Western Global Airlines, LLC 9260 Estero Park Commons Blvd Estero, FL 33579 November 16, 2015 U
.S. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJersey 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 takeoffand landing, during the Operating Experience as specified by 14 CFR 121.434. WGA is requesting the FAA to permitWGA to substitute aqualified and authorized Check Airman or Aircrew Program Designee, (APD), in place ofan FAA inspectorto observe aqualifying pilot in command who is completing the initial or upgrade training specified in Section 121
.424 during at least one flight leg that includes atakeoffand a landing
.WGA has an approved APD program and currently employs three (3) APDs underthe supervision ofourAircrew Program Manager, (APM), Inspector George Farinas ofCM0-67
.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/orAPDs be designated forthis authority; all ofthe candidates proposed by WGA to complete these observations are very highly experienced with many years ofCheck Airman and/orAPD 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, orthat it be granted aseparate but similar exemption
. WGA is predominantly engaged in international flying
. Requiring an FAA inspectorto 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 Inspectorto obtain foreign country clearance. WGA is an ad-hoc ACMI air carrier and rarely has the abilityto schedule aflight thirty days in advance
. Most, if not all ofOperating Experience for initial and upgrade training will be conducted outside ofthe United States ofAmerica. WGA requests the privileges ofthe exemption outside ofthe United States of America due to FAA Inspector availabilityforeign country clearance requirements
.

### Granting this exemption is in the public interest in that it allows the FAA to utilize Inspectorsfor more immediate needs, and should also provide financial savings in avoiding FAA inspectortravel 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 ofthis request. 

# fi}4.tL;7 f""""' Thomas 

### J. Quehl 

## f'
. Vice President ofOperations