## 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 ope rations 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:

S eeking 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

oper ations.

My experiences would offer the public an equal level of safety by crediting my military helicopter flight pilot in c ommand experience s 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 incl ude 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, as sessing, 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 int e grations i n all modes of flight while incorporating Crew Resource Management.

- I have experienced critical decision making situations , as pilot in command that directly affected the sa fety of operations to include in combat.

- My experiences operating th e CH

- 47D/F as pilot in command will assist me to be

a competent and safe P art 121 pilot in command.

- I credited approximately 50% of m y 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. M y 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.