# i Docket Management Facility US Department ofTransportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590
Petition of:
Gama Charters Inc. **~-** ·.:.

Regulatory Docket No.

for a deviation from Article 135.247 ofthe Federal Aviation Regulations in so much as it relates to the alternate currencyrequirements as described in sections (a)(3) (i) or (ii) ofsaid regulation.
PETITION FORDEVIATION
In accordance with the provisions ofF AR 11.25, Gama Charters Inc. (Gama) hereby petitions the Administrator for a deviation from Article 135.247 ofthe Federal Aviation Regulations in so much as it relates to the alternate night take-off and landing currency options as described in sections (a)(3) (i) or (ii) ofsaid regulation and specifically to allow said regulatory authority to extend to a pilot in command ofa turbine-powered airplane that is type certificated for one pilot crewrnember, provided thatpilothas complied with the requirements ofparagraph (a)(3)(i) or (ii) of said FAR to obtain and maintain night take-off and landing currency. Currently said regulatory authority is limited to a pilot in command ofa turbine-powered airplane that is type certificated for more than one pilot crewrnember:
Article ofthe FAR affected:
Article 135.247 provides, inpertinentpart, (2) For operation during the period beginning 1hour after sunset and ending 1hour before sunrise (as published inthe AirAlmanac), made three takeoffs and three landings during that period asthe sole manipulator ofthe flight controls in an aircraft ofthe same category and class and, ifa type rating is required, ofthe same type inwhich that person is to serve. A person who complies withparagraph (a)(2) ofthis section need not complywith paragraph (a)(1) ofthis section. (3) Paragraph (a)(2) ofthis section does not apply to a pilot in command ofa turbine-powered airplane that is type certificated for more than one pilot crewrnember, providedthat pilot has complied withthe requirements ofparagraph (a)(3)(i) or (ii) ofthis section:

PAGE ONE OF FOUR(i) The pilot in command must hold at least a commercial pilot certificate with the appropriate category, class, and type rating for each airplane that is type certificated for more than one pilot crewmemberthat the pilot seeks to operate under this alternative, and: (A) Thatpilot must have logged at least 1,500 hours ofaeronautical experience as a pilot; (B) In each airplane that is type certificated for more than one pilot crewmemberthat the pilot seeks to operate under this alternative, thatpilotmust have accomplished and logged the daytime takeoffand landing recent flight experience ofparagraph (a) ofthis section, as the sole manipulator ofthe flight controls; (C) Within the preceding 90 days priorto the operation ofthat airplane that is type certificated for more than one pilot crewmember, the pilotmust have accomplished and logged at least 15 hours offlight time inthe type ofairplane that the pilot seeks to operate under this alternative; and (D) Thatpilothas accomplished and logged at least 3 takeoffs and 3 landings to a full stop, as the sole manipulator ofthe flight controls, 

### in a turbine-powered airplane thatrequires more than one pilot crewmember. The pilotmusthave performedthe takeoffs and landings duringthe period beginning 1hour after sunset and ending 1 hourbefore sunrise within the preceding 6 months priorto the month ofthe flight. (ii) The pilot in command must hold at least a commercialpilot certificate withthe appropriate category, class, and type rating for each airplane that is type certificated for more than one pilot crewmemberthat the pilot seeks to operate under this alternative, and: (A) Thatpilotmust have logged at least 1,500 hours ofaeronautical experience as a pilot; (B) In each airplane that is type certificated for more than one pilot crewmemberthat the pilot seeks to operate under this alternative, thatpilot must have accomplished and loggedthe daytime takeoffand landingrecent flight experience ofparagraph (a) ofthis section, as the sole manipulator ofthe flight controls; (C) Withinthe preceding 90 days priorto the operation ofthat airplane that is type certificated for more than one pilot crewmember, the pilotmust have accomplished and logged at least 15 hours offlight time in the type ofairplane that the pilot seeks to operate underthis alternative; and (D) Withinthe preceding 12 months prior to the month ofthe flight, the pilot must have completed a training program that is approvedunderpart 142 ofthis chapter. The approved training programmust have required andthepilotmust have performed, at least 6 takeoffs and 6 landings to a full stop as the sole manipulator ofthe controls in a flight simulatorthat is representative ofa turbine-powered airplane thatrequires more than one pilot crewmember.

**Th~** flight simulator's visual system musthavebeen adjusted to represent the period beginning 1hour after sunset and ending 1hour before sunrise.

PAGE TWO OF FOURGama proposes to allow its pilots to maintain night currency requirements under this section's paragraphs (a)(3)(i) or (ii) in Beechcraft BE300-B300 type aircraft. Said aircraft are FAR 23 Commuter Category certified for operations with a crew ofone pilot. The FAR 135.247 night currency alternative described in paragraph (a)(3)(i) or (ii) only applies to aircraft certified for more than one pilot crewmember. Gama would like to use this night currency alternative for said single pilot certified aircraft.
Gama currently operates the Beechcraft BE300-B300 aircraft type with two pilots at all times. All of Gama's BE300-B300 pilots hold Airline Transport Pilot Certificates. The majority of these Beechcraft BE300-B300 type aircraft pilots have a requirement for a Second in Command limitation depicted on their Airline Transport Pilot Certificates. Gama does not hold Operations Specification, A015, "autopilot authorized in lieu of second in command" privileges listing the BE300-B300 type aircraft. Thus Gama is required to operate the subject aircraft with a minimum oftwo pilots at all times. Gama's BE300-B300 pilots successfully complete simulator training in level D BE300-B300 simulators every six months.
Gama takes the positionthat it can maintain an acceptable level ofsafety using two pilot operations ofthis single pilot certified aircraft by exercising and adhering to the night currency requirements depicted under the subject section's paragraphs (a)(3)(i) or (ii) for its BE300-B300 single pilot aircraft. The granting ofthis request would be inthe public interest and would not jeopardizepublic safety in any way. In support ofthis proposal, Gamarespectfully submits the following comments:
1. Gama's principal base ofoperations is located at 700 Great Meadow Road Sikorsky Memorial Airport, Stratford, CT 06497. Gama holds Air Carrier Operating Certificate Number 02GA9701 and conducts air taxi and on demand charter operations under FAR 135.
2. Gamaperforms management and consulting services for private individuals and corporations who own aircraft (hereinafterreferred to as Owners). In additionto operating these aircraft for theirprivate use, these Owners have found itbeneficial to occasionally charter these aircraftto third parties. This is done under contract to Gama and under the auspices ofGama's Air Carrier Operating Certificate.
3. Gamahas operational control ofthe Owners' aircraft whenthese aircraft are being operated under the authority ofthe Air Carrier Operating Certificate in accordance with FAR 135. The Owners have operational control oftheir respective aircraft when said aircraft are being operated under the rules ofF AR 91.
4. The demands ofthe charter (air taxi) service operated by Gama include operations at night as well as during daylight hours.
5. Gamahas been authorized by the FAA to conduct night operations under FAR 135 since 1983 through the authority ofOperations Specification A003. Gama has been safely conducting said night operations at all times since the issuance ofsaid authority.

PAGE THREE OF FOUR6. In over 32 years ofexperience inthe management ofnight aircraft operations under FAR 135, Gamahas never experienced a performance or safety issue. Gamahas instituted an effective SafetyManagement System used to identify and mitigate any and all risk in potentially unsafe operational conditions. Said Safety Management System has been officiallyrecognized by the following industry and governmental sources: 1) FAA SMS Pilot Program Level3, 2) Air Charter Safety Foundation (ACSF) Level 3, 3) IS-BAO Level 3, 4) IS0-9001-2008 Registered, 5) ARG-US Platinum Level, 6) WyvemRecommended.
7. Gamabelieves that this exemption would permit itto respond to a growing demand for night operations and would permit Gama aircraft to be available to the general public which would not otherwise be available. To not allow Gamato extend the flexibility offeredbythe FAR 135.247 night currency alternative described in paragraph (a)(3)(i) or (ii) to single pilot certified aircraft such as the BE300-B300 would impose an unreasonable burden to this operator. Ifgranted, this exemption would be inthe public interest while maintaining the desired level ofsafety.
For the reasons set forth above, Gama respectfully requests that the Administrator grant Gama a deviation from Article 135.247 ofthe Federal Aviation Regulations in so much as it relates to the alternate currency requirements as described in sections (a)(3) (i) or (ii) ofsaid regulation to the extent necessary to allow Gama to use this night take-offand landing currency alternative in an aircraft type that is certificated for one pilot while conducting charter (air taxi) operations under FAR 135 and grant such other reliefas shall be deemed in the public interest. Summary as follows:
Pursuantto FAR 11.25
Gama petitions the Administrator for a deviation from Article 135.247 ofthe Federal Aviation Regulations in so much as it relates to the alternate currency requirements as described in sections (a)(3) (i) or (ii) ofsaid regulation to the extent necessary to allow Gama to use this night take-offand landing currency alternative in an aircraft type that is certificated for one pilot while conducting charter (air taxi) operations under FAR 135 and grant such other relief as shall be deemed in the public interest. Respectfully submitted,



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THOMAS H. MILLER ACCOUNTABLE MANAGER Date: January 22, 2015

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