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Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue 

SE West Building, Ground Floor Room W12-140 

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OPEhM )Livermore, CA9455I 

2U A R: 5 £7"'October 2011 

Dear Sir or Madam: 

Ref: FAR 11 Petition for Exemption, Captain Steven James Randall ATP 2618972 

I am requesting exemption from FAR 6l.l95(b)& (c), that, would seem to preclude me from giving 

instrument instruction for the initial instrument rating to my private pilot wife because of the fact that my 

CFI certificate is rated: "instrument -airplane" , but not rated "aircraft category- airplane". 

As a current line Captain on the Airbus 320 for Virgin America, I hold an ATP certificate- multi-engine 

land, with Commercial privileges airplane single-engine land & private privileges single-engine sea. 

Additionally, I have a private pilot certificate- U.K. based- for airplane single-engine land & sea, and, 

multi-engine land. Importantly, I also was an FAA APD (Aircrew Program Designee) and check airman 

for Air Wisconsin on the CL-600 Canadair RJ aircraft. 

Flying in our busy airspace system nearly every day certainly reminds me that I should be the one 

teaching my wife instrument flying. All the teaching-your-spouse jokes aside, I suspect you can 

appreciate my honest goals here. Patience may be a (necessary) virtue, but peace of mind will be 

priceless. 

Historical normal operations, as well as the current & unchanged FAA Technical Order 8900.1, Volume 

5, Chapter 2, Section 1 1, paragraph 5-503, clearly make my proposed operation legal. The recent industry 

problem has come in the form of a Letter of Interpretation from the Office of the Chief Counsel (Grayson. 

Jan 4. 2010) that confuses the issue by discussing the October 2009 regulation changes to FAR 61.195(c) 

for instrument instruction for commercial certification and on multi-engine aircraft. 

When I asked my AOPA friends why in the world FAA made changes to FAR 61.195c, I found that FAA 

mentioned concerns about a few larger flight schools possibly using the CFI-I to shortcut knowledge 

testing for the basic CFI, rating add-on, under FAR 61.191. That kind of situation certainly does not relate 

'tome. As you know, as an FAR Pt. 121 Captain, I'm limited in total monthly, quanerly, and yearly ' 

commercial flight time and therefore, don't have interest in the business of commercial flight instruction, 

per say. 

As a further point to the school-issue above, I looked in the Federal Register (references below) at the 

Preambles to both the (Pilot, Flight Instructor and Pilot School Certification, Docket 2006-26661) NPRM 

(Feb. 7, 2007) and the Final Rule (Aug 21, 2009). I see that the appropriate item (#73) talks only about 

adding the flight instructor instrument rating requirement for " training at the commercial pilot and ATP 

certification levels " ; again, seemingly related to the aforementioned school issue. 
Also discussed is the CFI certificate without the instrument rating, and, the CFI certificate with only the 

instrument-airplane rating, but the CFI not holding an airplane multi-engine rating on his/her pilot 

certificate. None of these circumstances are like mine. I meet the past and current regulation 61.195c: I 

"hold an instrument rating on my pilot certificate and flight instructor certificate that is appropriate to the 

category (airplane) and class of aircraft used for the training provided." The Final Rule preamble 

acknowledges that the instrument flight instructor certificate does not have a class rating. Look at page 

42536, left column, paragraph 2, in this August 2009 Final Rule Preamble, where, they take the time to 

clarify the separate intended definitions between category & class on the flight instructor holder's pilot 

certificate and category & class on his/her flight instructor certificate. 

Summary: 

I request individual exemption from FAR 61.195(b)&(c) re the Grayson- Jan 4 2010 interpretation letter; 

confirming the existing Technical order 8900.1. Volume 5, Chapter 2, Section 11, Paragraph 5-503. B. 

"B7"dass Ratings. Flight instniciors who^holdflighliristfuctor^rtificatefi^iifdvindet^ " 

which allow only instrument instructor privileges in airplanes, may give instrument flight instruction 

in any class airplane that is listed without restriction on their pilot certificate. Instructors holding only 

a helicopter instrument rating on their flight instructor certificate are limited to conducting instrument 

flight instruction in helicopters." 

Thank you for your early consideration. 

Regards, 

Captain Steven Randall 

ATP/CFII 2618972 

References: . - - --

Tech order: 

http://fsims.faa.gov/PICDetail.aspx?docId=A60l8EF51590B0008525734F0076665F (scroll to: 5-503) 

Grayson Interp: 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/da 

tayinterps/2010/Grayson-2.pdf 

2007 Fit Instrut cert NPRM: 

http://edocket.access.gpo.gov/2007/pdf/E7-l467.pdf (see page 5826, item # 73) 

2009 Fit Instruct cert Final Rule: 

http://edocket.access.gpo.gov/2009/pdf/E9-l9353.pdf ( see page 42534, item # 73)