sep 2012 Winston Brown, Commercial Pilot, enrolled 20 Feb 2013 David Salvagnini, Flight Instructor Airplane, enrolled 20 May 2013 Sean Pay ne, 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 heav y interest in beginning flight training under Part 141 at our flight school in the near future.Very

few studen ts in the Washington, DC area fl y in a full time capacit y 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 b y 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 t o 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 duri ng 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 improvem ents 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 y ou can see from the above, GT Aviation has worked hard to expand our business and d o 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 rev oked at the end of this month, it would be detrimental to these students and would be a major setback for our small business. We respectfull y request relief from the ten graduate requirement in 14 CFR 141.5(e) for the man y reasons listed above. Thank yo u for your time and attention to this matter. Regards,

Timothy Poole President GT Aviation, LLC