# T i

l/15C0 FC /Gh►T T,?/t INING 6460 Lockheecl Drive Recicling, CA 96002 (530) 722-9419 Fax (530) 722-9420 www.IlSCOLISa.COn1
01 September 2014

US Department of Transportation Docket Operations West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590 RE: Petition for Exemption from 14 CFR §61.35(a)(2) and 14 CFR §61.156(b)

Dear Sir or Madam: IASCO Flight Training (IFT), holder of FAA Air Agency Certificate NN3S716L, and Civil Aviation Administration of China (CAAC) Pilot School Certificate V26R6, requests exemption from 14 CFR §61.35(a)(2) and 14 CFR §61.156(b) for students who are Chinese nationals and who graduate from IFT's CAAC-approved Professional Pilot Certification Courses (PPCC).

Relief: Reasons and Extent Since 2009 IFT has conducted training under FAA Part 141 and CAAC Part 141 for Chinese nationals whose training is sponsored by an airline in China. Some cadets are employees, while others are students with conditional offers of employment, and employment contracts with their sponsoring airline. AII of IFT's courses for Chinese airline-sponsored cadets are dual-approved by both civil aviation authorities, which allow the pilots a direct conversion of their pilot certificates once they return to China. The PPCC culminates with airline operations instruction, which includes:

• 147 hours of turbine transition ground school that covers all of the knowledge areas required by 14 CFR §61.156(a), but even more topics and in much greater detail; • 45 hours of airline transport pilot knowledge test preparation ground school (and ATP FAA Knowledge Test);

• 20 hours of turbine transition flight training in a Beechcraft King Air C-90.
IFT's PPCC does 

### not

include an ATP practical test. Cadets only take the ATP knowledge test in the USA, then complete training with their sponsoring airline in China. That training consists of a typical airline ground school followed by flight simulator training (in a Level C or D B737 or A320), and an airline transport pilot practical test and SIC type rating check with the CAAC. Also, the PPCC(CAAC) is not given to any other type of student from any other country for any reason.

### l VOY

l/15C0 FC/GHT TR/1/N/NG 6460 Lockheecl Drive Reciding, CA 96002 (530) 722-9419 Fax (530) 722-9420 www. iascousa.coni IFT seeks relief from the aforementioned regulations for its Chinese cadets because of contractual and CAAC regulatory obligations requiring completion of the FAA ATP Part 121 Knowledge Test as part of the training program conducted in the USA. IFT requests that these cadets be allowed to: • Enroll in, and graduation from, an FAA Part 141 ATP ground school that meets the requirements of Part 141 Appendix L;• Attempt the FAA Airline Transport Pilot (Part 121) Knowledge Test (now known as the ATP MultiEngine Airplane Knowledge Test).

Public Benefit IFT employs over 80 people in professional, technical, and administrative jobs, and provides a pathway for instructors to transition to career pilot positions. Along with job creation at IFT, our vendors and suppliers also experience increased business in fuel sales, parts sales and repairs, and aviation text publishers and distributers. Moreover, each student spends thousands of dollars towards living and recreation costs while they are here, which drives the economy further. It is reasonable to estimate that CAAC-approved flight schools in the United States (currently 12 schools) inject in excess of 200 million dollars of new money into the US economy, as well as create thousands of jobs from the direct result, or support of, Chinese pilot training programs. For Redding, California, the local economy is especially affected: according to the California Employment Development Department, Shasta County had an unemployment rate of 9.2% as of July, 2014. IFT's program provides pilots for airlines flying Boeing (and Airbus) equiprnent, which directly impact's the airlines' ability fill cockpits with qualified crew members. Indirectly, it also affects the manufacturers' ability to sell airplanes. Without qualified pilots to fly the aircraft already on order, airlines will have to delay delivery of aircraft if they cannot train more pilots in a timely manner due to regulations. Without an exemption to the requested rules, these impacts are certainly at risk, as the Chinese airline customers seek the services of pilot schools in other countries (currently in Australia, Canada, and France).

Safety Impact The exemption will have no effects on flight safety in any way because students only complete a ground course. They do not receive enough flight hours to meet the aeronautical experience requirements for an ATP practical test while they are in IFT's program, nor do they receive ATP-specific flight training. Granting the exemption will allow IFT to continue to provide Chinese PPCC students with comprehensive training in turbine and airline transport pilot principles and operations in accordance with the knowledge areas required by §61.156(a) and Part 141 Appendix L for an ATP ground course. In addition, IFT's Turbine Transition Course and ATP Ground Course exceed the minimum hours required by relevant regulations.

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l/15C0 FC/GHT TR/1 /N/NG 6460 Lockheed Drive Redd i ng, CA 96002 (530) 722-9419 Fax (530) 722-9420 wwW. iaSCOUSa.conl 

### Summary IFT seeks exemption from 14 CFR §61.35(a)(2) and §61.156(b) for students who are Chinese nationals and who graduate from IFT's FAA and CAAC-approved Professional Pilot Certification Courses . If and when granted, the exemption will allow said students to attempt the FAA ATP (Part 121) Knowledge Test without meeting the flight simulation training device (FSTD) requirements of §61.35(a)(2) and §61.156(b). The exemption is needed to continue providing contractual services for Chinese airlines that need cadets to complete the ATP (Part 121) knowledge test prior to commencing airline training in China.

Sincerely,



# , Jeff Mallory Director, Training Operations & Curriculum IASCO Flight Training 6460 Lockheed Drive Redding, CA 96002 530.722.9419 x106 jmallory@iascousa.com