Ms Ida Klepper 

Manager, Airmen and Airspace Rules Division 

Federal Aviation Administration 

800 Independence Avenue S.W 

Washington DC, 20591 

Dear Ms Klepper, 

Ref: Steven J RANDALL, ATP 2618972, FAR Exemption Requests 

2833 Alnwick Avenue, Unit 13 

Livermore, CA 94551 

Tuesday 24th January 2012 

First, let me apologize for the length of this letter, which detail the facts of my situation along with two 

exemption requests. 

On 27th May 2002, I passed my CFII flight test with FAA Designee Herb Barnes (E05-85-734293CFI). At 

the time, I was an active and very busy ferry pilot, delivering mainly GA aircraft all over the world for 

various brokers and manufacturers. I earned a reputation as a safe and reliable delivery pilot and as a 

result was asked to help teach new Atlantic/Oceanic delivery pilots before they flew the routes solo. I 

thought it best to acquire an instructor certificate and so arrived at Charis Air at Barnes Airport, MA in 

2002. Herb recommended that I train for a CFII only, as I would be teaching almost exclusively in the 

instrument erivironment•antf wotitd·ndfhlFtisinglity;iii!ititittot (>tMiegeS:td·conaucrany 'priniary · 

training. After checking·t'hannrs-was pb-sSio1i:hi.tltfi th·e%carFSDO',·l ·started m~rtrairliilg, .worked very 

hard and recei~ed my C::PII ceitifical~ (2b1897Lt~l) ffom.He.rb ... · · .· · · · · ·-- · 

In the following couple of years, I passed on my experience to many delivery pilots until joining Air 

Wisconsin Airlines' in 2004, to fly the-Cariadair Regional Jet. In 2005, I was selected to join the Training 

Department and began teaching new regional jet pilots. My ability to teach instrument flying lead to my 

appointment as a CL-65 Check Airman and then, on 23rd July 2007, an Airline Program Designee (APD2618972A6WA) which allowed me to issue CL-65 Type Ratings on behalf of the FAA. This was done 

under the authority of our FAA Principle Operations Inspector, Dan Balash. I continued flying the line as 

a Captain during this time. 

On 14th April 2008, I joined Virgin America Airlines as an A320/A319 pilot (becoming a line Captain in 

2010). 

The amount of instructicn I gave to'GA pilots using my CFII reduced while flying for the airlines, due to 

duty and flight time regulations. However, l ensured that I kept my hard earned certificate current. In 

2009, my wife, Andrea Goodnight, decided she would like to obtain her Private License and she passed 

her'flight test on 4th Septe'mb'er 2009 '(3436'221). I convinced my wife that her safety and proficiency as 

a pilot would increase enormdusl•/ifshea~ fCfed an lnstrurTI'enf rating te·her certificate. Finally, I could 

pass on ·my extensive instrumehtexpenencetd'her; soi'ne'tliirig that would be very satisfying and fun. 

"· .. . ··· 
My CFII was due to expire on 31st May 2010 and so I decided to sign up for an AOPA/ ASF seminar to 

renew my certificate. I attended the FIRC on 13th March 2010 in San Mateo, CA. During a review of 

regulation changes, our presenter mentioned that the 'FAA had stopped renewing CFII only certificates'. 

This shocked me and I asked for clarification. The presenter advised me that I could not be issued with a 

certificate, no grandfather rights existed and that I should consider starting over with a CFI certificate. I 

asked the presenter for a CFR reference and was advised that I could get this from ASF staff. 

For the next 11 weeks, I tried to get clarification from the AOPA/ ASF staff and finally received an 

interpretation of a ruling that did not make sense to my situation (FAR 61.195(b)&(c) re the Grayson 

interpretation, 4th January 2010). I sent e-mails to FAA contacts recommended to me by AOPA but did 

not receive a response, except for one standard 'on vacation' e-mail. 

On 31st May 2010, my certificate privileges expired. Some 10 days later, I received a telephone call from 

an official at the FAA in Washington DC. This person asked not to be named but stated that the 

interpretation by AOPA did not relate to my situation and that the renewal should have taken place at 

the ASF seminar. Confused, I began a journey with AOPA to try and correct this mistake and have my 

certificate privileges reinstated. Little did I know just how long and frustrating this process would 

become. For the past 18 months, I have pushed AOPA for progress and have a catalogue of 

communication, even including a promise of a renewal from an FAA inspector in March 2011 (something 

that didn't happen due to a transfer). 

AOPA have been supportive (Rodney Martz and Jonathan Greenway) but this misinterpretation has left 

me without the teaching privileges I worked so hard to gain. As a previous Type Rating Examiner for the 

FAA, instrument instructor, Check Airman and current Airbus line Captain, it seems absurd to allow this 

situation to continue any longer. As a result, AOPA have helped me to construct the following petitions 

to help correct this error. 

I thank you in advance for reviewing my situation and I trust that common sense will see a sensible 

conclusion of a long overdue renewal of my CFII privileges. I will, of course, be happy to attend another 

FIRC before my CFII certificate is formally renewed. Should you require any further information or 

clarification, kindly contact me at e-mail steve.randall@virginamerica.com, cell925-200-1417 (PST) or 

mail 2833 Alnwick Avenue #13, Livermore, CA 94551. 

Sincerely, / '' 

/ . 

Captain Steven J. Randall 

ATP 2618972 
1. FAR 11 PETITION FOR EXEMPTION (FAR 61.197) 

a. Captain Steven James Randall, 2833 Alnwick Ave unit 13, Livermore California, 94551 

b. I am requesting a one-time exemption from FAR 61.197 regarding flight instructor renewal-my 

attendance at the flight instructor renewal course (March, 2010, San Mateo Calif.) was cut short by the 

instructor who sent me away early, claiming, that I would not be able to instruct with the CFI-1 only. 

c. I seek relief simply to not have my CFi-1 expired from that time period. 

d. Public interest would be served by keeping the regulations valid: even if the new-at-the-time change 

to FAR 61.195c was not well understood by the instructor, I should have been allowed to complete the 

FIRC class for my future CFI options. 

e. Safety will not be adversely affected, as, upon your approval of my exemption request, I will take 

another FIRC (flight instructor refresher course) before any utilization of my CFI options. Timing is such 

that I can stay on my same May CFI renewal timeframe. Certainly, flying daily in my Virgin America line 

Captain's duties has kept my skills current. My whole intent has been the desire to teach my private 

pilot wife instrument flying. 

f. Summary for the Federal Register: Captain Steven James Randall: I seek exemption from FAR 61.197, 

my CFI expiration in May 2010, that was bought about by the FIRC instructor's mis-understanding on 

recent (at that time) changes for CFI's with 'instrument-only' ratings. I will attend a new FIRC class and 

can pick-up my same May renewal timeframe going forward. My skills have remained sharp and 

regularly tested, by my Pt. 121 Captain's duties & flying. 

g. Additional information: I have also submitted a companion exemption request for 61.195c: CFI 

'instrument-only' -rating instructing. Each exemption request can stand on its own merits. My personal 

pilot information: line Captain on the Airbus 320 for Virgin America, I hold an ATP certificate- multiengine land, with Commercial privileges airplane .single-engine land & private privileges single-engine 

sea. Additionally, I have a private pilot certificate- U.K. based- for airplane single-engine land & sea, and, 

multi-engine land. Importantly, I also held an FAA APD and check airman (APD, Aircrew Program 

Designee) for Air Wisconsin on the CL-600 Canadair RJ aircraft (2007). 

h. Exercise ofthe exemption privilege outside of the U.S. :although I have no plans for such, the onetime exemption to keep my CFI current from May 2010 will be history with the next FIRC that I will take 

to move forward. 
2. FAR 11 PETITION FOR EXEMPTION (SECTION 11.81) (FAR 61.195c) 

a. Captain Steven James Randall, 2833 Alnwick Ave unit 13, Livermore California, 94551 

b. I am requesting exemption from FAR 61.195(c) that would seem to preclude me from giving 

instrument instruction for the initial instrument rating because of the fact that my CFI certificate is 

rated: "instrument -airplane", but not rated "aircraft category- airplane". (I hold the CFI-1, but not CFI.) 

c. I seek relief to provide instrument instruction. The reason being, my situation is different from what I 

understand forced the FAA regulatory change, and, Letter of Interpretation, Office of the Chief Counsel 

(Grayson, dated: Jan 4, 2010). 

http://www. faa .gov I a bout/ office_ org/headq ua rte rs _offices/ age/ pol_ adjudication/ agc200/inte rpretatio 

ns/data/interps/2010/Grayson-2.pdf 

When I asked AOPA staff why the FAA made changes to FAR 61.195c, I found that FAA mentioned 

concerns about a few larger flight schools possibly using the CFI-1 to shortcut knowledge testing for the 

basic CFI, rating add-on, under FAR 61.191. That kind of situation is not a reflection of my safe and 

professional approach to aviation instruction. As you know, as an FAR Pt. 121 Captain, I'm limited in 

total monthly, quarterly, and yearly commercial flight time and therefore, have no interest in the 

business of basic-flight instruction, per say. 

d. Public interest will be served by what I believe will be my making of a safer instrument pilot (my wife, 

or others); my daily NAS -National Airspace System- experience with an air-carrier will absolutely create 

a safer and more knowledgeable new instrument pilot. 

e. Safety will not be adversely affected because any instrument candidate that I fly with will already hold 

PIC category and class qualification. I would also have such same category & class rating on my own pilot 

certificate. This type of operation was fully approved for many years as the current & unchanged FAA 

Technical Order 8900.1, Volume 5, Chapter 2, Section 11, paragraph 5-503. 

http:/ /fsims.faa.gov/PICDetail.aspx?docld=A6018EF51590B0008525734F0076665F (scroll to: 5-503)