Petition for Exemption

Matthew Gerlitzki

PO Box 61

Muldraugh, KY 40155

mgerlitzki@gmail.com

619-772-3439 Mobile

Exemption RE: 

Part 121.436 Pilot Qualification: Certificates and experience requirements.

(a) No certificate holder may use nor may any pilot act as pilot in command of an aircraft 

(or as second in command of an aircraft in a flag or supplemental operation that requires 

three or more pilots) unless the pilot:

(3) If serving as pilot in command in part 121 operations, has 1,000 hours as second in 

command in operations under this part, pilot in command in operations under 

§91.1053(a)(2)(i) of this chapter, pilot in command in operations under §135.243(a)(1) of 

this chapter, or any combination thereof. For those pilots who are employed as pilot in 

command in part 121 operations on July 31, 2013, compliance with the requirements of 

this paragraph (a)(3) is not required.

(c) For the purpose of satisfying the flight hour requirement in paragraph (a)(3) of this 

section, a pilot may credit 500 hours of military flight time obtained as pilot in command 

of a multiengine turbine-powered, fixed-wing airplane in an operation requiring more 

than one pilot.

Relief:

Seeking an exemption to the above rule by replacing (c) “fixed-wing airplane” with 

“rotary aircraft.”

Purpose/Reason:

To achieve the 1,000 hour requirement to operate as pilot in command in part 121 

operations.

My experiences would offer the public an equal level of safety by crediting my military

helicopter flight pilot in command experiences toward the 1,000 hour requirement.

- I served in the military as a CH-47D/F Chinook helicopter aviator flying in 

domestic and international areas of operation to include Afghanistan and South 

Korea.

- The CH-47D/F is a twin-engine turbine heavy-lift helicopter, transporting 

passengers and equipment, with a gross weight of 50,000lbs.
Petition for Exemption

- I am a military trained and certified Aviation Safety Officer that was responsible 

for risk management by identifying, assessing, and mitigating hazards to the

lowest level on a daily basis.

- One year of flying combat missions in Afghanistan that required thorough flight 

planning, multi crew, and multi aircraft integrations in all modes of flight while 

incorporating Crew Resource Management.

- I have experienced critical decision making situations, as pilot in command that

directly affected the safety of operations to include in combat.

- My experiences operating the CH-47D/F as pilot in command will assist me to be 

a competent and safe Part 121 pilot in command.

- I credited approximately 50% of my rotary flight time towards my ATP 

certificate.

- I possess an ATP certificate with an EMB-145 type rating.

- I have accumulated 717 hours of SIC flight time in 121 operations, EMB-145.

Summary:

Regarding Part 121.436 (c), I petition the administrator to allow my military pilot in 

command flight time in rotary turbine powered aircraft to be credited towards the 1,000 

hour requirement. My pilot in command experiences operating the CH-47D/F Chinook 

helicopter will offer an equal level of safety to the public as required in Part 121.436.