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October 23, 2015 

USA Jet Airlines 

2068 E Street 

Belleville, MI 48111 

U.S. Department of Transportation 

Federal Aviation Administration 

800 Independence Ave. SW 

Washington, DC 20591 

,-, -~ 

Re: USA Jet Airlines seeks exemption for 14 CFR 121.436(a)(3) 

USA Jet Airlines is seeking relief from the provisions of 14 CFR 121.436(a)(3) to allow 

USA Jet airlines to apply flight time accrued as Pilot in Command (PIC) of a turbojet 

airplane engaged in Part 135 Eligible On-Demand cargo operations toward the 

requirement of 1,000 hours of air carrier experience to serve as a part 121 PIC. 

The extent USA Jet Airlines seeks relief, and the reason it is being sought 

USA Jet Airlines seeks an Alternate Method of Compliance (AMOC) in meeting the 

intent of 14 CFR 121.436(a)(3). PICs operating our Falcon Jet DA-20 aircraft meet and 

exceed all the requirements of 14 CFR 135.243(a)(1), even though we are operating for 

cargo only. This AMOC and exemption to 14 CFR Part 121.436(a)(3) would be based 

upon the following factual data: 

- USA Jet Airlines is an all-cargo 14 CFR 121 Supplemental Air Carrier. 

- All DA-20 PICs are required to have an Airline Transport Pilot (ATP) by Op Spec 

A-057 to conduct Eligible On-Demand Operations per 14 CFR 135.4(ii)(A) and 

this is listed as a requirement in our FAA approved Flight Operations Training 

Manual (FOTM) and General Operations Manual (GOM). 

- USA Jet Airlines is authorized by the Administrator, per 14 CFR 135.3(c) to 

comply with the applicable sections of subparts Nand 0 of 14 CFR 121 instead of 

the requirements of subparts E, G, and H of 14 CFR 13 5. 

- DA-20 PICs and Second in Commands (SICs) are trained to 121 standards under 

121 sub parts Nand 0, all DA-20 proficiency checks are done under the guidance 

of 121 Appendix F, and qualifications are completed with 121 appendix H Line 

Oriented Flight Training (LOFTs). 

- The USA Jet DA-20 PIC's train to a higher standard than those required of part 135 

passenger carrying operations referenced in part 135.243(a)(1). 

USA JET AIRLINES. · 2068 E STREET · BELLEVILLE, MI 48111 

734-547-7200 
... 

The Following are reasons the FAA has denied the request for exemption from 

other air carriers, and USA Jet Airlines' responses: 

Issue 1. 

The FAA issued the Pilot Certification and Qualification Requirements for Air 

Carrier Operations final rule 15, 2013 (78 FR 42324), creating a new requirement 

for a PIC in part 121 operations to have 1,000 hours of experience in air carrier 

operations. In the preamble to the final rule, the FAA addressed comments on 

what type of flight time should count for the 1,000 hours of experience in air 

carrier operations. The FAA stated it determined that the ability to fly at the 

airline transport pilot (ATP) certification level and have demonstrated this 

proficiency during evaluation is an important regulatory differentiation. 

USA Jet Airlines' Response 

Issue 2. 

USA Jet airlines DA-20 Falcon PICs must have an ATP and demonstrate this 

proficiency during evaluation per CFR 135.4(ii)(A) and Op Spec A-057. 

The FAA first proposed that certain operations under part 135 should require an 

A TP certificate in 1977. In that NPRM, the FAA stated the requirement to hold an 

ATP certificate to act as PIC in some part 135 operations was" ... based in part on 

operational complexity and the number of persons carried, would provide a level 

of safety more comparable to that provided by part 121." The FAA still maintains 

this position. Operations under§ 91.1053(a)(2)(i) or§ 135.243(a)(1) require an 

ATP certificate, are multi-crew operations, generally use turbine aircraft, and 

therefore, are the most comparable to part 121 operations. 

USA Jet Airlines' Response 

USA Jet Airlines operates the DA-20 Falcon under CFR 135.4(a)(1)(2)(i)(ii) 

that requires two pilots (multi-crew), the PIC to have at least 1,500 hours of 

flight time, and for multi-engine turbine powered fixed wing aircraft (DA-20 

Falcon) the PIC must have an ATP and type rating. 

USA Jet Airlines is authorized by the Administrator per 14 CFR 135.3(c) to 

comply with the applicable sections of subparts Nand 0 of 14 CFR 121 

instead ofthe requirements of subparts E, G, and H of 14 CFR 135. 

USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 

734-547-7200 
... 

Issue 3. 

DA-20 PICs and Second in Commands (SICs) are trained to 121 standards 

under 121 sub parts Nand 0, all DA-20 proficiency checks are done under the 

guidance of 121 Appendix F, and qualifications are completed with 121 

appendix H Line Oriented Flight Training (LOFTs). 

The FAA determined that, while other part 91 and part 135 operations may 

involve certain elements that are relatable to part 121 operations, the varied nature 

of operations does not make credit toward the 1,000 hour requirement 

appropriate. Because turbojet pilots in part 135 cargo operations are not required 

to hold an ATP certificate, the time accrued in such operations does not count 

toward the requirements of§ 121.436(a)(3). 

USA Jet Airlines' Response 

USA Jet Airlines operates our DA-20 Falcon in accordance with 

135.4(a)(1)(2)(i)(ii). These operations are very specific and require the PIC to 

hold an ATP with the appropriate type rating and the SIC to hold a 

commercial and instrument rating with 500 hours minimum. 

135.4(a)(1)(2)(i)(ii) and 135.243(a)(1) have the same requirements for the PIC 

but 135.4(a)(1)(2)(i)(ii) is more restrictive requiring the SIC to have a 

minimum of 500 hours. 

USA Jet Airlines is authorized by the Administrator per 14 CFR 135.3(c) to 

comply with the applicable sections of subparts Nand 0 of 14 CFR 121 

instead of the requirements of subparts E, G, and H of 14 CFR 135. 

DA-20 PICs and Second in Commands (SICs) are trained to 121 standards 

under 121 sub parts Nand 0, all DA-20 proficiency checks are done under the 

guidance of 121 Appendix F, and qualifications are completed with 121 

appendix H Line Oriented Flight Training (LOFTs). 

The reasons why granting this request would be in the public interest 

USA Jet Airlines is an on-demand cargo airline that operates DC-9, MD-80 and B-727 

aircraft in accordance with 14 CFR part 121. For many years, our DC-9 PICs gained 

valuable operational and leadership experience asPICs of our DA-20 Falcon Jet Aircraft. 

USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 

734-54 7-7200 
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The exemption requested will permit USA Jet Airlines to meet and exceed the intent of 

14 CFR 121.436(a)(3), and to continue on meeting the necessary logistics requirements 

of the North American auto and agricultural manufacturing industry. USA Jet Airlines is 

an important expedite airlift provider for this industry and has been recognized by leaders 

in these industries numerous times. The ability to meet the demands of this industry will 

be threatened if this exemption is not granted. This exemption would allow USA Jet 

Airlines to continue to support public interest by augmenting the auto and agricultural 

industry's supply chain so that minimal interruptions occur that would cause, assembly 

line shut downs, possible employee layoffs, and the potential of the on-demand air cargo 

airline jobs shifting from U.S. to foreign air carriers as industry looks for alternate 

sources of airlift capability. 

The reason why granting the exemption would not adversely affect safety. 

Before the change to the regulations regarding FAR 121 PIC qualifications, USA Jet 

Airlines regularly moved DA-20 PICs, pilots with less than the 1000 FAR 121 SIC 

required by 121.436(a)(3), from the DA-20 Falcon Jet as PIC to the DC-9 as PIC. These 

pilots routinely made the transition to the DC-9 with no training difficulties. USA Jet 

Airlines has a track record of success with this process. 

Present rules permit a pilot with 1000 hours of Part 135 PIC hours gained in passenger 

operations under Part 135.243(a)(l) to meet the requirements of Part 121.436(a)(3). 

The requirements of 14 CFR 135.4(a)(1)(2)(i)(ii) meet or exceed the requirements of 14 

CFR 135.243(a)(l) regarding flight crew qualifications/requirements. Essential elements 

of these qualifications/requirements include the following: 

- Two pilot crew (multi-crew)(Meets the requirements of 14 CFR 135.243(a)(l)) 

- PIC has a minimum of 1,500 hours (Meets the requirements of 14 CFR 

135.243(a)(l)) 

- PIC holds an ATP with applicable type rating (Meets the requirements of 14 CFR 

135.243(a)(1 )) 

SIC has a minimum of 500 hours(Exceeds the requirements of 14 CFR 

135.243(a)(1 )) 

SIC is a commercial pilot with an instrument rating (Meets the requirements of 14 

CFR 135.243(a)(1)) 

USA Jet Airlines trains and checks all DA-20 pilots per 14 CFR 135.3(c) under 14 CFR 

121 regulations that meets or exceed the training and checking requirements of 14 CFR 

135.243(a)(1). Essential elements ofthis training regime include the following: 

USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 

734-547-7200 
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All DA-20 Falcon pilots are required to complete a 104-hour 14 CFR part 121 

Initial Ground Training Program. This program includes all FAA mandated 

training for a 14 CFR part 121 air carrier to include basic indoctrination, general 

emergency, security, hazardous materials and international procedures. 

These courses are all taught by USA Jet Airlines line pilots who are thoroughly 

versed in USA Jet Airlines Standard Operating Procedures and have completed a 

FAA approved air carrier instructor training program. 

The pilots receive orientation training in airline operations to include flight release 

procedures, performance limitations, and international regulatory compliance. Part 

of their training includes spending time in the dispatch center to observe 

operations, crew management and flight following. 

The DA-20 Falcon pilots receive 8 hours of Crew Resource Management (CRM) 

training. This covers Communications, Aviation Decision Making, Pilot 

Monitoring duties and Threat and Error Management. These CRM skills are 

evaluated under a realistic line environment during FAA approved simulator LOFT 

sesswns 

DA-20 Falcon pilots, then, attend 66 hours ofDA-20 systems training and 36 hours 

oflevel "D" DA-20 Falcon simulator training. The simulator is dry leased and 

operated by company check airman and instructors who are versed in multi-crewed 

company SOP and USA Jet Airline operations. The simulator training includes all 

part 121 required events to include wind shear, controlled flight into terrain, and 

reduced vertical separation minimum operations, high altitude stall recovery, and 

low visibility taxi. 

- USA Jet Airlines conducts FAA approved 14 CFR part 121 Appendix F 

proficiency checks and Appendix H qualification Line Oriented Flight Training 

(LOFT) as part of its DA-20 Falcon training program. 

All DA-20 PICs are required to attend a one day Command Authority Leadership 

and Management (CALM) class that stresses the role of the captain in a multicrewed environment. 

DA-20 Falcon pilots are required to complete 25 hours of supervised operating 

experience (OE) before being released to line operations. Both SICs and PICs are 

required to attend Level D simulator training twice a year to reinforce multi-crew 

training standards. 

Providing advanced simulator training for First Officers on a semi-annual basis 

exceeds current FAR 121 and 13 5 standards and reinforces multi -crew operation 

concepts. 

The USA Jet Airlines ATP rated DA-20 PICs are well-trained multi-crew PICs who are a 

product of a highly structured intense training program that meets all the requirements of 

part 121 training and checking. 

USA JET AIRLINES. · 2068 E STREET · BELLEVILLE, MI 48111 

734-547-7200 
A summary we can publish in the Federal Register 

Description ofReliefSought: USA Jet Airlines seeks relief from 121.436(a)(3) to allow 

the flight time gained as a DA-20 PIC operating under 14 CFR 135.4(a)(1)(2)(i)(ii) and 

trained and checked under 14 CFR part 121 to be included in the flight time requirements 

of 14 CFR 121.436(a)(3). This relief would be based upon a proposed AMOC to allow 

credit for the certification requirements ofOp Spec A057, and also the Part 121 training 

and checking for pilots requiring an ATP and appropriate type rating flying in USA Jet 

Airlines' Part 135 Eligible On-Demand cargo operation. 

Any additional information 

N/A 

The reason USA Jet Airlines needs to exercise the privileges of this exemption 

outside of the United States. 

It is requested that this exemption include operations outside of the United States 

providing economic benefits to all NAFTA states. Cargo operations in support ofUS 

based manufacturers routinely take place outside of the United States. Pilots qualified 

under this AMOC will operate with an equivalent or higher level of safety than pilots 

qualifying under the current interpretation. 

Thank you for your consideration regarding this very important matter. Please do not 

hesitate to contact me if you have any questions or concerns. 

Sincerely, 

~~ Craig Hunt 

Director of Operations 

USA Jet Airlines 

chunt@usajet.aero 

Office 734-547-7247 

Fax 734-547-7392 

USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 

734-547-7200