Sep 21 2010 

Mr. William Behe 

2322 Beale Avenue 

Altoona, PA 16601 

Dear Mr. Behe: 

This letter is to inform you that we are unable to process your request for an exemption from 

§ 61.197 of Title 14, Code of Federal Regulations (14 CFR). It explains why we can not 

process your request, gives you some important information about how we have handled 

similar requests, and tells you what you should do in the next 30 days. 

Why We Can Not Process Your Request

We entered your August 30, 2010, exemption request for William Behe into the public docket 

(No. FAA-2010-0889), but we are unable to process your request any further. The 

information you sent does not comply with the requirements of 14 CFR 11.81 (copy 

enclosed). For us to consider the request any further, you must send us all of the following: 

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief. 

 The reasons granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

 The reasons the exemption would not adversely affect safety or how the exemption would 

provide a level of safety at least equal to that provided by the rule from which you seek an 

exemption. 

 Any more information, views, or arguments available to support your request. 

How We Have Handled Similar Requests 

It is important for you to know that we have issued denials of exemption in circumstances 

similar to those presented in your petition. We are enclosing for your review examples of 

these denials, Exemption Nos. 5076 and 8246. As noted in those denials, the FAA has 

determined that the petitioner did not substantiate how his situation was unique when 

compared to other holders of flight instructor certificates who must comply with the FAA’s 

instructor certification procedures. In addition, 
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§ 61.199(a) also allows instructors to exchange his/her expired flight instructor certificate for 

a new certificate by passing the practical test prescribed in § 61.187. 

Because the previous denials of exemption dealt with circumstances similar to those 

presented in your petition, there is little reason to believe that we would grant your petition 

for exemption. 

What You Should Do 

 Before we commit agency resources to process and analyze your exemption request, we 

suggest that you review the enclosed denials of exemption. 

 If, after that review, you still want the agency to process your petition, you must tell us 

how the facts and circumstances of your particular situation are significantly different 

from the previous denials of exemption. 

 Send the information about your particular situation, and the information we requested 

earlier in this letter that will enable us to process your request, to reach us within 30 days. 

We will consider the docket on your request open for that period. 

If We Do Not Hear From You 

If we do no hear from you within 30 days, we will close the docket without telling you 

further. 

If you have any questions or need more time, you may call (202) 267-9677. 

Sincerely, 

/s/ 

Ida M. Klepper 

Manager, Airmen and 

 Airspace Rules Division 

Enclosure 
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