niCHOLAS AIR 

INNOVATIVE PRIVATE AIR TRAVEL® 

Marvin Baird --!I 

Director of Operations 

Nicholas Services, LLC 

Columbus, MS 39701 

866-935-7771 Ext. 31 

marvinb@nicholasair.com 

Docket Management Facility US Department of Transportation 

1200 New Jersey Avenue 

SE West Building Ground Floor Room Wl2-140 

Washington, D.C. 20590 

To Whom It May Concern: 

I am seeking relief from 14 CFR Part 61.51 (f)(2), which specifically states that: a person 

may log second-in-command time only for that flight time during which that person: (2) 

holds the appropriate category, class, and instrument rating ... for the aircraft being 

flown, and more than one pilot is requiredunder the' type certification ofthe aircraft or 

the regulations under which the flight 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 of an SIC program will only serve to strengthen this 

commitment. A fully trained and checked SIC will enhance the level of safety by 

providing a second set of eyes and an informed perspective during all phases of flight 

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 of safety in not only flights conducted by Nicholas Services, but 

will increase the level of safety attainable in the future endeavors of flight crews who are 

operating with two pilot crews. 

Nicholas Services feels that the incorporation of an SIC program into normal operations 

would serve the public interest in several viable ways. It will serve to promote a positive 

safety culture within our organization. It will be a direct benefit of our Pilot in 

Commands (PIC) as they will have the opportunity to mentor and direct the development 

of younger, less experienced pilots. This program will allow SICs to gain applicable 

flight experience that is directly related to their chosen carrier path. 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 opportunity to build applicable flight 

P.O. Box 8889 Columbus, MS 39705 86G.935.7771 I FAX: 662.297.7083 I www.nicholasair.com 
time that could be directly applied to the obtainment of an Airline Transport Pilot (ATP) 

license. 

In the event that this petition is granted, Nicholas Services would agree to the following 

conditions: 

1. SICs operating under 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 hour requirement 

of current Part 61 and 135 rules. 

3. Prior to assignment, SICs would successfully complete Nicholas 

Service's approved Basic Indoctrination, General Subjects, 

Aircraft Specific, and SIC training programs. 

4. SICs would be issued specific duties as set forth in Nicholas 

Services General Operations Manual. 

5. Nicholas Services will maintain records of SICs being utilized for 

flight operations. 

The granting of this petition does not constitute a requirement for Nicholas Services to 

assign a SIC other than 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 otherwise require an SIC and also to allow the SIC to log that 

flight time. 

Nicholas Services does, from time to time, operate outside of the United States. As this is 

a small, but growing, percentage of our business, I am also requesting the exemption 

from 14 CPR Part 61.51 ( f)(2) be applied to international operations. 

Within the limits ofPAA policy, Nicholas Services is ready to discuss, clarify, or amend 

this petition, and to consider any adjustments that might better address agency 

requirements in this matter. 

Thank you for time and consideration, 

Marvin Baird 

Nicholas Services, LLC 

Director of Operations 

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