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 Command completing initial or upgrade 

training to be observed by a Federal Aviation Administration (“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 specified 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 employs 

three 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 short 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 operate safely and in compliance with FAA rules, having 
a record of no accidents, incidents, or enforcement 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