i 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey 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 currency requirements as described in sections (a)(3) (i) or (ii) of said regulation. 

PETITION FOR DEVIATION 

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) of said regulation and specifically to allow said regulatory authority to 

extend to a pilot in command of a turbine-powered airplane that is type certificated for one pilot 

crewrnember, provided that pilot has complied with the requirements of paragraph (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 of a turbine-powered airplane that is type 

certificated for more than one pilot crewrnember: 

Article of the FAR affected: 

Article 135.247 provides, in pertinent part, 

(2) For operation during the period beginning 1 hour after sunset and ending 1 hour before 

sunrise (as published in the Air Almanac), made three takeoffs and three landings during that 

period as the sole manipulator of the flight controls in an aircraft of the same category and class 

and, if a type rating is required, of the same type in which that person is to serve. 

A person who complies with paragraph (a)(2) of this section need not comply with paragraph 

(a)(1) of this section. 

(3) Paragraph (a)(2) of this section does not apply to a pilot in command of a turbine-powered 

airplane that is type certificated for more than one pilot crewrnember, provided that pilot has 

complied with the requirements of paragraph (a)(3)(i) or (ii) of this 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 

crewmember that the pilot seeks to operate under this alternative, and: 

(A) That pilot must have logged at least 1,500 hours of aeronautical experience as a pilot; 

(B) In each airplane that is type certificated for more than one pilot crewmember that the pilot 

seeks to operate under this alternative, that pilot must have accomplished and logged the daytime 

takeoff and landing recent flight experience of paragraph (a) of this section, as the sole 

manipulator of the flight controls; 

(C) Within the preceding 90 days prior to the operation of that airplane that is type certificated 

for more than one pilot crewmember, the pilot must have accomplished and logged at least 15 

hours of flight time in the type of airplane that the pilot seeks to operate under this alternative; 

and 

(D) That pilot has accomplished and logged at least 3 takeoffs and 3 landings to a full stop, as the 

sole manipulator of the flight controls, in a turbine-powered airplane that requires more than one 

pilot crewmember. The pilot must have performed the takeoffs and landings during the period 

beginning 1 hour after sunset and ending 1 hour before sunrise within the preceding 6 months 

prior to the month of the flight. 

(ii) 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 

crewmember that the pilot seeks to operate under this alternative, and: 

(A) That pilot must have logged at least 1,500 hours of aeronautical experience as a pilot; 

(B) In each airplane that is type certificated for more than one pilot crewmember that the pilot 

seeks to operate under this alternative, that pilot must have accomplished and logged the daytime 

takeoff and landing recent flight experience of paragraph (a) of this section, as the sole 

manipulator of the flight controls; 

(C) Within the preceding 90 days prior to the operation of that airplane that is type certificated 

for more than one pilot crewmember, the pilot must have accomplished and logged at least 15 

hours of flight time in the type of airplane that the pilot seeks to operate under this alternative; 

and 

(D) Within the preceding 12 months prior to the month of the flight, the pilot must have 

completed a training program that is approved under part 142 of this chapter. The approved 

training program must have required and the pilot must have performed, at least 6 takeoffs and 6 

landings to a full stop as the sole manipulator of the controls in a flight simulator that is 

representative of a turbine-powered airplane that requires more than one pilot crewmember. Th~ 

flight simulator's visual system must have been adjusted to represent the period beginning 1 hour 

after sunset and ending 1 hour before sunrise. 

PAGE TWO OF FOUR 
Gama 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 of one 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 

of two 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 position that it can maintain an acceptable level of safety using two pilot 

operations of this 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 of this request would be in the public interest and would not 

jeopardize public safety in any way. 

In support of this proposal, Gama respectfully submits the following comments: 

1. Gama's principal base of operations 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. Gama performs management and consulting services for private individuals and 

corporations who own aircraft (hereinafter referred to as Owners). In addition to 

operating these aircraft for their private use, these Owners have found it beneficial to 

occasionally charter these aircraft to third parties. This is done under contract to Gama 

and under the auspices of Gama's Air Carrier Operating Certificate. 

3. Gama has operational control of the Owners' aircraft when these aircraft are being 

operated under the authority of the Air Carrier Operating Certificate in accordance with 

FAR 135. The Owners have operational control of their respective aircraft when said 

aircraft are being operated under the rules ofF AR 91. 

4. The demands of the charter (air taxi) service operated by Gama include operations at 

night as well as during daylight hours. 

5. Gama has been authorized by the FAA to conduct night operations under FAR 13 5 since 

1983 through the authority of Operations Specification A003. Gama has been safely 

conducting said night operations at all times since the issuance of said authority. 

PAGE THREE OF FOUR 
6. In over 32 years of experience in the management of night aircraft operations under FAR 

135, Gama has never experienced a performance or safety issue. Gama has instituted an 

effective Safety Management System used to identify and mitigate any and all risk in 

potentially unsafe operational conditions. Said Safety Management System has been 

officially recognized 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) Wyvem Recommended. 

7. Gama believes that this exemption would permit it to 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 Gama to extend the flexibility 

offered by the 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. If granted, this exemption would be in the public 

interest while maintaining the desired level of safety. 

For the reasons set forth above, Gama respectfully requests that the Administrator grant Gama a 

deviation from Article 135.247 of the Federal Aviation Regulations in so much as it relates to 

the alternate currency requirements as described in sections (a)(3) (i) or (ii) of said regulation to 

the extent necessary to allow Gama to use this night take-off and landing currency alternative in 

an aircraft type that is certificated for one pilot while conducting charter (air taxi) operations 

under FAR 13 5 and grant such other relief as shall be deemed in the public interest. 

Summary as follows: 

Pursuant to FAR 11.25 

Gama petitions the Administrator for a deviation from Article 135.247 of the Federal Aviation 

Regulations in so much as it relates to the alternate currency requirements as described in 

sections (a)(3) (i) or (ii) of said regulation to the extent necessary to allow Gama to use this night 

take-off and 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, 

)hOY>\(/) l{ (L 

THOMAS H. MILLER 

ACCOUNTABLE MANAGER 

Date: January 22, 2015 

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