# niCHOLAS 

# AIR INNOVATIVE PRIVATE AIR TRAVEL®
Marvin Baird --!I Director ofOperations Nicholas Services, LLC Columbus, MS 39701 866-935-7771 Ext. 31 marvinb@nicholasair.com Docket Management FacilityUS Department ofTransportation 1200 New Jersey Avenue SE West Building Ground Floor Room Wl2-140 Washington, D.C. 20590
To Whom It May Concern:
I am seekingrelieffrom 14 CFR Part 61.51 (f)(2), which specifically states that: aperson may log second-in-command time only for that flight time during which thatperson: (2) holds the appropriate category, class, and instrument rating

...for the aircraft being flown, andmorethan onepilot is requiredunder the'type certification ofthe aircraft or

the regulations under which theflight is being conducted. , I am requesting that Nicholas Services, LLCbe allowed to assign a second'

### in command (SIC) during a flight that does not otherwise require an SIC and also to allow the SIC to log that flight time. Nicholas Services is committed to fostering and furthering a strong safety culture. We believe that the incorporation ofan SIC program will only serve to strengthen this commitment. A fully trained and checked SIC will enhance the level ofsafetyby providing a second set ofeyes and an informed perspective during all phases offlight activities. Additionally, this will allow both crew members to develop and hone their crew resource management (CRM) and standardization skills. These skills are invaluable to increasing the level ofsafetyin not only flights conductedbyNicholas Services, but will increase the level ofsafety attainable in the future endeavors offlight crews who are operating with two pilot crews. Nicholas Services feels that the incorporation ofan SIC program into normal operations would serve the public interest in several viable ways. Itwill serve to promote a positive safety culture within our organization. Itwill be a directbenefit ofour Pilot in Commands (PIC) as they will have the opportunity to mentor and direct the development ofyounger, less experienced pilots. This program will allow SICs to gain applicable flight experience that is directly related to their chosen carrierpath. Ideally, SICs would be able to transition smoothly into a position as a PIC and, in tum, begin to mentor**~ICs** themselves. Additionally, this will allow**SI~s** the opportunityto build applicable flight

P.O. Box 8889 Columbus, MS 39705 86G.935.7771 I FAX: 662.297.7083 I www.nicholasair.comtime that couldbedirectly applied to the obtainment ofan Airline Transport Pilot (ATP) license.
In the eventthat this petition is granted, Nicholas Services would agree to the following conditions: 1. SICs operatingunder these provisions would hold a Commercial Pilot certificate with Airplane Multi-engine Land and Instrument Airplane ratings is accordance with§ 135.245(a). 2. SICs would meet any applicable minimum flight hourrequirement ofcurrent Part 61 and 135 rules. 3. Priorto assignment, SICs would successfully completeNicholas Service's approved Basic Indoctrination, General Subjects, Aircraft Specific, and SIC trainingprograms. 4. SICs would beissued specific duties as set forth inNicholas Services General Operations Manual. 5. Nicholas Services will maintain records ofSICs beingutilized for flight operations. The granting ofthis petition does not constitute a requirement for Nicholas Services to assign a SIC otherthan as specified in applicable regulations. Summary Nicholas Services, LLC is seeking exemption from 14 CPR Part 61.51 (f)(2) and requesting that Nicholas Services, LLC be allowed to assign a second in command (SIC) during a flight that does not otherwiserequire an SIC and also to allow the SIC to logthat flight time. Nicholas Services does, from time to time, operate outside ofthe United States. As this is a small, but growing, percentage ofourbusiness, I am also requesting the exemption from 14 CPR Part 61.51 (f)(2) be applied to international operations. Within the limits ofPAApolicy, Nicholas Services is ready to discuss, clarify, or amend this petition, and to consider any adjustments that mightbetter address agency requirements in this matter. Thank you for time and consideration,

Marvin Baird Nicholas Services, LLC Director ofOperations

P.O. Box 8889 Columbus, MS 39705 I 866.935.7771 I FAX: 662.297.7083 I www.nicholasair.com