P.O. Box 700548, Da llas, Texas 75370

- 0548 (972) 725

- 9000  FAX (972) 725

- 9090 D o c k et M a n agement F a cili t y U

. S

. De p artment of T r a n s p o r t a t i on
12 0 0 New J ersey A v e n ue, S E

West Buil d i n g

, G r ound F lo or

, Ro o m W1 2

- 1 4 0 Washington, D

. C

. 2059 0

February 2 9 , 2016

Re: Peti t ion for E xemp t ion

V ia E lectr o n i c F i ling

Dear S i r or M a d am:

Pu r suant to 1 4 C F R Pa r t 1 1

, Ameristar Air Cargo, Inc. (Ameristar) respectfully submits this p e t i t ion for

e xemption f r om a portion of 1 4 C F R 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 add r ess: Pat Hulsey, Director of Operat ions, Ameristar Air Cargo, Inc. , 4400 Glenn Curtiss Drive, Addison, TX 75001

II. Relief is sought from 14 C FR 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 (Pa rt 1 35 ) 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 a cquired 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 hold s an ATP while acting as PIC in Part 135 cargo operations.

A. Background The FAA promulgated 121.436 as the result of congressio nal 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 i n 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 (F AA 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 f or 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

- empl oyment screening, including anExemption Petition from 14 CFR Part 121 §121.436 Page 2 February 2 9 , 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 Crewme mbers.

— 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 R ule), 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. Specif ically, 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 th e 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 carrie r 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 a dded)

3. I n t he p r e a mble t o Part 121 §121.436, the F A A a dd r ess e d co m men t s on w h at type

of f li g ht t i me sh o u l d co u nt f or the 1

, 00 0 h o u r s of experie n ce.

a . For instructors, the F AA st a t e d :

“... 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 a bil i t y t o fly a t t h e a ir l i n e t r a n sp o r t p il o t (A T P ) c e r t if ic at e
l e vel an d h a v e d em o n st r at ed t his profi c ie n c y d u ri n g e v al u at i o n is a n i m p o r t a n t

r egu l a t o ry d if f er ent i a t io n

. Specifically, these pilots will have gained experience as a PIC of a turbojet airplane ...” 3 (Em p hasis a dd ed .)

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 s afety 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 12 1

1 Public Law 111

- 216 The Airline Safety and Federal Aviation Administration Extension Act of 2010 Sec. 216 Flight Crewmember screening and Qualifications

2 Pilo t Certification and Qualification Requirements for Air Carrier Operations Final Rule

– FAA Docket No. FAA

- 2010

- 0100
Page 42323

3 Ibid., 42337Exemption Petition from 14 CFR Part 121 §121.436 Page 3 February 2 9 , 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 appropria te. 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 (e mphasis added)

4. In an exemption issued to Raymond A. Salmon, December 15, 2015 5 , 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 relev ant 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

q ualify 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 certifica te 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 suf ficient 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 th at 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 opera tions 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, 2014Exemption Petition from 14 CFR Part 121 §121.436 Page 4 February 2 9 , 2016

6. I n t he p r e a mble t o Part 121 §121.436, the F A A stated that an evaluation of a pilot at

t he 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 proficienc y 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) Operations 8 consist ed 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 C ertificate (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 cha nges 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. T he F A A issued its f i n al r ule on July 1 5

, 20 1 3 9 crea t i n g n e w r e q ui r eme n ts in

121.436. Before a pilot could become a P I C in p art 12 1 op e r a t ions, that pilot would be required to comply with the following requirements:

a. 1, 00 0 h o u r s o f experie n ce by ser v i n g as a PIC in op e r a t ions under §§

91

. 1 0 3 (a) ( 2 ) ( i), 135

. 2 4 3 (a) ( 1 ) 10

, or as a s econd

- in

- command ( S I C) in p art 12 1

op e r a t ions 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 SI C 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 2 9 , 2016

E. Arguments

1. It appears that the intent of the 1,000

- hour air carr ier experience requirement in § 121.436(a)(3) is to prevent two pi lots 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 an d 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 Ame ristar 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

- c rew 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 rati ng 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 bot h passenger and cargo on the same aircraft type

, an ATP is required

.  Exemption Petition from 14 CFR Part 121 §121.436 Page 6 February 2 9 , 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 purs uant 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 K 12

Part 121 Part 135 Part 91subpart K

Can hold out to p ublic 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 Certifi cate 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 operation al 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 op erational control of a flight.

Subject to 14 CFR part 119 Rules Subject to 14 CFR part 119 R ules 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 alco hol 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 req uired 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

Su bject 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 Issue d 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 r equired

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 restric t 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 2 9 , 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 i n 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 req uirements 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 wh at elevate a Part 135 air carrier to more closely resemble the require ments 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 subpa rt 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 carrie rs, 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 re quiring 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 operati ons. 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 G ulf & 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 turboje t 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, turboj et 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, 2014Exemption Petition from 14 CFR Part 121 §121.436 Page 8 February 2 9 , 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

• Sch eduling practices

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

instrumen ts, GPS, Altimeters)

• Turbojet

– multi

- engine engine aircraft

• Require 2

- pilot crew in accordance with aircraft type design ( Multi

- crew aircraft)

• Freight com es from the same customer s

• On

- demand passenger and cargo charters serving over 300 airports in U.S., Central America, South America, Mexico, Canada and the Caribb ean

• Requires ATP to fly PIC

– Ameristar Jet Charter, Inc. requirement

• Administrative paperwork

8

. 14 CFR Par 135 §135.297 requires a n instrument proficiency check each 6 months

. An

all

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

p roficiency 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 proficien cy during ea ch of these required evaluation s

. 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 experienc es 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 a nd multi

- crew turbojet aircraft and is evaluated at the ATP certificate level twice a year

. In other words, the requirem ent to
hold an ATP vs. a PIC that does hold an ATP certifi cate in Ameristar Jet Charter, Inc

. ’ s all

cargo Part 135 environment w ould not be d ifferent to that pilot’s experience

.

IV. Public I n terest and Benefit :

• The grant of exemption would increase the number of highly trained and experienced pilots who are qualified t o 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 Ameris tar 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 PI C in part 121 operations.Exemption Petition from 14 CFR Part 121 §121.436 Page 9 February 2 9 , 2016

V. Th is 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 Amer istar Air Cargo, Inc (Part 121)

, the layers of safety would be increased.

• In the case of an A meristar Jet Charter, Inc. PIC, the overall structure is greater than that o f

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 e xemption 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. i n multi

- engine and multi

- crew tu rbojet aircraft while holding an ATP certificate to count towards the experience requi rements of 14 CFR part

121 § 121.436(a)(3)

.
VII. In the alternative

, Ameristar would propose that for pilots sub ject 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 m ay be counted towards the 1000 hours requirement of 14 CFR part 121 § 121.436(a)(3)

c. Have at least 15 00 hours of turbojet multi

- engine and multi

- crew flight time in Part 121,

Part 135 or Part 91 subpart K o perations or any combination thereof,

d. Ha ve 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 25 0 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 economi c 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 you r consideration.

Sincerely

Pat Hulsey Director of Operations Ameristar Air Cargo, Inc.

9 72

- 725

- 9000 Ext 9601 phulsey@ameristarjet.com