P.O. Box 700548, Dallas, Texas 75370-0548

(972) 725-9000  FAX (972) 725-9090

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, D.C. 20590

February 29, 2016

Re: Petition for Exemption

Via Electronic Filing

Dear Sir or Madam:

Pursuant to 14 CFR Part 11, Ameristar Air Cargo, Inc. (Ameristar) respectfully submits this petition for

exemption from a portion of 14 CFR part 121.436(a)(3), specifically that portion of the regulation 

requiring 1000 hours of flight time to become a pilot in command (PIC) in 14 CFR part 121 (Part 121) 

operations. The basis for this exemption is detailed below.

I. Name and mailing address: Pat Hulsey, Director of Operations, Ameristar Air Cargo, Inc., 4400 

Glenn Curtiss Drive, Addison, TX 75001

II. Relief is sought from 14 CFR part 121 §121.436 to allow the flight hours acquired by a pilot that 

holds a U.S. airline transport pilot (ATP) certificate while acting as a PIC of a turbojet aircraft in 

a multi-crew environment that is conducted under 14 CFR Part 135 (Part 135) in passenger or 

cargo operations to count towards the experience requirements of 14 CFR 121.436(a)(3)

hereinafter 121.436. 

III. Extent of relief sought and reasons for this petition for exemption: 

An exemption is sought to allow hours of experience acquired as a pilot acting as a PIC of a 

turbojet aircraft in a multi-crew environment that is conducted under Part 135 in all-cargo 

operations to count towards the experience requirements of 121.436. The relief sought is only 

for those pilots that acquire the experience required by 121.436 while in the employ of Ameristar 

Jet Charter, Inc., a Part 135 air carrier, and who holds an ATP while acting as PIC in Part 135 

cargo operations.

A. Background

The FAA promulgated 121.436 as the result of congressional action and the FAA’s final 

notice of proposed rulemaking (NPRM). The language is very specific as to the 

qualifications that were intended for a pilot to be a PIC in Part 121 operations. The intent 

appears to have been for a prospective PIC in Part 121 operations to have the experience 

similar to that of a Part 121 PIC. This is very clear in the following passages:

1. In Public Law 111-216 The Airline Safety and Federal Aviation Administration 

Extension Act of 2010 (FAA Extension Act of 2010) it states:

“(a) Requirements

(1) Rulemaking Proceeding.—The Administrator of the Federal Aviation 

Administration shall conduct a rulemaking proceeding to require part 

121 air carriers to develop and implement means and methods for 

ensuring that flight crewmembers have proper qualifications and 

experience.

(2) Minimum Requirements.—

(A) Prospective Flight Crewmembers.—Rules issued under paragraph 

(1) shall ensure that prospective flight crewmembers undergo 

comprehensive pre-employment screening, including an 
Exemption Petition from 14 CFR Part 121 §121.436 Page 2 February 29, 2016

assessment of the skills, aptitudes, airmanship, and suitability of 

each applicant for a position as a flight crewmember in terms of 

functioning effectively in the air carrier’s operational environment.

(B) All Flight Crewmembers.— Rules issued under paragraph (1) shall 

ensure that, after the date that is 3 years after the date of enactment 

of this Act, all flight crewmembers—

(i) have obtained an airline transport pilot certificate under part 61 

of title 14, Code of Federal Regulations; and

(ii) have appropriate multi-engine aircraft flight experience, as 

determined by the Administrator.”1 (Emphasis added)

2. In the final rule to the NPRM Pilot Certification and Qualifications Requirements for 

Air Carrier Operations (Final Rule), the FAA stated:

“The Airline Safety and Federal Aviation Administration Extension Act of 2010 

(Pub. L. 111-216) directed the FAA to conduct a rulemaking to improve the 

qualifications and training for pilots serving in air carrier operations. Specifically, 

section 216 of the Act focused on the qualifications of air carrier pilots and 

directed the FAA to issue a rule that would require all pilots serving in part 121 

air carrier operations to hold an ATP certificate by August 2, 2013. Section 217 

of the Act directed the FAA to amend 14 CFR part 61 to modify ATP 

certification requirements to prepare a pilot to function effectively in a multipilot 

(multicrew) environment, in adverse weather conditions, during high altitude 

operations, and in an air carrier environment, as well as to adhere to the 

highest professional standards. Section 217 also directed the FAA to ensure 

pilots have sufficient flight hours in difficult operational conditions that may be 

encountered in air carrier operations...”2 (Emphasis added)

3. In the preamble to Part 121 §121.436, the FAA addressed comments on what type

of flight time should count for the 1,000 hours of experience.

a . For instructors, the FAA stated:

“...the FAA chose these particular operations in subpart K of part 91 and part 

135 because they are air carrier-like operations that require the PIC to hold an 

ATP certificate. The ability to fly at the airline transport pilot (ATP) certificate

level and have demonstrated this proficiency during evaluation is an important

regulatory differentiation. Specifically, these pilots will have gained 

experience as a PIC of a turbojet airplane...”3 (Emphasis added.)

b. For pilots, the FAA stated:

“The FAA first proposed that certain operations under part 135 should require 

an ATP certificate in 1977. In that NPRM, the FAA stated the requirement to 

hold an ATP certificate to act as PIC in some part 135 operations was ‘[. . .] 

based in part on operational complexity and the number of persons carried, 

would provide a level of safety more comparable to that provided by part 121.’ 

For these same reasons the FAA has determined that flight time acquired as 

a PIC in operations under §91.1053(a)(2)(i),and §135.243(a)(1) and flight time 

acquired as an SIC in part 121 operations should count towards the 1,000 

hour air carrier experience requirement. Operations under §91.1053(a)(2)(i) or 

§135.243(a)(1) require an ATP certificate, are multicrew operations, and 

generally use turbine aircraft and therefore are the most applicable to part 121 

 1 Public Law 111-216 The Airline Safety and Federal Aviation Administration Extension Act of 2010 Sec. 216 Flight Crewmember 

screening and Qualifications 2 Pilot Certification and Qualification Requirements for Air Carrier Operations Final Rule – FAA Docket No. FAA-2010-0100 

Page 42323 3 Ibid., 42337
Exemption Petition from 14 CFR Part 121 §121.436 Page 3 February 29, 2016

operations. The FAA has determined that, while other part 91 and part 135 

operations may involve certain elements that are relatable to part 121 

operations, the varied nature of operations does not make credit toward the 

1,000 hour requirement appropriate. As such, the proposed requirement that 

the 1,000 hours in air carrier operations may be a combination of time as PIC 

in operations conducted under §91.1053(a)(2)(i) or §135.243(a)(1) or as SIC 

in part 121 operations remains unchanged from the NPRM”4 (emphasis 

added)

4. In an exemption issued to Raymond A. Salmon, December 15, 20155

, allowing 

previous Part 121 PIC flight time to count toward the 1000 hours of PIC flight time 

required by 121.436, the FAA stated:

“A PIC in part 121 air carrier operations is expected to possess leadership 

and command abilities, including aeronautical decision making and the 

sound judgment necessary to exercise operational control of the flight. The 

intent of the 1,000-hour air carrier experience requirement in § 121.436(a)(3) 

is to prevent two pilots in part 121 operations with little or no air carrier 

experience from being paired together as a flightcrew in line operations. In 

addition, the intent of this rule is to ensure that pilots obtain at least one full 

year of relevant air carrier operational experience before assuming the 

authority and responsibility of a PIC in operations conducted in part 121 

operations (78 FR 42355).” (Emphasis added)

“...In issuing the final rule, the FAA identified the types of experience that 

qualify a pilot to serve as PIC in part 121 operations based, in part, on the 

applicability of the experience to part 121 operations. A previous PIC in part 

121 operations has exercised the privileges of an ATP certificate in a 

position where that certificate is required by rule in the United States, the 

operation was in a turbine aircraft and in a multicrew environment. That pilot 

has also previously demonstrated proficiency operating at this level through 

an FAA-approved training and qualification program. Therefore, the FAA 

finds that allowing a pilot’s time as PIC in part 121 operations to count 

toward the air carrier experience required by § 121.436(a)(3) would not 

adversely impact safety and supports the FAA’s goal of ensuring that a pilot 

possesses sufficient experience to assume the authority and responsibility of 

PIC in part 121 operations.” (Emphasis added)

5. Ameristar realizes that the FAA denied a similar exemption from §121.436 of Title 

14 to Gulf & Caribbean Cargo, Inc. 6

, in that exemption denial the FAA stated that:

“..it determined that the ability to fly at the airline transport pilot (ATP) 

certificate level and have demonstrated this proficiency during evaluation is an 

important regulatory differentiation.” (Emphasis added)

The FAA goes on to state in this denial of exemption from §121.436:

“The FAA determined that, while other part 91 and part 135 operations may 

involve certain elements that are relatable to part 121 operations, the varied 

nature of operations does not make credit toward the 1,000 hour requirement 

appropriate. Because turbojet pilots in part 135 cargo operations are not 

required to hold an ATP certificate, the time accrued in such operations does 

not count toward the requirements of § 121.436(a)(3)” (emphasis added).

 4 Ibid, 42356 and 42357

5 Regulatory Docket No. FAA-2014-0658 Page 4

6

 Denial Of Exemption Docket FAA-2014-0361 dated May 30, 2014
Exemption Petition from 14 CFR Part 121 §121.436 Page 4 February 29, 2016

6. In the preamble to Part 121 §121.436, the FAA stated that an evaluation of a pilot at 

the ATP level is an important regulatory differentiation:

“The FAA has determined that the ability to fly at the ATP certificate level and 

have demonstrated this proficiency during evaluation is an important regulatory 

differentiation.”

7

B. The basic elements for flight crewmembers experience as intended by Congress in the 

FAA Extension Act of 2010 for Part 121 (part 121) Operations8 consisted of:

1. Screen prospective flight crewmembers to assess the skills, aptitudes, airmanship, 

and suitability of each applicant for a position as a flight crewmember in terms of 

functioning effectively in the air carrier’s operational environment, 

2. Each flight crewmember must obtain an FAA Airline Transport Pilot Certificate 

(ATP), and

3. Have appropriate multi-engine aircraft flight experience, as determined by the 

Administrator.

C. The FAA in its final rule stated that it was complying with the FAA Extension Act of 2010 

to prepare pilots for the ATP certificate by changes to 14 CFR part 61 to modify ATP 

standards to include: 

1. Have experience in adverse weather conditions,

2. High altitude operations,

3. Experience in an air carrier environment,

4. Experience in multi-crew environment,

5. Sufficient flight hours in difficult operational conditions that may be encountered in 

air carrier operations, and 

6. Adherence to the highest professional standards

D. Applicable portions of 121.436:

1. The FAA issued its final rule on July 15, 20139 creating new requirements in

121.436. Before a pilot could become a PIC in part 121 operations, that pilot would be 

required to comply with the following requirements:

a. 1,000 hours of experience by serving as a PIC in operations under §§ 

91.103(a)(2)(i), 135.243(a)(1)

10, or as a second-in-command (SIC) in part 121

operations or any combination thereof. For those pilots who are employed as 

a pilot in command in part 121 operations on July 31, 2013, compliance with 

the requirements of this paragraph (a)(3) is not required.11

b. An SIC must have a type rating for the specific aircraft that he/she is going to 

fly,

c. A PIC must be at least 23 years old

 7 Ibid, 42356

8 FAA Extension Act of 2010 ¶a.2.

9 78 FR 42324

10 14 CFR Part 135.243(a)(1) requires an ATP for passenger operations. 11 14 CFR 121.436(a)(3)
Exemption Petition from 14 CFR Part 121 §121.436 Page 5 February 29, 2016

E. Arguments

1. It appears that the intent of the 1,000-hour air carrier experience requirement in 

§121.436(a)(3) is to prevent two pilots in part 121 operations with little or no air 

carrier experience from being paired together as a flight crew in Part 121 line 

operations. Since 91 subpart K operators are not air carriers and cannot hold out to 

the public, a deeper schism exists from their similarities to Part 121 air carriers than 

any Part 135 PIC

2. Similarities between a Part 135 all-cargo turbojet PIC and a part 135 passenger 

turbojet PIC are shown in Table 1. As can be seen in Table 1, a Part 135 PIC 

obtains the same experience in every aspect of a Part 135 operation in a turbojet 

aircraft whether it is operated with passengers on board or not. There is virtually no 

difference in the overall experience between an all-cargo Part 135 PIC and a

passenger-only Part 135 PIC. All Ameristar Jet Charter, Inc. PICs hold an ATP.

TABLE 1

Ameristar Jet Charter, Inc Part 135 All-Cargo 

Turbojet Operations

Part 135 Passenger 

Turbojet Operations

High Altitude Operations  

Operations in the national 

airspace system is the same  

Multi-crew environment  

Management of Aircraft systems 

are the same  

Weather knowledge, and weather 

minima are the same  

Same instrument approaches –

ILS, VOR, LOC, PRM, etc.

 

Subject to strict operational control  

Requires aircraft type rating 

issued by FAA or FAA designee  

Requires 6 month instrument 

proficiency Check – which is the 

same for an all-cargo pilot or 

passenger pilot at Ameristar Jet 

Charter, Inc since a pilot could fly 

either type of aircraft.

 

Requires yearly line check  

Aircraft handling characteristics, 

including takeoffs, landings, power 

management, engine out 

maneuvers, aircraft limitations, 

etc. are the same

 

Requires same amount of ground 

school hours  

If a PIC at Ameristar Jet Charter, 

Inc. can fly both passenger and 

cargo on the same aircraft type, 

an ATP is required.

 
Exemption Petition from 14 CFR Part 121 §121.436 Page 6 February 29, 2016

3. Table 2 illustrates some of the differences between Part 121, Part 135 and part 91 

subpart K. The purpose of this table shows that cargo and passenger operations 

conducted pursuant to Part 135 regulations are more closely related to Part 121 air 

carriers, whether the flights are operated as passenger or cargo.

TABLE 2

Differences Table for Part 135 and part 91 subpart K12

Part 121 Part 135 Part 91subpart K

Can hold out to public to conduct 

Common Carriage

Can hold out to public to conduct 

Common Carriage

NO Common Carriage – Cannot holdout 

to the public 14 CFR part 91.1005. Can 

fly only owners in the program. Very 

limited.

Certificate holder must be a U.S. 

Citizen

Certificate holder must be a U.S. 

Citizen U.S. Citizenship NOT required 

Air carrier is responsible for 

operational control. Persons 

exercising operational must be highly 

trained

Air carrier is responsible for operational 

Control. Persons exercising 

operational must be highly trained

NO Training required to perform the 

functions of operational control See 14 

CFR part 91.1009 through 1013. The 

fractional owner is in operational control 

of a flight.

Subject to 14 CFR part 119 Rules Subject to 14 CFR part 119 Rules

NO requirements under part 119. No 

certificate is issued (is NOT defined as an 

air carrier)

Drug and alcohol testing program 

required. Subject to 14 CFR part 120

Drug and alcohol testing program 

required. Subject to 14 CFR part 120 NO drug and alcohol testing required

Must have Director of Operations, 

Chief Pilot, Chief Inspector, Director 

of Safety and Director of 

Maintenance 14 CFR part 119 

§119.65

Must have Director of Operations, 

Chief Pilot and Director of Maintenance 

14 CFR Part 119.69

NO required management personnel or 

qualifications but must designate points of 

contact.

Line check of PIC required §121.440 Line check of PIC required 14 CFR part 

135.299

NO line check of pilots in command 

required

Subject to U.S. Department of 

Transportation (DOT) rules

Subject to U.S. Department of 

Transportation rules concerning aircraft 

size limit and registration

NOT subject to any DOT rules

Assigned FAA principal inspectors 

and inspection program subject to all 

types of FAA inspections

Assigned FAA principal inspectors and 

inspection program subject to all types 

of FAA inspections

NOT subject to FAA inspections for line 

checks and en route inspections.

Subject to FAA enroute inspections 

§121.548

Subject to FAA enroute inspections 14 

CFR part 135 §135.75

NOT Subject to FAA enroute inspections 

§91.1019(a)

Issued Operations Specifications Issued Operations Specifications Issued management specifications

Issued FAA U.S. Air Carrier 

Certificate

Issued FAA U.S. Air Carrier Certificate NOT a U.S. air carrier – no certificate is 

issued

Lower minimums established in 

§121.652(a) specifically allows credit 

for ALL 135 PICs operating under 14 

CFR part 91 operations.

May credit PIC experience gained in 

part 135 operations to meet the 

experience requirements of 

§121.652(a)

NO credit is given to any 91 subpart K 

experience to meet the requirements of 

121 §121.652 

Must report potentially hazardous 

weather §121.561

Must report potentially hazardous 

weather 14 CFR part 135 §135.67 NOT required

Certificate holder or PIC must restrict 

or suspend operations when hazards 

are known to exist for safe operations 

§121.553.

Certificate holder or PIC must restrict 

or suspend operations when hazards 

are known to exist for safe operations 

§135.69

NO language exists that requires 

restriction of operations when hazards 

are known for safe operations

 12 See AC91-84 Appendix 2, part 91 Subpart K, part 119, part 135 and part 121.
Exemption Petition from 14 CFR Part 121 §121.436 Page 7 February 29, 2016

4. Interestingly, Part 91 subpart K PICs are not able to credit PIC time toward the 

requirements stated in 14 CFR part 121 §121.652(a)13. Yet, there is no restriction on 

whether a PIC engaging in Part 135 operations is flying all-cargo or passenger aircraft to 

be able to credit his/her flight time as a PIC towards the §121.652(a) requirement. The 

relevant part of §121.652(a) states:

“...a Pilot in command employed by a certificate holder conducting operations in 

large aircraft under part 135 of this chapter, may credit flight time acquired in 

operations conducted for that operator under part 91 in the same type airplane for 

up to 50 percent of the 100 hours of pilot in command experience required by this 

paragraph.”

5. Part 91 subpart K, shown in Table 2 above, demonstrates the layers of requirements for a 

Part 135 air carrier vs. the requirements for a Part 91 subpart K operator. These layers 

translate into more management oversight of pilots in the Part 135 certificate holders vs. 

the Part 91 subpart K operators. These distinctions are what elevate a Part 135 air carrier 

to more closely resemble the requirements for Part 121 air carriers regardless of whether 

or not a pilot is flying all-cargo or passenger operations.

a. Ameristar is not discounting the experience allowed by Part 91 subpart K PICs, but 

rather demonstrating that the entire environment must be considered if the FAA is 

going to equate a Part 91 subpart K operation to a Part 135 operation. 

b. Since there is a large contingent of all-cargo Part 121 air carriers, the FAA can 

simply modify a grant of exemption for Ameristar to include the following 

requirement for pilots utilizing this exemption:

i. An ATP with an appropriate type rating

ii. The hours must be as PIC

iii. The hours must be in a multi-engine turbojet aircraft requiring at least 2 pilot 

crewmembers by type design.

6. In the denial of exemption from §121.436 of Title 14 to Gulf & Caribbean Cargo, Inc. 14,

the FAA stated that:

a. While it is true that a Part 135 PIC is not required to hold an ATP to be a PIC in Part 

135 operations. However, if a PIC does hold an ATP and is flying in Part 135 

operations as a turbojet PIC in a multi-engine and multi-crew environment in cargo 

operations, the quality of his/her flight time would clearly overcomes both of the 

FAA’s objections in denying Gulf & Caribbean Cargo, Inc.’s exemption request. 

This type of flying, as illustrated in Tables 1 and 2 above, meets the intent of 

Congress to have qualified pilots fly as PIC in Part 121 operations.

b. It is highly unlikely that a pilot flying a turbojet aircraft as a PIC in Part 135 all-cargo 

does not have an ATP. For this reason alone, the FAA should grant this exemption 

request and allow all Part 135 all-cargo turbojet PIC flight time towards the 

requirements of 121.436 since most, if not all, turbojet Part 135 PICs have an ATP.

 13 §121.652(a) sets forth landing ceiling and visibility requirements for PICs with less than 100 flight hours in Part 121 

operations. 14 Denial Of Exemption Docket FAA-2014-0361 dated May 30, 2014
Exemption Petition from 14 CFR Part 121 §121.436 Page 8 February 29, 2016

7. In addition to the strict standards of a Part 135 air carrier, further commonality exists 

between air carriers Ameristar Jet Charter (AJI Part 135) and Ameristar Air Cargo, Inc. 

(AAC Part 121). The following common traits between AJI and AAC are:

• Both are air carriers

• Shares a common Flight Control Facility

• Flight Control personnel are the same

• iPad usage for manuals and approach information

• Flight Planning

• Hazardous Materials Program

• Fatigue Risk Management Practices

• Scheduling practices

• Aircraft instrumentation (Flight Directors, Attitude Direction Indicators (ADI) Analog 

instruments, GPS, Altimeters)

• Turbojet – multi-engine engine aircraft 

• Require 2-pilot crew in accordance with aircraft type design (Multi-crew aircraft) 

• Freight comes from the same customers

• On-demand passenger and cargo charters serving over 300 airports in U.S., Central 

America, South America, Mexico, Canada and the Caribbean 

• Requires ATP to fly PIC – Ameristar Jet Charter, Inc. requirement

• Administrative paperwork

8. 14 CFR Par 135 §135.297 requires an instrument proficiency check each 6 months. An 

all-cargo pilot and passenger pilot at Ameristar Jet Charter, Inc. take the exact same 

proficiency check. This is the same requirement for Part 91 subpart K and Part 121 pilots 

as well. Since the all-cargo Ameristar Jet Charter, Inc. PIC is qualified on passenger and 

all-cargo operations, he/she must fly at the ATP certificate level and demonstrate his/her 

proficiency during each of these required evaluations. This evaluation meets the FAA’s 

concern for a pilot to be evaluated at the ATP certificate level on a regular basis.

9. Not requiring an ATP in Part 135 all-cargo operation, in and of itself, does not provide any 

layer of increased safety and does not provide a different set of experiences envisioned 

by Congress and the FAA. This is especially true for a pilot flying in the Part 135 

environment that holds an ATP, flies a multi-engine and multi-crew turbojet aircraft and is 

evaluated at the ATP certificate level twice a year. In other words, the requirement to 

hold an ATP vs. a PIC that does hold an ATP certificate in Ameristar Jet Charter, Inc.’s allcargo Part 135 environment would not be different to that pilot’s experience.

IV. Public Interest and Benefit: 

• The grant of exemption would increase the number of highly trained and experienced pilots 

who are qualified to fly as PIC in Ameristar’s Part 121 operations providing better support of 

the public’s air transportation needs.

• The public would benefit from an increased level of safety as a result of allowing pilots with 

extensive PIC experience in Part 135 air carrier operations to transition to PIC for a Part 

121 air carrier. 

• In the case of Ameristar, the commonality between it and Ameristar Jet Charter, Inc. is very 

similar and further adds to the layers of continuity that Ameristar would provide to the 

public’s air transportation needs.

• It is in the public interest to ensure that candidates with the best experience are available to 

serve as PIC in part 121 operations.
Exemption Petition from 14 CFR Part 121 §121.436 Page 9 February 29, 2016

V. This exemption would not adversely affect safety: 

• Granting this exemption would meet the FAA’s goal of ensuring that a pilot possesses 

sufficient experience to assume the authority and responsibility of PIC in part 121 

operations. 

• Due to the similarities between Ameristar Jet Charter (Part 135) and Ameristar Air Cargo, 

Inc (Part 121), the layers of safety would be increased. 

• In the case of an Ameristar Jet Charter, Inc. PIC, the overall structure is greater than that of 

a Part 91 subpart K PIC which, in turn, would provide a greater level of safety than the 

current rule.

• The training, qualifications and experiences of all-cargo Part 135 PICs, as shown above, 

would not adversely affect safety

VI. Summary for the Federal Register:

Ameristar Air Cargo, Inc. seeks an exemption from 14 CFR Part 121.436(a)(3) to the extent 

necessary to allow flight hours acquired as a PIC under 14 CFR Part 135 all-cargo operations 

while employed by Ameristar Jet Charter, Inc. in multi-engine and multi-crew turbojet aircraft

while holding an ATP certificate to count towards the experience requirements of 14 CFR part 

121 §121.436(a)(3).

VII. In the alternative, Ameristar would propose that for pilots subject to a grant of exemption, as 

requested in this petition, would be restricted to the following conditions:

a. Have at least 1 year experience as a PIC with Ameristar Jet Charter, Inc. (Part 135),

b. Hours flown in multi-crew and multi-engine turbojets as a PIC during all-cargo Part 135 

operations while holding an ATP may be counted towards the 1000 hours requirement of 

14 CFR part 121 §121.436(a)(3)

c. Have at least 1500 hours of turbojet multi-engine and multi-crew flight time in Part 121, 

Part 135 or Part 91 subpart K operations or any combination thereof,

d. Have at least 3000 hours total flight time

e. If the conditions of 14 CFR part 121 §121.436(a)(3) have not been met, that pilot would be 

restricted to all-cargo only flying until reaching at least 250 hours of SIC or PIC time in 

Part 121 operations on turbojet aircraft.

VIII If this petition is granted, Ameristar requests that this exemption include operations outside of 

the United States which would include areas of operations listed in its operations specifications 

providing economic benefits to all those areas 

IX. Ameristar requests that this petition be granted without the public notice procedures under 5 

U.S.C. 553(b).

Thank you for your consideration.

Sincerely

Pat Hulsey

Director of Operations

Ameristar Air Cargo, Inc.

972-725-9000 Ext 9601

phulsey@ameristarjet.com