Paul D. Salvati 

12560 N.W. 83rd. Court 

Parkland, Florida 33076-4931 

(954) 7 48-6197 

Fax(754)229-6782 

E-Mail: imcflying@bellsouth.net 

U.S. Department of Transportation 

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 of 61.156 and academic and FTSD 

requirements of 14 C.F.R. 61.156(a) and (b) 

I am requesting a waiver of the 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 A TP 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 However, my ATP license was revoked 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) of the 

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 of 61.156. A complete copy of the 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 of the written graduation certificate ensures an 
equivalent level of safety. Obviously, I will still be required to demonstrate 

my knowledge and proficiency on the written and practical A TP 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 prior training 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 of the 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 of this 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~ Pilot Proficiency Check Job Aid 

Certificate No: 2 5~8" 3</--7 3 

Aircraft Type· £b--.;:{?-~ -:2-

Captain F/0 

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Preflight 

Equipment examination 

Preflight inspection 

Taxiing 

Powerplant Checks 

Takeoffs 

Normal 

Instrument 

Crosswind 

Powerplant failure 

Rejected 

Instrument 

Area departure 

Holding 

Area arrival 

NormaiiLS approach (coupled if applicable) 

Engine-out ILS (manually controlled) 

Non-precision approach v tl ((__ 

Second non-precision approach I _f') c..-. 

Non-precision GPS approach (SJU base only) 

Circling approach 

Missed approach from ILS 

Second missed approach . 

In-flight Maneuvers 

Steep turns 

Approach to stalls 

Powerplant failure 

Landings 

Normal landing 

Landing from ILS 

Crosswind landing 

Engine-out landing 

From circling approach 

Rejected landing 

Procedures 

Normal procedures 

Abnormal procedures 

Emergency procedures 

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Unit 6: Simulator Qualification Checkride 

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Unit 7: LOFT (not applicable for non-advanced sim) 

Instructor: Date: ----- Training Hours: ___ _ 

Instructor Signature: ___________ _ Instructor ID: ____ _ 

Unit 8: Airplane Training (not applicable for advanced sim) 

Instructor: Date: ----- Training Hours: ___ _ 

Instructor Signature: ___________ _ Instructor ID: 

Instructor Cert No: ____ _ 

Airplane Qualification (not applicable for advanced sim) 

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New Hire I Initial Equipment I Transition I Upgrade(Long) I Requalification 3 
' . Jun 14 05 12:45p Carlos M. Hernandez 787-253-6463 

TO: ALL PILOTS/DISPATCHERS 

FROM: Captain Carlos M. Hernandez {Director of FUght Standar·<~~c.JIIB':rA 

DATE: June9, 2005 

RE: Dispatch Procedures for Dominica (DOM) 

This is to clarify dispatch procedures for Dominica 

PROCEDURE: Note that the procedure is labeled "CLOUD BREAK". It 

provides a means for the flight to descend below the· minimum enroute altitude 

while in IMC to a point in space where the flight crew can request a visual 

approach if they establish visual contact with the airport . The actual approach to 

the airport after completion of the letdown is under VMC as determined by the 

flight crew. The procedure is not an instrument approach procedure leading to a 

point where a landing can be made from circling maneuver within the runaway 

environment. 

WEATHER: Minimum weather forecast and reported at ETA required for 

dispatch: 

Ceiling -1,500 ft Visibility- 3 sm {4.8 km) 

Explanatory notes on weather: 

1. Although the procedure calls for a cloud break at 2,600 ft the ceiling 

required is 1,500 ft. The reason fur this dmerence is that the airport 1s 

surrounded by high terrain and dense tropical vegetation. Furthermore, the 

airport is located on the windward side of the island. The wind and the 

mountains provide lifting action for the moisture generated by the vegetation. 

This moisture condenses as it rises producing low-level clouds. Remember that 

the temperature of this rising is lower that the surroutllding air because of the 

energy absorbed by the vegetation itsetf. The clouds-generated in this region will 

form at a lower altitude than normal because of the cool and very humid air. 

2. The procedure as depicted provides for the flight to descend east of the 

airport, over the water and clear of any obstacles. In this region, atmospheric 

conditions are different that over the ground specified above - the amount of 

water vapor in the air is less, and the lifting action is ~reater because of radiation 

heat In this case, clouds will also form but at a higher altitude, as the air is 

warmer and not as humid. (water vapor has to rise to a higher altitude 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 FAA published a final rule establishing a second-in-command 

(SIC) type rating in order to conform with International Civil Aviation Organization (ICAO) pilot qualification 

standards. This FAA initiative has been under way since November 2004. Its purpose is to prevent U.S. flights 

and crews from being grounded by foreign civil aviation authorities when SICs do not possess the applicable 

type rating for operating in international airspace. While the effective date of this rule is September 6, 2005, air 

carriers and their flight crewmembers serving as second-in-command have until March 6, 2006, to comply with 

the new rule (14 CFR Part 61.55). The rule does NOT apply to those pilots flying domestically in U.S airspace, 

but one should not confuse the term "domestically" with any rest provisions that treat Canada or Mexico as 

"domestic." If you operate into cities outside the U.S., you need to comply. 

Historically, the FAA has found it unnecessary to require an SIC type rating because it already requires annual 

recurrent knowledge and flight training for Part 121 and 135 U.S. flight crews. Unfortunately, this longstanding FAA position is unsatisfactory to some European and Caribbean states, who have recently informed 

the U.S. that they intend to enforce the ICAO SIC type rating standard on U.S. flight crews who fly in their 

arrspace. 

A type rating for SIC privileges can be issued to a pilot after completing the SIC familiarization training 

required by 14 CFR Part 61.55(b ). Basically, if you have a current PC, this is a paperwork exercise. 

RECOMMENDATIONS: 

• If you are affected by this rule, immediately contact your Chief Pilot to apprise him or her of this 

requirement and to request his or her assistance in following the application and certification process 

outlined on page 3 of the final rule (please visit ALP A's e-library at www.crewroom.alpa.org). 

• Notify your LEC or MEC training representative, or your FO representative about this rule. 

FAA's Airmen Registry Office is sending out a memorandum of instruction to all pertinent agency field offices 

with samples of a 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 on this bulletin to 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