Western Global Airlines, LLC 

9260 Estero Park Commons Blvd 

Estero, FL 33579 

November 16, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Subject: Request for Exemption from 14 CFR 121.434(3) (c) (1) (ii)- Docket FAA-2014-0310 

Dear Sir/Madam: 

Western Global Airlines, LLC ("WGA") is requesting an exemption from 14 CFR 121.434(3) (c) (1) (ii), the 

requirement for a Pilot in Command completing initial or upgrade training to be observed by a Federal 

Aviation Administration ("FAA") Inspector during at least one flight leg which includes takeoff and 

landing, during the Operating Experience as specified by 14 CFR 121.434. 

WGA is requesting the FAA to permit WGA to substitute a qualified and authorized Check Airman or 

Aircrew Program Designee, (APD), in place of an FAA inspector to observe a qualifying pilot in command 

who is completing the initial or upgrade training specified in Section 121.424 during at least one flight 

leg that includes a takeoff and a landing. WGA has an approved APD program and currently employs 

three (3) APDs under the supervision of our Aircrew Program Manager, (APM), Inspector George Fa rinas 

of CM0-67. WGA is in the MOU process with FAA CM0-67 for an approved APD program for our Boeing 

747-400 fleet and will be training an FAA APM . WGA proposes check airmen and/or APDs be designated 

for this authority; all of the candidates proposed by WGA to complete these observations are very highly 

experienced with many years of Check Airman and/or APD experience. 

WGA currently has an exemption request, Docket FAA-2014-0310, which has been forwarded to 

rulemaking for review and approval. However, WGA's Principal Operations Inspector has advised us that 

the current grant will be limited to the MD-11 fleet. WGA desires that its B-747-400 fleet also be 

included in the exemption granted, or that it be granted a separate but similar exemption. 

WGA is predominantly engaged in international flying. Requiring an FAA inspector to conduct the 

observation results in a substantial burden on both the FAA and WGA due to the thirty day lead time 

required for an FAA Inspector to obtain foreign country clearance. WGA is an ad-hoc ACMI air carrier 

and rarely has the ability to schedule a flight thirty days in advance. 

Most, if not all of Operating Experience for initial and upgrade training will be conducted outside of the 

United States of America. WGA requests the privileges ofthe exemption outside ofthe United States of 

America due to FAA Inspector availability foreign country clearance requirements. 
Granting this exemption is in the public interest in that it allows the FAA to utilize Inspectors for more 

immediate needs, and should also provide financial savings in avoiding FAA inspector travel expense. It 

will also allow WGA to more expeditiously complete Operating Experience for initial new hire and 

upgrade pilots-in command. Moreover, similar exemptions have been routinely granted to other 

carriers in the past, and no purpose would be served by publishing this application in the Federal 

Register. 

WGA appreciates your consideration of this request. 

fi}4.tL;7 

f""""' Thomas J. Quehl 

f' . Vice President of Operations