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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. 
/ 

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