aut ew eaf laite, izc. I 

#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, requires 

our 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.