24 Sep 2013 

The Administrator 

Federal Aviation Administration 

United States of America

Subject: Exemption request for Part 141 provisional certificate waiting period requirements

Dear Inspector, 

GT Aviation, LLC previously operated under provisional certificate # 27GS055L. This provisional 

certificate expired on 31 Jul 2013. We submitted for a certificate renewal via FAA Form 8420-8

dated 5 Jun 2013. We were informed by Principal Operations Inspector Mark Fair of the 

Washington FSDO our certificate could not be renewed due to the provision in 14 CFR 141.5(e) 

requiring a provisional school to have graduated ten different students from approved TCOs during 

the 24 months prior to certificate expiration. A subsequent request for an exemption from 14 CFR 

141.5(e) was also denied.

GT Aviation now respectfully requests an exemption from the 180 day waiting period specified in 

14 CFR 141.27(b)(3).

At the time of our certificate expiration, we had five students already enrolled and actively flying in 

approved Part 141 TCOs. 

They are:

Roger Marcellus, Instrument Rating, enrolled 23 Sep 2012

Winston Brown, Commercial Pilot, enrolled 20 Feb 2013

David Salvagnini, Flight Instructor Airplane, enrolled 20 May 2013

Sean Payne, Instrument Rating, enrolled 26 June 2013

Peter Rawlings, Instrument Rating, enrolled 9 July 2013

Since the certificate expiration I have been forced to turn away 6 additional potential customers who 

were interested in earning various ratings/certificates under Part 141. This is a particular problem 

for our VA/GI Bill customers where a Part 141 school is a hard requirement for use of their benefits.
Very few students in the Washington, DC area fly in a full time capacity where they can take full 

advantage of Part 141 accelerated instruction. Issues we deal with due to our location in the Flight 

Restricted Zone / Special Flight Rules Area further complicate student training. 

Once we received our provisional certificate, we later applied to the Veterans Administration for VA 

Approval as a training center that can accept VA / GI Bill benefits. We felt that would increase the 

potential customer base of our school, and by extension help meet the 10 graduate requirement.

Despite submitting our application to the VA on 15 Mar 2012, the request was not approved until 24 

Oct 2012, just 8 short months ago. 

To further broaden our ability to offer Part 141 instruction to the public, we have partnered with the 

Community College of Baltimore County as a training provider in their Aviation degree program. I 

have attached a letter confirming this relationship has been established allowing us to start providing 

training during the Fall 2013 semester.

GT Aviation has made significant investments in equipment and infrastructure to support our Part 

141 and Part 61 training offerings via our in house training and the CCBC relationship mentioned 

above. Chief among these improvements was the expansion to twice the administrative space 

occupied when the provisional certificate was first issued. This new space now accommodates a 

formal isolated classroom environment and a dedicated space for our latest investment – a Redbird 

LD AATD simulator. This simulator came at considerable expense (close to $50,000) but was 

chosen due to its ability to be integrated seamlessly into the Part 141 curriculum.

As you can see from the above, GT Aviation has worked hard to expand our business and do so in a 

manner to meet FAA requirements under the provisional certificate. Those efforts took some time 

to hit their stride but we are now at a point of having five (potentially eleven) 14 CFR 141 students 

active in the school. Having to wait the full 180 day waiting period is detrimental to both the 

students who now have to meet the higher Part 61 requirements and is costing our business 

significant money, opportunity, and time.

We respectfully request relief from the 180 day waiting period requirement in 14 CFR 

141.27(b)(3)for the many reasons listed above. 

Thank you for your time and attention to this matter.

Regards,

Timothy Poole

President

GT Aviation, LLC