U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room w12-140 1200 New JerseyAvenue, S.E: Washington, DC 20590



# Petition for Exemption Under 14 CFR 61.73(c) to Allow Eligibility for Issuing ofa Commercial Pilot Certificate Based on Military Training.

July 14, 2015 Petitioner: Marco EPIFANIO, AIR OPERATIONS, PSC 812 BOX 1675, FPO AE 0927-0017 Cell: +39 3468766902 Email: marcob@gmail.com Dear FAA, This application is for Petitioning for Exemption underSection 61.73 (c) to allow eligibility for issuing ofa Commercial Pilot Certificate based on training completed when militarypilot ofthe Armed Forces ofa foreign contracting State assigned to pilot duties for flight training. 1. Sections from which exemptions are sought: Application is herebymade for exemption from: 61.73 (c). 2. Reliefsought: Iwas a Italian Navy Officer enrolled in the US NAVY flight program. I GRADUATED from both Fixed Wing Trainingwhile assigned to VT-31 NAS CORPUS CHRISTI, TX and was DESIGNATED NAVAL AVIATOR on MAY 2008. After that I was assigned to Helicopter Squadron Training 8 NAS WHITING FIELD and designated RotaryWing Pilot in MARCH 2009. I have been a PERMANENT RESIDENT ofthe United States since JANUARY 2013 and I'm in the process to become a CITIZEN.This171reliefis sought as an opportunityto receive a Commercial Pilot Licence with Instrument Rating for both Airplane and Helicopter having completed the same training as the US NAVY pilots and having modified my status becoming a US PERMANENT RESIDENT and being in the process to become a CITIZEN. Recognition ofthese certificates will permit me to startto work in the USA as a commercial pilot.

3. Publicbenefit:

a. By obtaining this certificate Iwill be able to obtain a Commercial Pilot Certificate giving me the opportunityto be hired by a helicopter /airplane companies and to perform Search and Rescue, Air Evacuation and transport duties serving the country with my 10+ years ofmilitaryflight experience overseas in international missions and deployments. b. Obtaining the certificate based on my previous training will also be a crucial part ofmy application to the US NAVY RESERVE DIRECT COMMISSIONING PROGRAM as a specific skill thatwill allow me to serve in the United States Navy as the only form ofcommission that I can apply for due to my age. 4. Safety: The safety ofthe rule in question will remain untouched. As stated by previous meeting atvarious FSDOs (Birmingham, AL/Long Beach, CA/ Helena, MT) all the documentation that I presented shows that Imetthe requirements for the issue of the licenses (Logbook, Designation letters) and that Ipassed the Military CompetencyTest as stated bythe PSI Test Report. 5. Additional Information: I believe an exemption to this rule could be permitted since itwas explained to me thatthis rule has been writtenthis wayto avoid non-legal immigrants to be granted a pilot certificate in the States as a matter ofsecuritythrough the application ofthe directives included in the PatriotAct. My situation is now different than my situation atthe moment oftraining. My change ofstatus started with my application for permanentresidency (in 2012) and now goes on with the application submitted to become a citizen ofthe United States ofAmerica (2015). I, in fact, understand the importance ofbecoming a legal immigrantbefore applying for this exception. In my application to USCIS for legal immigration, Iwas asked whatjob Iwill do and what I could do to benefit the United States once I become a resident. I answered that Iwish to work in the aeronautical business and become an active part ofthis country's development in the aeronautical industry. In orderto do so, Iwould like to be granted credits for the training given me by the United States Navy in this very same country. I can presentto any FSDO designation letters as a NAVAL AVIATOR and bothAirplane and Helicopter Pilot designation letters. I can also showproofof graduation from United States Navy Flight Training Program, the same one completed by wife, Jenna Amber Epifanio, a citizen and an active US Naval Aviator herself, thatgraduated in my same class and through which she obtained a Commercial Pilot Certificate with Instrument Rating for both Airplane and Helicopter. ,'·:
I can showproofofpassing a Test ofEnglish in Aviation with the maximum score. This test, as you know, is recognized throughoutthe world. My score was 6/6 which means that Ihave validated the testfor the rest of mylife. I can also provide a current aeronautical medical certificate and proofofall the flight hours and qualifications received after completing US Naval Flight School. For all this I am wishing to be granted an exception to this rule, this will allow me to applyfor US NAVY RESERVE DIRECT COMMISSIONING PROGRAM which requires an officially documented specific setofskills (FLIGHT LICENCES) and it's the onlyprogram I can applyto be able to serve in the United StatesArmed Forces due passingthe age limitfor the other commissioning sources. Thanks for your time.

AIR OPERATIONS, PSC 812 BOX 1675, FPO AE 0927-0017 Cell: +39 3468766902 Email: marcob@gmail.com