### Paul D. Salvati 

### 12560 N.W. 83rd. Court Parkland, Florida 33076-4931 (954) 748-6197 Fax(754)229-6782 E-Mail: imcflying@bellsouth.net

U.S. Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, S.E. Washington, DC 20590 Attn: Administrator, Federal Aviation Administration
RE: ATP Written Test Requirements- Petition for exemption from graduation certificate requirement of61.156 and academic and FTSD requirements of 14 C.F.R. 61.156(a) and (b)
I am requesting a waiver ofthe ATP written test requirements set forth in FAR section 61.156 and 61.156(a) and (b). This new regulation became effective on August 1, 2014, and requires the completion of academic and FTSD training and an ATP written graduation certificate when applying for the ATP knowledge test. My date of birth is August 17, 1955. I am 59 years old. I currently hold Airman Certificate Number 3168984 (copy enclosed). I continuously held an FAA Single and Multi-Engine Air Transport Pilot license from July 4, 1996 to February 14, 2013. However, my ATP license was revoked pursuant to an Emergency Order of Revocation issued on February 14, 2013. That Emergency Order stated that I violated Section 120.33(b) ofthe Federal Aviation Regulations; the Emergency Order of Revocation did not involve any issue of my skill or knowledge as an airman. Following the period of revocation specified in the Order, I retested and obtained the ratings reflected in my current Airman Certificate so I could return to my

### career as a commercial airline pilot. I plan to take the ATP written and practical examinations to complete the recertification necessary to return to service as an airline pilot at a U.S. air carrier. The FAA has a policy after a revocation that during the recertification process the airman must complete the written exams and take the practical flight tests, however the airman's prior experience is recognized and the airman need not repeat practical experience. In my case the FAA recognized that I had more than 8,000**acciden~** 

### and incident free flying hours when I took all the written exams and practical flight tests in issuing the ratings reflected on my current Airman Certificate.
I was employed as a line pilot with American Eagle 

### I ENVOY Airlines since February 22, 1999 and held a type rating on the ATR in the positions of Captain and First Officer. During this time I underwent academic and FTSD training in substantial compliance with and beyond the intent and requirements of61.156. A complete copy ofthe training program can be obtained from the FAA P.O. I. 

### for American Eagle 

### I ENVOY airlines. I have enclosed what records are shared with the crewmembers but it is not a complete record.
As written, 61.156 does not expressly state that my prior class room and simulator training with my Part 121 airline will count for the new ATP written test requirements as my flight experience counted to reacquire my current airman ratings.
The simulator and class room instruction I have received as a line pilot with my Part 121 airline completely covers all the areas that are required by the new ATP written regulation, 61.156.
If I am required to obtain an ATP written graduation certificate simply to repeat academic and FTSD training subjects already documented in the air carrier training records as successfully completed, the additional burden and expense would be significant and there would not be any enhancement of air safety. As a result of my past academic and simulator training at the airline, my requested waiver ofthe written graduation certificate ensures an

### equivalent level ofsafety. Obviously, I will still be required to demonstrate my knowledge and proficiency on the written and practical ATP test.
The ATP graduation certificate that 61.156 requires is currently offered at only one or two schools in the U.S. My financial resources are limited and my livelihood is being affected by this inability to take the ATP written exam. I have addressed the issue giving rise to the Emergency Revocation which was not related to my operational knowledge or competency as a pilot. No public purpose would be served by requiring me to obtain the ATP written graduation certificate pursuant to FAR Section 61.156. To the contrary, the delay and expenses necessary to obtain a certificate for subjects I have already accomplished by through priortraining would be contrary to the public interest and would impose an unnecessary burden on the transportation system by requiring a pilot to repeat academic and simulator training for all practical purposes identical to that already received and passed.
14 CFR Section 11.81 specifies that my request should provide a summary that you can publish in the Federal Register. That summary follows:
1. The rule from which I seek exemption is FAR 61.156. 2. The exemption I seek is an exemption from requirement of an ATP written graduation certificate. 3. The information which supports my request is: a) I have over 8,000 hours total time; b) I previously held an ATP; c) my ATP was revoked for reasons not related to my knowledge or skill as an airman; d) my action in obtaining the ATP written certificate would involve substantial delay and expense; and e) the waiver ofthe academic and simulator graduation certificate requirement in my case will provide an equivalent level of safety in the air transport system as I have previously met and surpassed the tasks and standards specified in the regulation.
Your consideration ofthis request is deeply appreciated.

### Please contact me if you have any questions or need any additional information. Sincerely,

Captain Paul D. Salvati**~~ ~.**  r < " 

## American Eagle Training Center**American~** 

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## . Jun 14 05 12:45p Carlos M. Hernandez 787-253-6463



### TO: ALL PILOTS/DISPATCHERS FROM: Captain Carlos M. Hernandez{DirectorofFUght**Standar·<~~c.JIIB':rA** DATE: June9, 2005 RE: Dispatch Proceduresfor Dominica (DOM)

This is to clarify dispatch proceduresfor Dominica PROCEDURE: Note thatthe procedure is labeled "CLOUD BREAK". It provides a meansfor the flightto descend belowthe·minimum enroute altitude while in IMC to a point in space where the flight crew can request a visual approach iftheyestablish visual contactwith the airport

. The actual approach to the airport aftercompletion ofthe letdown is underVMC as determined by the flight crew. The procedure is not an instrument approach procedure leading to a pointwhere a landing can be madefrom circling maneuverwithin the runaway environment. WEATHER: Minimum weather forecast and reported at ETA required for dispatch: Ceiling -1,500ft Visibility- 3 sm{4.8 km) Explanatory notes on weather:
1. Although the procedure calls for a cloud break at 2,600ft the ceiling required is 1,500ft. The reason furthis dmerence is

### that the airport 1s surrounded by high terrain and dense tropical vegetation. Furthermore, the airport is located on thewindward side ofthe island. The wind and the mountains provide lifting action forthe moisture generated 

### bythe vegetation. This moisture condenses as it rises producing low-level clouds. Rememberthat the temperature ofthis rising is lowerthat the surroutllding air because ofthe energyabsorbed bythevegetation itsetf. The clouds-generated inthis region will form at a loweraltitude than normal because ofthe cool and very humid air.
2. The procedure as depicted provides fortheflight to descend east ofthe airport, overthewater and clear ofany obstacles. In this region, atmospheric conditions are different that overthe ground specified above

- the amount of water vapor in the air is less, and the lifting action is**~reater** because ofradiation heat In this case, clouds will alsoform but at a higher altitude, as the air is warmerand not as humid. (water vapor hasto rise to a higheraltitude for condensation to occur). p. 1

## TO BE POSTED IN DOMICIU


# ALPA OPERATIONS BULLETIN 2005-09
SUBJECT: Second-in-Command (SIC) Type Rating
BACKGROUND: On August 4, 2005, the FAApublished a final rule establishing a second-in-command (SIC) type rating in orderto conformwith International Civil Aviation Organization (ICAO) pilot qualification standards. This FAA initiative has beenunder way since November 2004. Its purpose is to prevent U.S. flights and crews from being groundedby foreign civil aviation authorities when SICs do notpossess the applicable type rating for operating ininternational airspace. While the effective date ofthis rule is September 6, 2005, air carriers andtheir flight crewmembers serving as second-in-commandhave until March 6, 2006, to comply with the newrule (14 CFRPart 61.55). The rule does NOT apply to those pilots flying domestically inU.S airspace, but one shouldnot confuse the term "domestically" with any restprovisions thattreat Canada orMexico as "domestic." Ifyou operate into cities outside the U.S., you need to comply. Historically, the FAAhas found it unnecessary to require an SIC type rating because it already requires annual recurrentknowledge and flight training for Part 121 and 135 U.S. flight crews. Unfortunately, this longstanding FAAposition is unsatisfactoryto some European and Caribbean states, who haverecently informed the U.S. thatthey intendto enforce the ICAO SIC type rating standard on U.S. flight crews who fly intheir arrspace. A type rating for SIC privileges canbe issuedto a pilot after completing the SIC familiarization training requiredby 14 CFRPart 61.55(b). Basically, ifyou have a currentPC, this is a paperworkexercise.
RECOMMENDATIONS:

• Ifyou are affectedbythis rule, immediately contactyour ChiefPilotto apprise him orher ofthis requirement andto request his orher assistance in following the application and certificationprocess outlined onpage 3 ofthe final rule (please visit ALPA's e-library at www.crewroom.alpa.org). • Notify yourLEC orMEC training representative, oryourFO representative about this rule.
FAA's AirmenRegistry Office is sending out a memorandum ofinstructionto all pertinent agency field offices with samples ofa completed**Fi~.A** Form 8710-1, Application, and FA_""a

.... Form 8060-4, Temporary Airmen Certificate for the SIC type rating.
Please direct any questions onthis bulletinto the Engineering and Air Safety Department at 1-800-424-2470 or EAS@alpa.org.
September 12, 2005 Captain Terry McVenes Executive Air Safety Chairman