20 August 2015

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, D.C. 20590

Re: Petition for Exemption

Via Electronic Filing

Dear Sir or Madam:

Pursuant to 14 CFR Part 11, this is a Petition for Exemption from specific portions of 14 CFR.

Section I

The name and mailing address for the subject of this petition is Mr. Alwyn R. Lynch Jr.,

520 Crawley Run Drive Unit 208, Centerville Ohio, 45458. Telephone number is (478) 787-9266.

Email address is mail.lynch90@gmail.com.

Section II

Relief is sought from 14 CFR Part(s) 121.436(a)(3) and/or 121.436(c) as it applies to the

subject of this petition, Mr. Alwyn R. Lynch Jr., with regards to the pilot in command experience

requirements so as to allow the subject of this petition to credit 500 hours of equivalent military

pilot in command experience, technical knowledge, and experience towards the pilot in command

flight time requirements of 14 CFR Part 121.436.

Section III - Extent of Relief Sought and Reasons

The subject of this petition, Mr. Alwyn R. Lynch Jr., is seeking an exemption from 14 CFR

Part(s) 121.436(a)(3) and/or 121.436(c) to expand the scope and applicability of said sections of

that part to allow the subject of this petition to credit 500 hours of military turbine command

experience towards the 1,000 hour second-in-command (SIC) flight requirements to become

eligible to serve as a pilot in command in Part 121 operations. The subject desires the Federal

Aviation Administration (FAA) to consider in part his equivalent training, pilot in command time,

and Part 121 experience when reviewing this petition.

IIIa. Background

A final rule, 14 CFR Part 121.436 was enacted to require certain flight time experience

requirements to be met before an individual can be considered eligible to serve as a pilot in

command under 14 CFR Part 121 air carrier operations (Part 121). The basic eligibility

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requirements state that a pilot in command must first acquire at least 1,000 hours of flight

experience as a Second-in-Command (SIC) before being afforded the opportunity to attend

upgrade training to become a Captain. This was a measure put in place to ensure that a

pilot-in-command (PIC/Captain) has a basic level of operational familiarity with Part 121 Air

Carrier operations spurred by the February 2009 crash of Colgan Airlines flight 3407. A

potentially increased margin of safety could possibly be realized in certain situations from

increasing flight experience requirements however we believe that the new rule merely

quantifies the required “experience” without detailing what, if any specific milestones or

operational learning objectives each pilot should acquire within that 1,000 hours of flight time as

an SIC. The new rule makes an assumption that the level of operational clarity, experience, and

command ability will be equal amongst those pilots who have gained the 1,000 hours flight

experience in Part 121 operations.

It might be assumed that the original intent of requiring 1,000 hours of SIC flight

experience would require a pilot to spend at least 1 consecutive year at a Part 121 carrier,

successfully participate in and complete at least one recurrent training event as a pilot

crewmember, and witness a diverse array of operating conditions. We may further assume that

the FAA finds 1,000 hours of SIC experience as a Part 121 crewmember to be a satisfactory

demonstration of potential for future leadership and cockpit management roles. While we do

believe that gaining experience is a necessary component for assuming a leadership role and

career progression, requiring for 1,000 hours in Part 121 operations provides no reasonable

certainty that a pilot will earn that experience. This may be in part to air carrier training

performance historical data that might suggest that outside of the required reading for

mandatory training events, SICs may not seek professional development through academic

pursuits on their personal time the current Part 121 environment and if possible certain SICs

may avoid schedules or trips that present significant operational challenges, such as flying within

the Washington, DC or Philadelphia areas.

We believe that the scope of the 1,000 hour rule can be extended to better recognize

relative academic training, practical training, and experience in command of complex aircraft

without any degradation to the current level of safety provided under Part 121. In fact, allowing

a wider array of military pilots to credit previous experiences will increase safety as the

experience credited can easily be qualified. That is, the quality of the experience those pilots

gained is well documented. The FAA has made similar strides with the new ATP certification rule

which allows pilots to credit academic training and military experience towards reduced ATP

certification flight time requirements. To wit, the new 121.436 rules do allow some alternate

experience (flight experience other than that experience gained as a 121 SIC) to be credited

towards the total 1,000 hour SIC requirement. Even still, some inconsistencies do exist in the

ruling with the experience that may be credited relative to the equivalent level of safety and

operational knowledge gained from that experience. Simply, certain pilots whose level of

experience and command ability is at least the same level of Part 121 operations are not allowed

to credit any of their experience towards the 1,000 hour requirement.

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The final rule extends this alternate experience credit to certain types of operations such

as pilot-in-command time earned in Part 91K or Part 135 operations. If those operations meet

the basic requirements specified in 121.436, a pilot may credit all of his command time towards

the Part 121 1,000 hour SIC requirement to be eligible to become a PIC. Significant to this

exemption is our discovery that a pilot serving as a PIC in commuter operations under Part 135,

even a commuter airline operating aircraft with less than 10 seats and a Maximum Takeoff

Weight (MTOW) of less than 12,500 lbs, can credit all of his pilot command time earned in

commuter operations towards the 1,000 SIC requirements of 14 CFR Part 121.436.

Basically, a pilot serving as a pilot in command of a light twin engine airplane under

commuter operations of Part 135, such as a Cessna 402 or 404, may credit all of his PIC time

towards Part 121 PIC requirements even if such an operation does not require turbojet

experience, a PIC type rating, or any familiarity with the operational complexity and standards

for safety for Part 121 operations. Furthermore, there is no guarantee that said pilot has any

technologically advanced aircraft, turbojet aircraft, or Part 121 experience. The requirements for

such a commuter operation are clearly defined in FAA Order 8900.1, paragraph 3-1275. We

conclude that a certain group of pilots with comparable training, technical skills, and operational

expertise are not allowed to be credit that flight experience towards the 1,000 hour requirement

even though they can provide the equivalent level of safety of at least a commuter pilot who gets

full relief under this regulation.

Military command pilots of turbine powered, fixed wing airplanes received some relief

under the new rule. They may credit 500 hours of pilot in command flight time received in such

aircraft towards the total 1,000 hour requirement. This direction recognizes the training,

acquired technical and demonstrated leadership skills that are required to operate complex

military aircraft at a high level. While most military flight training is similar to scope with respect

to leadership, command, and CRM disciplines, the final rule provides no relief for pilots of

powered-lift aircraft, such as the V-22 Osprey, or transport rotorcraft helicopters, such as the

H-53, H-60, H-47, or H-72. We assume that this is due, at least in part, to a basic unfamiliarity

with military aircraft operations, specifically powered lift and rotary wing operations, and a

general assumption that military powered lift and rotary wing pilots are perhaps less trained and

less capable than their fixed wing military counterparts, or that the transport category operations

are so difficult and complex to grasp that a military trained aviator would need at full 1,000 hours

of SIC experience to obtain a level of operational familiarity and confidence in air carrier

operation. We respectfully disagree.

In this regard, the final rule has limited the a potential for enhanced air safety for the

general public as it prevents pilots with complex aircraft experience, enhanced Crew Resource

Management (CRM) training, and demonstrated leadership ability in demanding, transport

category operations from becoming pilot in command eligible until gaining 1,000 hours of SIC

experience in Part 121 operations. In the same rule, commuter pilots with no relative complex

airplane experience become pilot in command eligible based on flying time gained in commuter

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aircraft alone, not demonstrated ability to operate complex aircraft in a demanding transport

environment. A secondary effect is the potential for unnecessarily negative career consequences

for powered lift and rotary wing military pilots as they may miss an opportunity to become a part

121 Captain while not appropriately qualified by the regulation and may not be presented with

another PIC upgrade opportunity after they do become eligible.

It would be understandable if this measure was proven to provide some level of increased

safety by not allowing certain military pilots to credit their flight time, however this is simply not

the case. These pilots have been expertly trained to operate complex aircraft in demanding

transport category environments and have through experience and examinations, have proven to

the administrator that they are capable of operating complex, technically advanced aircraft at the

pilot in command level. These military pilots are capable, competent, highly trained

crewmembers that, especially when compared to a 2,500 hour pilot with little command

experience in complex aircraft and 1,000 hours of SIC experience in Part 121 operations (who

qualifies to become a PIC), are more than capable of commanding turbojet aircraft in air carrier

operations.

In the final rule the FAA makes it clear that it’s primary desire in recognizing certain

experience towards the 1,000 hour requirement is that it seeks to provide credit to experience

gained in Part 121 operations or in operations that provide a comparable level of operational

complexity and safety to Part 121. ​Through the provision for allowing credit for military pilot

in command fixed wing flight time we gather that the FAA recognizes the inherent ability that

military pilots have demonstrated while operating complex military aircraft. The military credit

provision allows the pilot of any ​multi-engine turbine powered airplane may credit 500 hours

towards the 1,000 Part 121 SIC requirement. There is no specification for “transport operations”,

merely multi-engine, turbine powered airplanes.

The level of operational relevance of a multi-engine combat ‘fighter jet’ to Part 121

operations is no more apparent than the relevance of transport helicopter or powered-lift

operations to the same, especially if that experience is in combination to that pilots actual

experience in turbojet or turbopropeller aircraft if he has been appropriately trained. For the

purpose of this exemption, we will assume that the military pilots we discuss have earned a

turbojet airplane PIC type rating on an Airline Transport Pilot certificate and also possess

command experience in powered lift or rotorcraft category aircraft. To be clear, we do not

disagree that combat fighter jet pilots be allowed to credit their flight time towards the

requirement. We simply make the point that certain powered lift and rotary wing aviators are no

less qualified to credit their previous military command experience based in part on operational

relevance to transport category operations, highly standardized CRM training, and demonstrated

leadership/command ability.

An F-15 Eagle is a U.S. Air Force operated multi-engine, turbine powered, fixed-wing

airplane. The “C” models have conventional type avionics systems. This aircraft is a

multi-mission, multi-role, fighter jet whose primary purpose is air superiority through aerial

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dominance, better known as “dog fighting”. The aircraft is a centerline thrust only aircraft. The

aircraft is not capable of transporting any persons other than the cockpit crew and it is not a

typical (or possible) mission for the crew to perform civilian IFR transport operations. The

aircraft is crewed by a single pilot and a weapons systems operator in the rear seat. Other than

the demonstrated ability to operate a turbojet aircraft, the F-15’s routine operations have very

little in common with Part 121 operations if anything at all. The level of demonstrated piloting

ability is high, however the level of operational knowledge of transport category operations

obtained through operating an centerline thrust fighter jet is limited and no greater than a

powered lift or rotorcraft category aircraft would possess. An F-15 pilot in command may credit

500 hours of command time towards the requirements of Part 121.436, regardless of his

previous experience or type ratings held.

An A-10 Warthog is a U.S. Air force operated multi-engine, turbine powered, fixed-wing

airplane with an MTOW of 50,000 pounds. The A-10 is a single pilot aircraft. The aircraft is a

multi-role attack aircraft whose primary purpose is ground attack and evasion through

aggressive maneuvering. This scenario is the same. Other than demonstrated ability ​of

operating turbojet aircraft, the same ability that is demonstrated through an ATP evaluation per

the administrator, the A-10 pilot has the same operational knowledge of “transport category”

operations as an F-15 pilot. An A-10 pilot may credit 500 hours of command time towards the

requirements of Part 121.436, regardless of his previous experience or type ratings held.

The Boeing CH-47D/F Chinook is a U.S. Army operated, multi-engine, turbine powered,

helicopter with a standard MTOW of 50,000 pounds. This is a higher takeoff weight that certain

versions of the CRJ200 (CL65), a popular transport category aircraft used in Part 121 operations.

The “F” series aircraft are equipped with a fully integrated, digital flight deck with dual flight

management systems (FMS) and a 4 axis autopilot. The aircraft has a service ceiling of 20,000

feet and routinely performs high altitude operations. This is a two pilot aircraft where the pilot in

command is responsible for managing a full crew of 5. Aircrew Coordination Enhancement

Training (ACTE), the equivalent of Crew Resource Management, and aircraft commander

leadership training are annual requirements for all pilot crewmembers, including the pilot in

command. The aircraft is standard equipped to transport 33 passengers, and can be configured

for up to 50 passengers. The aircraft is all weather capable and IFR certified. It operates under

both visual and instrument flight rules for the purpose of transport operations within the United

States, in addition to its wartime combat mission. U.S. Army regulations require that all

transport flights be operated under IFR unless a mission requirement dictates otherwise. A

CH-47 pilot may not credit any of his command time towards the requirements of Part 121.436,

regardless of his previous experience or type ratings held.

A commuter pilot flying a Cessna 402 may credit all of his pilot in command flight time in

a non-crewed, non-technologically advanced aircraft towards the 1,000 hour requirement. We

believe strongly that a military powered lift or rotorcraft helicopter pilot who holds the

appropriate qualifications and has demonstrated his ability through earning an turbojet type

rating should have the opportunity to credit that flight time in recognition of the significant

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amount of leadership/CRM training and IFR transport operation experience he has earned during

military operations. Simply, a military trained powered lift or rotorcraft helicopter pilot with an

ATP rating in multi-engine airplanes can provide at least the equivalent level of operational

safety that a commuter pilot can in Part 121 operations.

Even if a military powered lift or helicopter pilot held an Airline Transport Pilot certificate with

an Airplane Multi-Engine Rating and a PIC turbojet type rating, the final rule does not allow him

to credit any of his military experience towards the 1,000 SIC hour requirement. He has through

examination on behalf of the FAA administrator, demonstrated mastery of transport category

airplanes through civilian training and evaluation. He has demonstrated his ability to operate in

complex, dynamic transport environments while commanding complex aircraft and utilizing the

same model of CRM training found among civilian Part 121 carriers. We believe strongly that a

military helicopter pilot in transport operations has gained an in-depth understanding of the

operational complexity required for “transport category” operations. If such a pilot holds an

airplane rating and has earned, in the eyes of the FAA administrator, an Airline Transport Pilot

certificate and a turbojet type rating, he should be allowed to credit 500 hours of his military

command time towards the 1,000 hour SIC requirement. However; even if a military helicopter

pilot possesses an Airline Transport Pilot certificate with Airplane Multi-Engine Ratings

and a turbojet type rating, he is still not permitted to credit ​any ​of his military command

time towards the 1,000 hour requirement.

If a pilot has earned an Airline Transport Pilot certificate, he has in the eyes of the FAA

administrator demonstrated mastery of an airplane and command ability to operate a fixed wing

multi-engine airplane at a level commensurate with that required to operate under as a PIC

under Part 121. The operational standards for turbojet qualifications are based on the same FAA

published practical test standards for an ATP or type rating, regardless of the type of operation

performed. If that pilot has earned a turbojet type rating, regardless of the level of certificate

held, that pilot has demonstrated to the administrator his ability to operate a fixed wing

multi-engine turbojet airplane, ​in dynamic conditions with multiple unexpected failures, from

the pilot-in-command station of a turbojet in the same manner that the PIC of a Part 121

operation would be required to do. The level of Crew Resource Management (CRM) training

that each multi-pilot military crewmember receives equals or surpasses those CRM training

requirements of Part 121 while still using the same basic concepts and guidelines as civilian

counterparts.

The basic rationale for the rulemaking is to ensure that pilots who act as pilots in

command have the technical and operational knowledge and abilities to perform in a command

role in Part 121 and guarantee the flying public some increased level of safety in the wake of the

Colgan 3407 crash in Buffalo, New York in February of 2009. In a posted regulatory docket

(FAA-2014-0361) the preamble stated the following with respect to determining what flight time

should be credited towards the 1,000 hour experience requirement:

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...the ability to fly at the airline transport pilot (ATP) certificate level and have demonstrated this

proficiency during evaluation is an important regulatory dif erentiation [to determine the

suitability of flight hours credited]....

The FAA’s primary position on this matter is that demonstrated ability and not merely

flying hours is a crucial part of determining whether a pilot should have the opportunity to credit

his flight time towards the 1,000 hour requirement. The initial requirement proposed in 1977 to

require Part 135 commuter PICs to possess an ATP certificate was based in large part on

“operational complexity” and the desire to provide the flying public a level of safety “comparable

to that provided by Part 121 when flying on commuter aircraft. A commuter pilot flying small

multi-engine airplanes is no more valuable to our national safety effort than a military command

pilot with heavy aircraft, turbine experience in powered lift or rotorcraft.

Even with this demonstrated ability the final rule does not take advantage of

opportunities to significantly increase the margin of safety in transport category operations by

allowing pilots who have previously commanded aircraft in operations with a level of safety

equal to or greater than part 121 operations to receive credit for such command time. This is a

disservice to the flying public who generally, if provided with an opportunity would likely prefer

such command and CRM experience over the potential alternatives. This is also a disservice to

those military aviators who have been expertly trained but are denied the opportunity to put that

training into use in an environment that would appreciate the level of safety they could provide.

We believe strongly that equivalent experience, relative to Part 121 operations or in such

operations that are similar in nature to other creditable operations, should be considered in part

when making a determination as to the qualifications for a pilot in command.

The subject of this petition, Mr. Alwyn R. Lynch Jr. is an Airline Transport Pilot (ATP) with

a multi-engine airplane rating. His certificate number is 3057935. He currently possesses 4,087

hours of total flying experience and 2,987 of command experience, of which 1,107 is in command

of multi-engine fixed wing airplanes. He holds a FAA Gold Seal instructor certificate with

Airplane Single Engine, Airplane Multiengine, and Instrument Airplane Ratings. He holds a

turbojet type rating in the CL-65 (CRJ200/700/900) and has previous experience as a 14 CFR

Part 121 flight crewmember. He has attended command training for the CL65, has performed a

PIC proficiency check from both seats, and is currently an Instructor Pilot for the

CRJ200/700/900 providing flight training for air carrier pilot crewmembers for initial,

differences, upgrade, and recurrent training. In this position he is required to maintain and

demonstrate pilot in command proficiency on an annual basis through an oral and practical

examination, in the same manner and to the same standards that are expected of a pilot in

command in Part 121 operations. Mr. Lynch was the primary course developer and senior

instructor for the Instructor/Check Airman Training (ICAT) program at a Part 121 carrier as well

as a qualified Part 121 pilot instructor, delivering the necessary training for initial, differences,

and recurrent training as well as remedial training for initial new hires as well as those

individuals who were found deficient or did not successfully complete Captain upgrade training.

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In a previous role, Mr. Lynch was the Manager of the Advanced Qualification Program

(AQP) for a Part 121 carrier responsible for the development, implementation, and oversight of a

training program for well over 1,000 pilots. Mr. Lynch’s command of Part 121 regulations and his

willingness to lead and assume leadership responsibilities are apparent. Mr. Lynch has also been

a qualified pilot in command and Instructor Pilot for a Part 135 carrier, and has been nominated

to become a Check Airman for that carrier. Mr. Lynch is a former military aviator, serving in the

U.S. Army with over 1,000 hours of time in command of complex, multi-engine, turbine powered

aircraft in transport category operations. He is qualified in the B206/OH58A/C, CH-47, and

UH-72 aircraft. In his military role, Mr. Lynch was an Air Mission Commander, responsible for the

direction and operational control of multiple aircraft engaged in transport operations on behalf

of the unit commander. As a senior pilot in command and lead pilot, Mr. Lynch was also an IFR

and advanced avionics mission trainer responsible for training new pilots on the operation of

advanced avionics systems during IFR transport operations. Prior to becoming a military aviator,

Mr. Lynch was a qualified military Air Traffic Controller and holds an FAA Air Traffic Control

Tower Operator certificate, number 3057935. He progressed to a supervisory role very quickly

and became the Shift Leader/Controller-in-Charge for his facility, overseeing the daily operations

of 5 air traffic controllers on his shift/watch. He was also responsible for the training and

recommendation for new air traffic controllers under his supervision.

It is now respectfully requested that in recognition of Mr. Lynch’s demonstrated

command ability, his Part 121 operational experience as a pilot, his instructor qualifications in

transport category jet aircraft in both Part 121 and Part 142 operations, his Part 121 training

management experience, his multi-engine airplane command experience, his IFR and advanced

avionics training experience, and his military training experience to include Crew Resource

Management and advanced avionics training experience, relief is requested from 121.436 to the

extend required to allow Mr. Lynch to credit 500 hours of turbine military command experience

towards the 1,000 hour PIC requirement of 121.436(a). In addition to the aforementioned

supporting statements in this document, the following summaries are also provided:

1. Mr. Lynch has accepted high levels of responsibilities in a Part 121 environment and has

demonstrated a high level of proficiency and/or mastery of Part 121 turbojet air carrier

operations by becoming a qualified Part 121 pilot instructor, standardization team leader,

and training program manager at a Part 121 air carrier.

2. Mr. Lynch has over 1,000 hours of pilot-in-command time in multi-engine, fixed wing

aircraft, to include certain aircraft routinely utilized in commuter operations as described

in this exemption petition, the pilot of which aircraft could credit all of their command

time towards the 1,000 hour SIC requirement.

3. Military helicopter flight experience is a safe credit for the experience required by Part

121.436 for certain pilots whose experience in transport category operations and

multi-crew environments are more closely aligned to Part 121 than those operations

which are currently allowed flight time credit under the final rule. If a military helicopter

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pilot possesses an Airline Transport Pilot certificate with a turbojet category type rating

then he has demonstrated his operational abilities satisfactorily to the FAA as determined

by the provided statement of the Flight Standards Director and, in recognition of other

qualifications, job performance, and/or experience, should have the opportunity to credit

his command time towards the 1,000 hour requirement.

4. Mr. Lynch has demonstrated his ability to train, mentor, and coach Part 121

crewmembers as well as the ability to operate a transport category aircraft to the highest

degree of safety, commensurate with the level of safety required by Part 121 and

demanded by the general public.

5. Even with a granted exemption, Mr. Lynch would still be required to demonstrate his

command and leadership ability during Part 121 upgrade training, pilot in command

flight evaluations, and initial operating experience line checks. Granting this exemption

does not prevent those skills from being tested, vetted, and verified by the FAA on behalf

of the flying public. It simply provides the flying public with a tool to assess the skills and

operational competence of a trained aviator with the intent of maintaining or increasing

the level of safety currently provided within the Part 121 environment.

6. The Crew Resource Management (CRM) and command training received that Mr. Lynch

has received from the military, as well has his CRM training conducted under Parts 121,

135, 142 have well prepared him to be in command of a crew under Part 121 and his

diverse amount of CRM training and knowledge would be a benefit to the flying public.

7. Mr. Lynch is a trained and certificated Air Traffic Controller and former Air Traffic Control

supervisor and understands the unique challenges and requirements of the national

airspace system.

8. Mr. Lynch is of good moral character, is safety oriented, conservative pilot and has never

had an incident, accident, violation, or personal training failure in both his professional

and personal career settings. He is also a graduate from the U.S. Army Safety Officer

Training Program (Additional Duty Safety Officer).

Section IV - Public Benefit

Granting this exemption would grant the flying public access to pilot in command who is a

military trained command aviator and qualified civilian turbojet instructor with a demonstrated

ability operate turbojet aircraft at the pilot in command level, thereby maintaining and/or

increasing the level of safety required by Part 121 and desired by the flying public.

The experience obtained by Mr. Lynch in his various positions as well as his qualifications

held are greater than the sum of experiences he might stand to gain by flying an additional 500

hours as an SIC under Part 121. The gains realized by an additional 500 hours of SIC flying would

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be minimal and incomparable to those experiences already realized through the previous 500

hours when considered in conjunction with his experience and qualifications.

Section V - Reasons This Exemption Would Not Adversely Affect Safety

(Or How The Exemption Would Provide A Level Of Safety Equivalent To The Current Rule)

Mr. Lynch has already demonstrated his ability to perform at the pilot in command level

in a turbojet aircraft from both seats, and has also demonstrated his ability to operate the aircraft

safely and precisely as a Second-in-Command of that aircraft during actual Part 121 passenger

carrying operations. In the current rule, a Part 135 commuter pilot with little to no CRM training,

no advanced avionics or autopilot experience, and no part 121 experience may credit all of his

pilot in command time towards the 1,000 hour requirement. A military fighter pilot can credit

500 of his command hours towards the same requirement, even if he is not performing or

familiar with transport category operations. A Part 121 second-in-command with 1,000 hours of

Part 121 SIC experience whose only previous command experience is in light, single engine,

piston powered airplanes to credit all of his flight SIC flight time towards the requirement. This

pilot is no more command capable than a military trained powered lift or rotorcraft pilot with a

turbojet type rating whom we believe should be allowed some relief based on relative

experience.

All pilot in command qualified candidates must participate in upgrade training and

evaluation where they must demonstrate to the administrator their level of operational

competence to the satisfaction of the administrator through oral and practical examination, and

the successful completion of an FAA observation check at the end of Initial Operating Experience

(IOE) training. Mr. Lynch would not bypass this step. It is merely requested he be allowed to

credit some of his military command experience in conjunction with experience gained under

Part 121 in various positions so that he may have the opportunity to demonstrate his pilot in

command competence to the administrator. Allowing him to credit 500 hours of military

experience would not adversely affect safety and would, at the very least, provide a level of safety

that is equivalent to the safety provided through adherence to the current rule as stated herein.

The same level of safety and operational competence that is being provided by Part 121 pilots in

command that Mr. Lynch previously trained as a Part 121 pilot instructor. Granting this

exemption would maintain the current level of safety provided by the regulations, if not

enhancing it by some degree and would be in the best interest of the flying public.

Part VI - Summary For the Federal Register

A certificated Airline Transport Pilot (ATP), certificate number 3057935, and qualified

turbojet instructor pilot (CL65), Mr. Alwyn R. Lynch Jr., seeks an exemption from 14 CFR Part(s)

121.436(a)(3) and/or 121.436(c) to count that military pilot in command time obtained toward

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the 1,000 hour experience requirements for Part 121.436 in recognition of other training,

qualifications, and experience.

________

Capt. Alwyn R. Lynch Jr.

Instructor Pilot - Bombardier CRJ200/900, Airbus H135/145

Airline Transport Pilot (ATP), 3057935 | Gold Seal Flight Instructor, 3057935CFI

Air Traffic Controller, 3057935

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