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 pr ovisional certificate # 27GS055L . This provisional certificate expire d 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 Washin gton FSDO our c ertificate 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 activel y fl yi ng 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 Pay ne, Instrument Rating, enr olled 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 fl y in a full time capacit y 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 Administrat ion 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 b y 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 f irst 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 ab ility

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 t ime to hit their stride but we are now at a point of having five (potentiall y 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 requ irements and is costing our business significant money , opportunity , and time

. We respectfull y request relief from the 180 day waiting period requirement in 14 CFR 141.27(b)(3) for the man y reasons listed above. Thank you for your time and attention to this matter. Regards,

Timothy Poole President GT Aviation, LLC