AIRNET 3041 George Page Jr Dr. Columbus, Ohio 43217

January 29, 2016

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor Room W12-140

Washington DC 20590

Re: Petition for Exemption from Certain Provisions of 14 CFR 61.51 (f) (2)

This petition follows the requirements for inclusion in such documents set forth in the order presented in 

14 CFR Part 11.81 (Petition for Exemption).

Petitioner Name and Mailing Address

Mr. Thomas Schaner

Director of Operations

AirNet II, LLC

3041 George Page Jr. Rd.

Columbus, OH 43217

614-409-4900

DO@airnet.com

Specific Section or Sections of 14 CFR from which Exemption is Sought

[14 CFR 61.51 (f) (2)]

To allow AirNet II, LLC (AirNet) to assign a properly trained and qualified second in command 

(SIC) during a flight that otherwise does not require a SIC and to also allow the SIC to log that 

flight time. 14 CFR 61.51 (f) (2) states: 

“A person may log second-in-command time only for that flight time during which 

that person ... holds the appropriate category, class, and instrument rating (if an 

instrument rating is required for the flight) for the aircraft being flown, and more 

than one pilot is required under the type certification of the aircraft or the 

regulations under which the flight is being conducted.”

Extent of Relief and Reason it is Sought

AirNet II, LLC seeks relief allowing the assignment of a SIC to flights that otherwise do not 

require a SIC and to allow the SIC to log that flight time subject to the following conditions and 

limitations:

1) Any flight time logged as SIC flight time under this relief may not be used to otherwise 

gain an additional rating or certificate as prescribed in part 61, to include an airline 

transport pilot (ATP) certificate;
AIRNET 3041 George Page Jr Dr. Columbus, Ohio 43217

2) SIC pilots assigned to a flight under this relief may only log SIC flight time, even if such 

pilot is operating the aircraft as the sole manipulator of the flight controls;

3) SIC flight time gained under this exemption may only be used for the purposes of 

upgrading from an SIC to PIC in part 135 operations;

4) Any SIC flight time gained under this exemption must be documented in the pilot’s 

logbook as SIC flight time gained under this exemption

5) The SIC must hold a commercial pilot certificate with appropriate category, class and 

instrument rating, if applicable, as set forth in §135.245 (a) or (b);

6) The SIC must meet the minimum regulatory flight hour requirement for the type of 

operation to be conducted;

7) The PIC and SIC assigned to the flight must meet the 75-hour crew pairing requirements 

as set forth in 14 CFR §135.4 for any flights conducted under the eligible on-demand 

regulations;

8) The SIC must have completed the operator’s approved SIC training program, including 3 

hours of crew resource management (“CRM”) training. One hour of the required CRM 

training may be accomplished in conjunction with other approved flight training curricula;

9) The SIC will be assigned specific ground and flight duties consistent with those required 

of pilots assigned as SIC to flights that do require an SIC by operation or regulation and 

these duties will be documented in the certificate holder’s operating manual;

10) The SIC must complete any other pilot training required for two-pilot crews necessary to 

conduct operations consistent with certificate holder’s operations specifications;

11) The certificate holder will maintain, at the principal operations base, a current list of SICs 

conducting flights under the provisions of this exemption; and

12) Once the SIC transitions to an aircraft requiring two pilots by type certificate, upgrades to 

PIC, or is no longer employed by the certificate holder, he or she may be removed from 

SIC exemption list.

How This Benefits the Public as a Whole

The benefits of providing this relief have been well established through the issuance and 

renewal of identical relief requests (e.g. reference Exemption 9770) to operators similar to 

AirNet. Expressly stated, some of the benefits include:

1) Providing SIC pilots actual “line” experience in on-demand and regularly scheduled 

charters in all weather conditions, demanding deadlines, with an airline “feel and 

function” including operational control procedures.

2) Providing pilots assigned as SIC and those assigned as PIC with earlier exposure to and 

an opportunity to utilize Crew Resource Management (CRM) skills that they will require 

throughout their career.

3) While not required for safe, legally compliant operations, this relief does enhance 

operational safety by placing a second properly trained and qualified pilot in the aircraft 

for such operations. 

It is in the public interest for Second in Command pilots to gain valuable flight experience in the 

aircraft types operated by AirNet and to operate in a crew environment prior to accepting other 

pilot positions.
AIRNET 3041 George Page Jr Dr. Columbus, Ohio 43217

Reasons Exemption Would Not Adversely Affect Safety / Equivalent Level of Safety

As stated previously, the benefits of providing this relief have been well established through the 

issuance and renewal of identical relief requests (e.g. reference Exemption 9770) to operators 

similar to AirNet. Pilots participating in the program as SIC gain valuable experience in 

commercial operations prior to accepting positions where they are required to act as PIC. 

Overall program benefits include:

• Providing inexperienced pilots the opportunity to gain relevant experience in commercial 

operations earlier than is now possible.

• In the current environment where qualified pilots are in demand, this program reduces 

the time required for inexperienced pilots to gain valuable and directly relevant flight 

experience necessary to qualify for these positions, while also providing them 

opportunities to upgrade to positions where they can gain PIC experience that they 

might not otherwise receive if hired as an SIC for an airline.

• Enhances operational safety by placing a second properly trained and qualified pilot on 

such operations.

Summary

AirNet II, LLC seeks relief allowing the assignment of a SIC to flights that otherwise do not 

require a SIC and to allow the SIC to log that flight time.

Additional Information

No additional information. 

Operations Outside of the United States

By allowing this relief outside of the United States, where allowed by the State in which the 

operations are conducted, it allows AirNet SIC pilots to continue to log flight time and gain 

valuable experience in complex international environments. The same rationale for allowing this 

exemption within the United States applies for outside the United States.

Respectfully,

Thomas Schaner

Director of Operations

AirNet II LLC

614-409-4900