AFS-15-3362-E

September 24, 2015

 Exemption No. 13047

 Regulatory Docket No. FAA-2008-0904

Mr. Kurt M. Kamrad

Vice President Flight Operations

Miami Air International

P.O. Box 660880

Miami, FL 33266

Dear Mr. Kamrad:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By date posted July 29, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Miami Air International (Miami Air) for an extension of Exemption No. 9757. That 

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

Air 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. That exemption, however, expired on May 31, 2015; therefore, we will treat 

your request as a new petition.

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

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Miami Air.

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 8054 (copy enclosed), the FAA 
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found that subject to certain conditions and limitations, the requirement for an FAA inspector 

to observe a qualifying PIC before he/she begins operations in an airplane unsupervised may 

be conducted by and satisfied by the certificate holder’s check airman or aircrew program 

designee. The FAA found that this could be accomplished without reducing the level of 

safety provided by the regulation.

Having reviewed your reasons for requesting an exemption, I find that—

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 8054;

• the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 8054 also 

apply to the situation you present; and 

• a grant of exemption is in the public interest.

Our Decision

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Miami Air International an exemption from 

14 CFR § 121.434(c)(1)(ii) to the extent necessary to allow Miami Air 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 

described below.

Conditions and Limitations 

1. A Miami Air 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. Miami Air, therefore, must contact an appropriate FAA office, in 

each instance, before substituting that check airman or aircrew program 

designee;

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 Miami Air check airman or aircrew program designee conducting a PIC 

observation in place of an FAA inspector must––
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a. Be approved by the Administrator to conduct the observation;

b. Have served as a check airman or aircrew program designee for Miami Air 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.

3. Miami Air must maintain student, check airman, and aircrew program designee 

records that demonstrate compliance with the conditions and limitations of this 

exemption.

This exemption terminates on September 30, 2018, unless sooner superseded or rescinded.

Sincerely,

/s/

John Barbagallo

Deputy Director, Flight Standards Service

Enclosure