818 Willow Run Airport, Ypsilanti, MI 48198

Telephone 734-484-0088

Fax 734-544-5008

Norman D. Gage

Assistant Director of Operations

Kalitta Air, LLC

818 Willow Run Airport

Ypsilanti, MI 48198

Phone: 734-484-0088 ext 7050

Fax: 734-544-7023

Email: ngage@kalittaair.com

Specific section from which Kalitta Air, LLC seeks exemption:

• Kalitta Air hereby petitions for exemption to 14 CFR Part 61.39(b)(1)(i).

• This specific section of the regulation provides for an individual with an expired Airline Transport 

Pilot (ATP) Knowledge Test to take the Airline Transport Pilot Practical Test if: (1) the applicant is 

employed by a certificate holder under Title 14 CFR Part 121 at the time the practical test is 

taken and (2) has satisfactorily accomplished that operator’s pilot-in-command aircraft 

qualification training program. 

The extent of relief sought:

• Kalitta Air requests this exemption to allow a First Officer with an expired Airline Transport Pilot 

Knowledge Test to take the Airline Transport Pilot Practical Test provided the First Officer is 

employed by Kalitta Air, LLC at the time the practical test is taken and has completed the FAAApproved Training Program (ATP) initial or recurrent First Officer training (as appropriate). This 

includes applicants in Kalitta Air’s Continuing Qualification Curriculum under its Advanced 

Qualification Program (AQP).

How the public (as a whole) would benefit:

• Issuance of the requested exemption to 14 CFR Part 61.39(b)(1)(i) will not directly benefit the 

public as a whole. 

Reason why safety would not be adversely affected:

• This exemption will not adversely impact operational safety. The pilots affected are currently 

performing duties as flight crewmembers under 14 CFR Part 121 and those duties will not 

change with this exemption. 

• In addition, while these pilots are not upgrading through a pilot-in-command qualification 

program, they are accomplishing a training program approved by the Federal Aviation 

Administration for Kalitta Air, LLC and have passed the required knowledge test (although 

expired).

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818 Willow Run Airport, Ypsilanti, MI 48198

Telephone 734-484-0088

Fax 734-544-5008

(Page 2 of 2)

Summary for publishing in the Federal Register:

• Kalitta Air, LLC requests an exemption to 14 CFR Part 61.39(b)(1)(i).

• Kalitta Air requests this exemption to allow a First Officer with an expired Airline Transport Pilot 

Knowledge Test to take the Airline Transport Pilot Practical Test provided the First Officer is 

employed by Kalitta Air, LLC at the time the practical test is taken and has completed the FAAApproved Training Program (ATP) initial or recurrent First Officer training (as appropriate).

Additional information, views or arguments:

Recent regulatory changes, primarily The Airline Safety and Federal Aviation Administration Extension 

Act of 2010 (Pub. L. 111-216)(the “Act”), require crewmembers to hold an Airline Transport Certificate 

as a requirement for employment for a First Officer position at an air carrier operating under 14 CFR 

Part 121 by August 2013. This requirement is a change from the previous requirement to possess at 

least a commercial pilot certificate. Due to these recent regulatory changes, Kalitta Air has First Officer 

crewmembers that will receive the training and practical test for a combined aircraft type rating and 

airline transport pilot certificate outside the normal upgrade cycle that would comply with pilot-incommand qualification program referenced in 14 CFR Part 61.39(b)(1)(i).