Western Global Airlines, LLC

9260 Estero Park Commons Blvd

Estero, FL 33579

April 13, 2016

U.S. Department of Transportation Docket Operations West Building Ground Floor Room W12-140

1200 New Jersey Avenue SE Washington, DC 20590

Re: Amendment to Request for Exemption, Docket DOT-FAA-2014-0310

Dear U.S. Department of Transportation:

Western Global Airlines, LLC (“WGA”) hereby amends its application, dated November 16, 2015, in this docket, to include the following supplemental information. At that time, WGA requested an exemption from 14 CFR 121.434(3) (c) (1) (ii) , the requirement for a Pilot in Comm and completing initial or upgrade training to be observed by a Federal Aviation Admini stration (“FAA”) Inspector during at least one flight leg which includes takeoff and landing, during the Operating Experience as specified by 14 CFR 121.434.

WGA is requesting the FAA to permit WGA to substitute a qualified and authorized Check Airman or Aircrew Program Designee (APD) in place of an FAA inspector to observe a qualifying pilot in command who is completing the initial or upgrade training sp ecified in Section 121.424 during at least one flight leg that includes a takeoff and a landing. WGA has an approved APD program and currently employsthree APDs under the supervision of our Aircrew Program Manager, Inspector George Farinas of CMO67. WGA proposes check airmen and/or APDs be designated for this authority; all of the candidates proposed by WGA to complete these observations are very highly experienced, with many years of Check Airman and/or APD experience.

WGA’s business is predominantly engaged in international flying. Requiring an FAA inspector to conduct the observation may result in a substantial burden on the FAA, as an inspector must travel outside the United States, which inevitably requires additional time and expenditures. WGA is an ad-hoc ACMI air carrier, and must be able to respond on very shor t notice to its customers’ demands. It would be difficult for both the agency and the carrier to arrange feasible times for such observations.

Most, if not all of Operating Experience for initial and upgrade training will be conducted outside of the United States of America. WGA requests the privileges of the exemption outside of the United States of America due to FAA Inspector availability foreign country clearance requirements.

WGA has adequate experience in Part 121 air carrier operations, having operated continuously since August 1, 2014. It has a demonstrated ability to oper ate safely and in compliance with FAA rules, havinga record of no accidents, incidents, or enforcemen t actions. Further, the carrier has received final approval for its training program.

Granting this exemption is in the public interest in that it allows the FAA to utilize Inspectors for more immediate needs and should also provide financial savings in avoiding FAA inspector travel expense. It will also allow WGA to more expeditiously complete Operating Experience for initial new hire and upgrade pilots-in command. And, given that pilots in command will be observed in accordance with an FAA-approved APD program and by FAA-approved personnel, a level of safety equivalent to the requirement of the regulation will be maintained.

Accordingly, WGA requests that the FAA proceed expeditiously to grant the exemption request filed November 16, 2015. WGA appreciates your consideration of this request.

Sincerely,

/s/ Thomas J. Quehl

Thomas J. Quehl Vice President of Operations