_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

PETITION FOR EXEMPTION FROM CERTAIN PROVISIONS OF 

14 CFR 135.243(c)(2) FOR AMERIFLIGHT, LLC 

GENERAL 

Ameriflight, LLC (AMF), has a substantial interest in the increased pilot shortage; 

specifically the ability to find qualified pilots to operate flights that meet the requirements 

of 14 CFR Part 135.243(c)(2). 

The upcoming pilot shortage is exacerbated by the Airline Safety and Federal Aviation 

Administration Extension Act of 2010, Sections 216 and 217, and the FAA proposed 

NPRM, Docket Number FAA-2010-0100, Pilot Certificate and Qualification 

Requirements for Air Carrier Operations. 

Ameriflight is the largest 14 CFR Part 135 On-Demand Cargo Airline in the United States. 

Ameriflight employs over 575 people and operates a fleet of 175 aircraft in cargo and 

passenger configurations. Ameriflight’s fleet consists of PA-31, BE99, BE200, SA227, 

BE1900, and EMB120 aircraft. Ameriflight operates primarily as a small feeder for UPS, 

DHL, and FedEx, and has aircraft operating in Alaska, Canada, Contiguous US, Mexico, 

all of the Caribbean, and South America. 

Ameriflight feels this petition request is a necessary first step before a rule change is 

implemented due to a changing airline environment. The increased quality and efficiency 

of flight training and the advancements in risk management assessments has created a 

need for an updated regulation. 

SUBSTANCE OF RULE FROM WHICH EXEMPTION IS SOUGHT 

The current regulation that applies to Pilot-In-Command requirements for On-Demand 

IFR operation is 14 CFR 135.243(c)(2), which states, “Has at least 1,200 hours of flight 

time as a pilot, including 500 hours of cross country flight time, 100 hours of night flight 

time, and 75 hours of actual or simulated instrument time at least 50 hours of which 

were in actual flight”. 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

NATURE AND EXTENT OF RELEIF SOUGHT 

Ameriflight seeks an exemption from the above flight time limitations for all cargo ondemand operations conducted in non-type rated aircraft with a maximum takeoff weight 

of 12,500 pounds or less, the relief sought is as follows: 

• Minimum flight time of 800 hours total time to include at least 500 hours in 

airplanes. 

• Minimum cross country flight time of 400 hours. 

• Minimum of 75 hours of actual or simulated instrument time at least 30 of which 

were in actual flight. 

Ameriflight feels certain specific aircraft types that meet the above weight limits may be 

excluded from this petition due to unique handling qualities, complexity, or high 

workload in a single pilot operation that might make them unsuitable for pilots with less 

than 1,200 hours total flight time. Ameriflight does not currently operate any of these 

aircraft. All of the aircraft that Ameriflight operates have no adverse handling 

characteristics or increased complexity. 

HISTORY 

The FAA set the 1,200 hour time requirement for PIC in 14 CFR Part 135 IFR 

operations over 40 years ago. The time requirement has never been an issue due to the 

fact there has always been qualified pilots to meet this need in the United States. It 

should be noted that the 14 CFR Part 135 time requirement to operate IFR is the same 

time requirement for all sizes and types of aircraft, regardless of complexity or difficulty. 

The airline industry and the FAA are now at a place where we need to specifically 

address time requirements for Part 135 IFR operations due to both the difference in 

aircraft complexity and to ease the effects of an impending pilot shortage. 

The FAA commented in 1996 for Single-Engine IFR operations “The experience and 

skill level required for single-engine air transportation under IFR are not equivalent to 

those required for large transport category airplanes”. This same comparison can be 

made for operating non-type rated aircraft in Part 135 IFR operations with less than 

1,200 hours total time. The experience and skill level required for non-type rated Part 

135 IFR operations is not equivalent to those required for large transport category 

operations. 

In 2010, a Pilot Source Study was accomplished by the Aviation Accreditation Board 

International (AABI) which followed 2156 new-hire pilots. It was evident the best 

performing group of pilots had accumulated between 500 and 1,000 hours of total flight 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

time. These pilots had fewest extra training events and a comparatively fewer 

incompletes as compared to pilots with greater than 1,500 hours total time. 

By lowering the flight time requirement to 800 hours, Ameriflight will be hiring pilots that 

statistically are the best performing group. 

PILOT SHORTAGE 

The FAA and the industry are fully aware of the impending pilot shortage. It is a fact that 

there are dramatically fewer people becoming pilots. According to the FAA, in 1990 

there were 41,749 private pilot certificates issued, in 2010 that number dropped to 14, 

977 which is a 64% decrease. Of those 14,977 certificates issued only 29% went on to 

be a professional pilot. 

The number of Commercial certificates being issued is also down. In 1979 there were 

approximately 13,000 new Commercial pilots and in 2009 that number dropped to just 

over 5,000. Using the accepted percentage of 30%, only 1,500 of these pilots will go on 

to be professional pilots. 

This large decrease in Commercial pilots is startling because the Department of Labor 

and the Occupational Employment Statistics have predicted that in 2018 there will be a 

need for pilots to fill 47,000 commercial pilot jobs, which is a 19% increase over today. 

These jobs do NOT include airline pilots. 

Starting in January 2013 the industry will see the first age 65 retirements begin. 

Between 2011 and 2015 a total of 27,634 pilots will retire. In 2013 the forecast for Major 

Airline hiring is approximately 4,400 pilots. The peak is reached in 2021 with a total of 

5,900 pilots hired. The total forecasted pilot needs, from 2011 through 2030 is 329,820. 

The US aviation industry is facing the real possibility of not having enough pilots to fulfill 

the need. There are many factors coming together in a very short time period that are 

creating this inevitable pilot shortage: 

• The US and Worldwide economic crisis.

• The high cost of flight training.

• Low pay questions being raised by possible new professional pilots and the 

inability to repay student debt. 

• Aviation Improvement Act of 2010, Sections 216 and 217.

• The new 14 CFR Part 117, Flight and Rest rules (which will also affect 14 CFR 

Part 135 operations in the near future). 

• The proposed rule on 14 CFR Part 121, Subpart N training requirements.
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

• The NPRM for Pilot Certification and Qualification Requirements for Air Carrier 

Operations. 

• The recognized loss of flying being an attractive, secure, enjoyable, and wellcompensated career.

All of these issues come together to create a problem that needs to be dealt with and 

analyzed by all parties involved. The industry will continue to grow at a rapid pace, and 

currently there is a forecast of a 66,222 shortfall of pilots over the next twenty years. 

That number accounts for all aspects of Commercial operations. 

Ameriflight will be an essential piece of the solution by bridging the gap from the future 

professional pilots by taking an 800 hour pilot and placing them in 14 CFR Part 135 IFR 

operations. Not only have studies been done to prove that having an 800 hour PIC 

under this petition request is safe, it also shows they perform better than more 

experienced pilots. 

The approval of this petition will increase the candidate pool, and more importantly, it 

will create a path for the future professional pilots to meet the legally mandated floor of 

1,500 hours to become an airline pilot. 

EQUIVALENT LEVEL OF SAFETY 

Ameriflight recognizes the FAA has to review all requests to verify any proposed 

exemption or deviation provides an equivalent level of safety. 

The approval of this exemption will provide an equivalent level of safety through special 

FAA-reviewed training, checking, and quality-control programs as set forth below. 

The following additional experience, training, and checking requirements (beyond those 

already required by Part 135 for qualification as a pilot at Ameriflight) would be 

mandatory for pilots in command to whom the decreased minimum flight times in this 

petition apply. These provisions would be incorporated into the Ameriflight Flight 

Operations Training Manual. Scaling the complexity of the airplane to the pilots total 

flight time, in the context of these additional requirements, will result in an equivalent 

level of proficiency to that achieved under the current rule. 

 

• A minimum of 100 flight hours as first officers in Ameriflight multiengine aircraft 

• Satisfactory completion of Ameriflight aircraft-specific pilot in command training 

for the aircraft in which they are to serve. 

• A minimum of 15 hours of Ameriflight aircraft and instrument procedures training 

in a flight training device or simulator specific to the aircraft type in which the pilot 

is to serve as pilot in command. 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

• Satisfactory completion of a full Part 135.293-297-299 check with no elements 

waived. 

• A minimum of ten hours inflight Initial Operating Experience (IOE) in turboprop 

aircraft or five hours IOE in other aircraft, during line operations in the aircraft 

type, under the supervision of an Ameriflight Training Captain. 

• Mentoring by an Ameriflight Training Captain during the first 100 hours of 

operation. 

• Pilots operating under the exemption will be further subject to unannounced line 

checks by company Check or Training Captains 

• Until the pilot reaches 1,200 hours total flight time, a full Part 135.293-297-299 

check will be conducted each six months [grace periods allowed per 14 

CFR135.301(a)] with no elements waived in each aircraft type in which the pilot 

is to serve. 

• Requirements above would apply to transitions to other aircraft than the type in 

which initial pilot in command qualification was accomplished, until the pilot 

reaches 1,200 hours total time. 

Unsatisfactory performance by a pilot subject to this exemption on any of the checkrides 

or line checks above would be reviewed by the Chief Pilot and Director of Operations 

and, at their discretion, result in the pilot being given additional training followed by a full 

Part 135.293-297-299 check, or removed from assignment as Pilot in Command. 

All of Ameriflight’s flight training is FAA approved through the Flight Operations Training 

Manual. 

PUBLIC INTEREST 

Public interest would be served at several levels: 

 

• The 800 hour pilot reaching the 1,200 hour threshold is better prepared to 

transition into larger, more complex and demanding, faster aircraft 

• The pilot reaching 1,500 hours is already experienced in real-world scheduled 

airline operations, load planning, weather flying, dealing with maintenance and 

flight/duty/rest issues, and the revenue flying environment – and consequently 

much better prepared to succeed in Part 121 passenger service as a safe and 

competent pilot. 

• Air feeder operations conducted by Ameriflight provide next day express package 

delivery and other expedited air cargo service to hundreds of communities 

throughout the U.S., Canada, Alaska, Mexico, the Caribbean, Central, and South 

America. Manufacturers, health care organizations, manufacturers, and other 

businesses have grown to depend upon their reliability. These services affects 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

millions of people. A shortage of pilots means a decrease in current service 

levels – specifically, later (or in some markets) no, delivery of this freight. 

• Granting this petition indirectly serves public interest in assisting to prevent the 

disruption of commerce which will certainly befall U.S. commercial aviation at all 

levels if nothing is done to ameliorate the pending shortage of pilots. 

• The U.S. cargo industry relies on small feeder aircraft to extend their networks to 

smaller communities. It would not be in the public interest to deny service to rural 

areas due to lack of pilots to operate the flights. 

PRECEDENT

There are several precedents applicable to the flexibility this exemption would grant: 

• Decision by the FAA many years ago to lower the minimum time limit for 

certification of pilots with instrument ratings – a decision which improved the 

integration of IFR training with other flying and ultimately improved safety 

• Long-standing provisions in Part 141 that allow certification of pilots with lower 

total flight times than those specified in Part 61, based upon the quid pro quo of 

specific, carefully regulated training – much like Ameriflight proposes in this 

petition. 

• Flexibility granted to the airlines on the basis of specialized training and checking 

programs such as AQP. 

• Various provisions in Part 135 that grant additional flexibility to cargo-only 

operations based upon the inherently reduced public risk of that type of flying. 

• Provisions in the current “Pilot Certification and Qualification Requirements” 

NPRM related to reduction of minimum flight time requirements in exchange for 

specific training requirements 

A number of exemptions and deviations currently in effect at Ameriflight, which have 

been utilized for years with no adverse effect upon the safety of our operations. These 

demonstrate the Company’s commitment to effectively manage such privileges. 

EXPEDITED HANDLING 

Since the requested petition only addresses On-Demand Cargo operations and not 

passenger carrying, Ameriflight does not regard it as precedent-setting. Therefore, 

Ameriflight request that the processing of this petition be expedited to the extent 

deemed feasible by the FAA, including waiver of Federal Register publication and public 

comment periods normally required in 11.85 and 11.87. 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

COMMUNICATIONS 

Within the limits of FAA policy, Ameriflight is available and open to discuss, clarify, or 

amend this petition, and particularly to consider any adjustments that might better 

address agency requirements while meeting Ameriflight’s objective. 

CONCLUSION 

Granting this petition is the first step to the FAA proposed “U.S. Aviation Academy”. This 

is a needed step that would also work for already established college programs. Also, 

the increased quality of flight training in the modern airline environment as compared to 

when 14 CFR 135.243 was written. 

This process will produce a cadre of pilots who, upon reaching the current 14 CFR Part 

135.243(c)(2) 1,200 hour flight time limit would have obtained much more valuable and 

well-rounded experience in the real world of enroute ATC operations, weather flying, 

disciplined airline type operations in accordance with airline Standard Operating 

Procedures, cockpit resource management, payload control, and other elements of 

revenue flight management that are simply not available in common “flight time builders” 

such as flight instruction, pipeline patrol, traffic watch flying, and other various means for 

time building. 

These pilots would then continue into larger and type-rated equipment from a 

foundation of experience which would make them much easier to train and qualify in 

those more-demanding aircraft. This would in turn generate a supply of safer, more 

seasoned, operationally experienced pilots well prepared to enter the world of Part 121 

passenger flying under the current public law-mandated 1,500 hour experience 

minimum for entry-level First Officers.