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#1 Coquille Drive, Belle Chasse, LA 70037 • CHARTER

Telephone: (504) 394-5633 • MAINTENANCE Fax: (504) 394-8458 • HANGER STORAGE—TIE DOWNS

June 12, 2015

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

To Whom It May Concem:

I am writing this letter requesting an exemption to Federal Aviation Regulations Part 141.55(d)(1) for our Part 141 Seaplane Add-On Course Certificate number SSCS2691. Southern Seaplane has held a Provisional Flight School Certificate for 24 calendar months, but stopped training in the interest of safety. Exemption from this regulation would allow us the ability to work with our Flight Standards District Office (FSDO) to amend our Training Course Outline (TCO) that would make the course safe for our students and instructors.

As per Appendix 140)(1), a student is required to have a minimum of 3 hours of flight training on the areas of operations under Part 141, appendix B, paragraph 4.(d)(1). This includes: three hours of cross country, three hours instrument flight training, and a three hour 100 nautical mile nighttime training flight with 10 takeoffs and 10 landings to a full stop.

As per our TCO, a prerequisite for enrollment of the course is to hold a Private Pilot Certificate or higher in Airplane Category. Under Part 61 and Part 141 Regulations, a private pilot is required to complete all the requirements that are stated above. Therefore our student has already completed these requirements.

After the first student went through the course, Southem Seaplane, Inc. feels that the nighttime requirement greatly increases risk for an accident and has no benefit to the student. As a Part 135 Seaplane Charter Operator, we do not advocate water landings at night. Our standard practice is to make sure we are back at our base before dark in a straight float aircraft. If we are in an amphibious aircraft we are sure to take off from a remote water location before dark and return to our base landing on our hard surface runway to eliminate a water landing at night. Water landings at night are not prohibited but are not encouraged. According to FAA Handbook, FAA-A-8083-23, Seaplane, Skiplane, and Float/Ski Equipped Helicopter Operations Handbook, "A night water landing should generally be considered only in an emergency. They can be extremely dangerous due to the difficulty of seeing objects in the water, judging surface conditions, and avoiding large waves or swell." (Chapter 6: Seaplane Operations-Landing, page 6-8).

The level of difficulty and skill it takes to perform such a maneuver is one that a student pilot should never be in a position to be forced to demonstrate. Routinely putting a novice pilot behind the controls in a night time water landing situation puts himself and the instructor in a situation where the risk for an accident is greatly increased. The repercussion of an egress scenario at night is potentially fatal. Safety is at the top of our list of concems and we strongly feel that it is a necessity to remove this requirement as soon as possible.• Page 2 June 12, 2015

This exemption request would benefit the public because there is no Part 141 Seaplane Add-On (Additional Category) Course currently offered to the public as an option for training. This milestone is important for the aviation community. Many Veterans have inquired about the course in hopes to utilize benefits from the GI Bill to pay for a percentage of their training. They are unable to utilize this fund at a Part 61 training school. Without a Part 141 school available, they are unable to acquire a rating with financial assistance. We have received plenty of calls to enroll in the course but we will not put another student through the course with the nighttime requirement. The aviation community deserves a Part 141 Seaplane Add-On Rating Course where safety is at the forefront of training.

Removing a three hour 100 nautical mile nighttime training flight with 10 takeoffs and 10 landings to a full stop from our Seaplane Add-On course would not adversely affect safety because the student has already fulfilled this requirement in category while obtaining his/her prerequisite of holding a minimum of a Private Pilot Certificate, Airplane Category. This means he/she has gone through the proper training and checkride where they have shown they can perform this section of the Practical Test Standards. Therefore this is equal to the level of safety that has already previously been determined for a Private Pilot Certificate.

In regards to the night time flight, not relieving our course of this regulation does adversely affect safety. Not giving our course relief from this regulation is paving the way for a potentially fatal accident. Removing this requirement for the course would exceed the level of safety currently in place. By not allowing us to work with the FSDO under 141.55(d) to obtain relief from these requirements, requiresour TCO to contain training that forces our school to operate in direct conflict with FAA Handbook, FAAA-8083-23 and its recommendations regarding safety of flight and protection of human life by performing routinely what should only be done in an emergency situation.

Allowing relief from Federal Aviation Regulations Part 141.55(d)(1) would give us the ability to work with our FSDO to request and receive initial approval for a TCO per 141.55(d) with less than the minimum specified training times for a Part 141 Seaplane Add-On Rating even though Southern Seaplane has not held a pilot school certificate issued under this part for 24 consecutive calendar months previous and therefore cannot comply with 141.55(d)(1).

This course will exceed all requirements of the Practical Test Standards for the rating as well as holding safety to a high standard.

Sincerely,

Lacey P. Charvet Vice President Southern Seaplane, Inc.