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 a t 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
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... · · .· · · · ··-- · In the following couple ofyears, 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 bevery 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 F I RC on 13th March 2010 in San Mateo, CA
. During a review of regulat ion changes, our presenter mentioned that the 'FAA had stopped renewing CF II on ly certificates'. This shocked me and I asked f or 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 w ith a CF I certificate
. I asked the presenter for a CFR reference and was advised that I cou ld get th is from ASF staff
. For the next 11 weeks, I tried to get clarificat ion from the AOPA/ ASF staff and fi nally 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-mai ls 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 cert ificate privileges expired. Some 10 days later, I rece ived a telephone call from an official at the FAA in Washington DC. This person asked not to be named but stated that the inte rpretation by AOPA did not relate to my situation and that the renewa l 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 communicat ion, even including a promise of a renewal from an FAA inspector in March 2011 (someth i ng that didn't happen due to a transfer). AOPA have been supportive (Rodney Martz and Jonathan Greenway) but th is mis interpretation has left me without the teach i ng privileges I worked so hard to gain. As a previous Type Rati ng Examiner for the FAA, instrument instructor, Check Airman and current Airbus line Captain, it seems absurd to allow this situation to cont inue any longer. As a result, AOPA have helped me to construct the following petitions to help correct this error. I t hank you i n advance for reviewing my situation and I trust that common sense will see a sensible conclusion of a long overdue renewa l of my CFII privileges. I will, of course, be happy to attend another FIRC before my CFII cert ificate is formally renewed. Should you require any further information or clarificat ion , kindly contact me at e-mail steve.randall@virginamerica .com, cell925-200-1417 (PST) or mail 2833 Alnwick Avenue #13, Livermore, CA 94551
.
S

incerely, / '' 

# /
. Captain Steven 

### J. Randall ATP 26189721. FAR 11 PETITION FOR EXEMPTION (FAR 61.197)

a. Captain Steven James Randall, 2833 Alnwick Ave unit 13, Livermore Californ ia, 94551 b. I am requesting a one-time exemption from FAR 61.197 regarding flight instructor renewal-my attendance at the flight in structor renewal course (March, 2010, San Mateo Cal if
.) 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 (fl ight instructor refresher course) before any utilization of my CFI options. Timing is such th at 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 Reg ister: Captain Steven James Randall: I seek exemption from F AR 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 i nformation: 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- mu lti engine 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 sing le-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 Californ ia, 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 CF I-1, but not CFI.) c. I seek relief to provide instrument instruction. The reason being, my situation is different f rom what I understand forced the FAA regulatory change, and, Letter of Interpretation, Office ofthe Chief Counsel (Grayson, dated: Jan 4, 2010)
. http://www.faa .gov

## Iabout/office_ org/headqua rters_offices/ age/pol_ adjudication/ agc200/interpretat io ns/data/interps/2010/Grayson-2.pdf When I asked AOPA staffwhy 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 ofsituation is not a reflection of my safe and professional approach to aviation instruction
. As you know, as an FAR Pt. 121 Captain, I'm lim ited in total monthly, quarterly, and yearly commercia l fl ight time and therefore, have no interest in the business of basic-flight instruction, per say. d. Pub lic interest will be served by what I believe will be my making of a safer instrument pi lot (my wife, or others); my daily NAS -National Airspace System- experience with an air-carrie r wil l absolute ly create a safer and more knowledgeab le new instrument pilot
. e. Safety will not be adversely affected because any instrument candidate that I fly with will al ready 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, Vol ume 5, Chapter 2, Section 11, paragraph 5-503. http:/ /fsims.faa.gov/PICDetail.aspx?docld=A6018EF51590B0008525734F0076665F (scroll to: 5-503)