AFS-15-3351-E

September 24 2015

 Exemption No. 8644E

 Regulatory Docket No. FAA-2005-22497

Mr. Robert E. Zeng

Director of Operations

Omni Air International

3303 N. Sheridan Road

Tulsa, OK 74115

Dear Mr. Zeng:

This letter is to inform you that we have granted your petition to extend Exemption 

No. 8644, as amended. It explains the basis for our decision, describes its effect, and lists the 

conditions and limitations.

The Basis for Our Decision

By letter dated June 30, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Omni Air International (OAI) for an extension of Exemption No. 8644, as amended. 

That exemption from § 121.434(c)(1)(ii) of Title 14, Code of Federal Regulations (14 CFR)

allows OAI to substitute a qualified and authorized check airman or aircrew program designee 

for an FAA inspector to observe a qualifying pilot in command (PIC) who is completing 

initial or upgrade training specified in § 121.424 during at least one flight leg that includes a 

takeoff and a landing. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to OAI.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 8644, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 

under the authority provided by 49 U.S.C. § 106(f), 40113 and 44701 which the FAA 

Administrator has delegated to me, Omni Air International is granted an extension to 

Exemption No. 8644 for § 121.434(c)(1)(ii) that allows OAI to substitute a qualified and 

authorized check airman or aircrew program designee for an FAA inspector to observe a PIC 

who is completing initial or upgrade training specified in § 121.424 during at least one flight 

leg that includes a takeoff and a landing, subject to the conditions and limitations listed below.

Conditions and Limitations

1. An OAI check airman or aircrew program designee may conduct a PIC observation in 

place of an FAA inspector when—

a. The Administrator preapproves that substitution for each observation of a 

qualifying PIC candidate, thus reserving first right of refusal to the FAA in 

each case;

b. The qualifying PIC candidate has completed no less than 10 hours of 

supervised operating experience (OE) and accomplished no fewer than two 

takeoffs and landings; and

c. The qualifying PIC candidate is performing PIC duties during a complete flight 

leg, including flightdeck preparation, before starting engines checklist, taxi, 

takeoff, all other flight phases, landing, taxi, and securing checklist.

2. Each OAI check airman or aircrew program designee conducting a PIC observation in 

place of an FAA inspector must—

a. Be approved by the Administrator to conduct the observation;

b. Have served as check airman or aircrew designee for OAI for no less than 

6 months; and

c. Not supervise the OE or conduct the initial line check for the qualifying PIC 

candidate being observed.
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3. OAI must maintain student, check airman, and aircrew program designee records that 

demonstrate compliance with the conditions and limitations of this exemption.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 8644, as amended, to 

September 30, 2018, unless sooner superseded or rescinded. 

Sincerely,

/s/

John Barbagallo

Deputy Director, Flight Standards Service