•._October 23, 2015 USA Jet Airlines 2068 E StreetBelleville, MI 48111 U.S. Department of Transportation Federal Aviation Administration 800 Independence Ave. SW Washington, DC 20591 ,-,**-~** Re: USA Jet Airlines seeks exemption for14 CFR 121.436(a)(3) USA Jet Airlines is seeking relief from the provisions of14 CFR 121.436(a)(3) to allow USA Jet airlines to apply flight time accrued as Pilot in Command (PIC) ofa turbojet airplane engaged inPart 135 Eligible On-Demand cargo operations toward the requirement of 1,000 hours ofair carrier experience to serve asapart 121 PIC. The extent USA Jet Airlines seeks relief, and the reason itis being sought USA Jet Airlines seeks an Alternate Method of Compliance (AMOC) in meeting the intent of14 CFR 121.436(a)(3). PICs operating our Falcon Jet DA-20 aircraft meet and exceed allthe requirements of14 CFR 135.243(a)(1), even though weare operating for

cargo only. This AMOC and exemption to14 CFR Part 121.436(a)(3) would be based upon the following factual data:

- USA Jet Airlines isan all-cargo 14 CFR 121 Supplemental Air Carrier. - All DA-20 PICs are required to have an Airline Transport Pilot (ATP) byOp Spec A-057 to conduct Eligible On-Demand Operations per14 CFR 135.4(ii)(A) and thisis listed asa requirement inour FAA approved Flight Operations Training Manual (FOTM) and General Operations Manual (GOM). - USA Jet Airlines is authorized bythe Administrator, per14 CFR 135.3(c) to comply with the applicable sections of subparts Nand 0of14 CFR 121 instead of the requirements of subparts E,G,andHof14 CFR 135. - DA-20 PICs and Second in Commands (SICs) are trained to121 standards under 121 sub parts Nand 0,all DA-20 proficiency checks are done under the guidance

of121 Appendix F,and qualifications are completed with 121 appendix H Line Oriented Flight Training (LOFTs). - The USA Jet DA-20 PIC's train toa higher standard than those required ofpart 135 passenger carrying operations referenced inpart 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 anew requirement foraPICinpart 121 operations to have 1,000 hours of experience inair carrier operations. Inthe preamble tothe final rule, the FAA addressed comments on what type of flight time should count forthe 1,000 hours of experience inair carrier operations. The FAA stated it determined that the ability toflyatthe airline transport pilot (ATP) certification level and have demonstrated this proficiency during evaluation isan 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 ATP certificate in 1977. Inthat NPRM, the FAA stated the requirement to hold an ATP certificate toactasPICin some part 135 operations was" ... based inpart on operational complexity and the number of persons carried, would provide alevel of safety more comparable tothat 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, arethe most comparable topart 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 PICto 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 bythe Administrator per14 CFR 135.3(c) to comply with the applicable sections of subparts Nand 0of14 CFR 121 instead ofthe requirements of subparts E,G,andHof14 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 to121 standards under 121 sub parts Nand 0,all DA-20 proficiency checks are done under the guidance of121 Appendix F,and qualifications are completed with 121 appendix H Line Oriented Flight Training (LOFTs). The FAA determined that, while other part 91and part 135 operations may involve certain elements that are relatable topart 121 operations, the varied nature of operations does not make credit toward the 1,000 hour requirement appropriate. Because turbojet pilots inpart 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 PICto hold an ATP with the appropriate type rating and the SICto holda commercial and instrument rating with 500 hours minimum. 135.4(a)(1)(2)(i)(ii) and 135.243(a)(1) have the same requirements forthe PIC but 135.4(a)(1)(2)(i)(ii) is more restrictive requiring the SICto havea minimum of500 hours. USA Jet Airlines is authorized bythe Administrator per14 CFR 135.3(c) to comply with the applicable sections of subparts Nand 0of14 CFR 121 instead ofthe requirements of subparts E,G,andHof14 CFR 135. DA-20 PICs and Second in Commands (SICs) are trained to121 standards

under 121 sub parts Nand 0,all DA-20 proficiency checks are done under the guidance of121 Appendix F,and qualifications are completed with 121 appendix H Line Oriented Flight Training (LOFTs). The reasons why granting this request would beinthe public interest USA Jet Airlines isan 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 ofour DA-20 Falcon Jet Aircraft. USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 734-54 7-7200-... sA**J~::)­ ~-** **-t~4/"' ~;;;;E\** **~~- {:/~f1(9**  ""-....l __**,1.--'~~** '11 11Ltt-l The exemption requested will permit USA Jet Airlines to meet and exceed the intent of

14 CFR 121.436(a)(3), andto continue on meeting the necessary logistics requirements ofthe 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 ofthis industry will be threatened ifthis exemption isnot granted. This exemption would allow USA Jet Airlines to continue to support public interest by augmenting the auto and agricultural industry's supply chain sothat minimal interruptions occur that would cause, assembly line shut downs, possible employee layoffs, and the potential ofthe 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 JetasPICtothe DC-9 as PIC. These pilots routinely made the transition tothe DC-9 with no training difficulties. USA Jet Airlines hasa track record of success with this process. Present rules permit apilot 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 of14 CFR 135.4(a)(1)(2)(i)(ii) meet or exceed the requirements of14 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 of14 CFR 135.243(a)(l)) - PIC hasa minimum of 1,500 hours (Meets the requirements of14 CFR 135.243(a)(l)) - PIC holds an ATP with applicable type rating (Meets the requirements of14 CFR 135.243(a)(1 )) SIC hasa minimum of500 hours(Exceeds the requirements of14 CFR 135.243(a)(1 )) SICisa commercial pilot with an instrument rating (Meets the requirements of14 CFR 135.243(a)(1)) USA Jet Airlines trains and checks all DA-20 pilots per14 CFR 135.3(c) under 14 CFR

121 regulations that meets or exceed the training and checking requirements of14 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•VL1IIIIP 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 fora14 CFR part 121 air carrier to include basic indoctrination, general emergency, security, hazardous materials and international procedures. These courses areall 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 inthe 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 and36 hours oflevel "D" DA-20 Falcon simulator training. The simulator isdry 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) aspart ofits DA-20 Falcon training program. All DA-20 PICs are required to attend aone day Command Authority Leadership and Management (CALM) class that stresses the role ofthe captain ina multicrewed environment. DA-20 Falcon pilots are required to complete 25 hours of supervised operating experience (OE) before being released toline operations. Both SICs and PICs are required to attend Level D simulator training twice ayear to reinforce multi-crew training standards.Providing advanced simulator training for First Officers ona semi-annual basis exceeds current FAR 121 and135 standards and reinforces multi -crew operation concepts. The USA Jet Airlines ATP rated DA-20 PICs are well-trained multi-crew PICs who area product ofa highly structured intense training program that meets allthe requirements of part 121 training and checking. USA JET AIRLINES. ·2068 E STREET · BELLEVILLE, MI 48111 734-547-7200A summary we can publish inthe Federal Register Description ofReliefSought: USA Jet Airlines seeks relief from 121.436(a)(3) to allow the flight time gained asa DA-20 PIC operating under 14 CFR 135.4(a)(1)(2)(i)(ii) and trained and checked under 14 CFR part 121tobe included inthe flight time requirements of14 CFR 121.436(a)(3). This relief would be based upon a proposed AMOC to allow credit forthe 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/AThe reason USA Jet Airlines needs to exercise the privileges ofthis exemption outside ofthe United States. Itis requested that this exemption include operations outside ofthe United States providing economic benefits toall NAFTA states. Cargo operations in support ofUS based manufacturers routinely take place outside ofthe 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 donot hesitate to contact meifyou have any questions or concerns. Sincerely,**~~** Craig HuntDirector of Operations USA Jet Airlines chunt@usajet.aeroOffice 734-547-7247

Fax 734-547-7392 USA JET AIRLINES.· 2068 E STREET· BELLEVILLE, MI 48111 734-547-7200