U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E: 

Washington, DC 20590 

Petition for Exemption Under 14 CFR 61.73(c) 

to Allow Eligibility for Issuing of a 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 of a Commercial Pilot Certificate based on training completed 

when military pilot of the Armed Forces of a foreign contracting State assigned to 

pilot duties for flight training. 

1. Sections from which exemptions are sought: 

Application is hereby made for exemption from: 

61.73 (c). 

2. Relief sought: 

I was a Italian Navy Officer enrolled in the US NAVY flight program. I GRADUATED 

from both Fixed Wing Training while 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 Rotary Wing 

Pilot in MARCH 2009. 

I have been a PERMANENT RESIDENT of the United States since JANUARY 2013 and 

I'm in the process to become a CITIZEN. 
This171reliefis sought as an opportunity to 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 of these certificates will permit me to start to work in the USA as a 

commercial pilot. 

3. Public benefit: 

a. By obtaining this certificate I will be able to obtain a Commercial Pilot Certificate 

giving me the opportunity to be hired by a helicopter /airplane companies and to 

perform Search and Rescue, Air Evacuation and transport duties serving the country 

with my 1 0+ years of military flight experience overseas in international missions 

and deployments. 

b. Obtaining the certificate based on my previous training will also be a crucial part 

of my application to the US NAVY RESERVE DIRECT COMMISSIONING PROGRAM 

as a specific skill that will allow me to serve in the United States Navy as the only 

form of commission that I can apply for due to my age. 

4. Safety: 

The safety of the rule in question will remain untouched. As stated by previous 

meeting at various FSDOs (Birmingham, AL/Long Beach, CA/ Helena, MT) all the 

documentation that I presented shows that I met the requirements for the issue of 

the licenses (Logbook, Designation letters) and that I passed the Military 

Competency Test as stated by the PSI Test Report. 

5. Additional Information: 

I believe an exemption to this rule could be permitted since it was explained to me 

that this rule has been written this way to avoid non-legal immigrants to be granted 

a pilot certificate in the States as a matter of security through the application of the 

directives included in the Patriot Act. 

My situation is now different than my situation at the moment of training. My 

change of status started with my application for permanent residency (in 2012) and 

now goes on with the application submitted to become a citizen of the United States 

of America (2015). 

I, in fact, understand the importance of becoming a legal immigrant before applying 

for this exception. In my application to USCIS for legal immigration, I was asked 

what job I will do and what I could do to benefit the United States once I become a 

resident. I answered that I wish to work in the aeronautical business and become an 

active part of this country's development in the aeronautical industry. In order to 

do so, I would like to be granted credits for the training given me by the United 

States Navy in this very same country. 

I can present to any FSDO designation letters as a NAVAL AVIATOR and both 
Airplane and Helicopter Pilot designation letters. I can also show proof of 

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, that graduated in my same class and through which she obtained a 

Commercial Pilot Certificate with Instrument Rating for both Airplane and 

Helicopter. 

,'·: 

I can show proof of passing a Test of English in Aviation with the maximum score. 

This test, as you know, is recognized throughout the world. My score was 6/6 which 

means that I have validated the test for the rest of my life. 

I can also provide a current aeronautical medical certificate and proof of all 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 

apply for US NAVY RESERVE DIRECT COMMISSIONING PROGRAM which 

requires an officially documented specific set of skills (FLIGHT LICENCES) and 

it's the only program I can apply to be able to serve in the United States Armed 

Forces due passing the age limit for 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