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

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- 0088 ext 7050 Fax: 734

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- 7023 Email: ngage@kalittaair.com Specific section from whic h 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 Airlin e 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

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- command aircraft qualification t raining 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 FAA

Approved 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 affec ted:

• 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

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- 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). (Page 1 of 2)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 th e 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 FAA

Approved Training Program (ATP) initial or recurrent First Officer training (as appropria te).
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 a s 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

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co mmand qualification program referenced in 14 CFR Part 61.39(b)(1)(i).