U.S. Department of Transportation

Docket Management Facility 1200 New Jersey Avenue, SE We st Building Ground Floor Room W12

- 140 Wa shington, DC 20590 Petitioner: Swift Air, LLC. Sections of FAR Affected Regulation Affected: 14 CFR 61.157(a) 14 CFR 61 Appendix A Item I(b) 14 CFR 121.424(a) and (b) and (d)(1) 14 CFR 121 Appendix E Item I(a) 14 CFR 121 Appendix F Item I(b) Description of Relief Sought **:** Swift Air, LLC for Exemption No. 4416. The exemption permits operators to conduct training and checking of pilots of airplanes requiring only two flight crewmembers on the required preflight inspection, both interior and exterior, using approved advanced pictorial means

. **Discussion** A. Preflight Visual Inspection. The preflight visual inspection is one of the most important elements of preparation for flight. The exemptions cited above contemplate the use of sophisticated, advanced pictorial systems that exceed the practical limitations imposed by use of an actual airplane. Pictorial systems provide the inspector or examiner a unique opportunity to evaluate the depth of the subject pilots preflight inspection knowledge to an extent not available on static airplanes. End

- products are a higher degree of proficiency in flight crews and a greater level of safety overall. Regulations and the exemptions themselves offer little specific quality criteria for reference by inspectors and operators in addressing advanced pictori al systems. The following guidance shall apply: (1) General Characteristics. The FAA must approve each pictorial system in its entirety. The following are desirable characteristics: (a) a sufficient number of pictures to portray the location and detail of preflight inspection items: (b) capability for random, rapid access to any picture, (c) still and motion pictures, (d) distant and close

- up pictures, (e) pictures of each passenger compartment and each preflight inspection item,(f) depictions o f normal and abnormal conditions, and

(g) sequence of pictures should match the flow of the actual preflight inspection. (2) Specific Characteristics. Experience has shown that the following specific characteristics are appropriate. Inspectors should det ermine that these characteristics are included: (a) Enough pictures should be m aintained to permit coverage of a variety of preflight items in practical tests. (b) The aircraft should be shown in a typical prior

-to

-flight condition, which may include sup port people and equipment which are associated with flight preparation, such as fueling, cleaning, and catering. (c) Nothing should obstruct the view of the preflight item (jetways, fuel trucks, workstands, etc.). (d) The same aircraft, or identical airc raft, should be pictured throughout the pictorial series; in some cases use of non

- identical aircraft may be justified to depict differences. (e) Text and voice should match each picture. (f) Pictorial systems used for testing should be of high quality, including projection equipment with random and rapid access capability. Examples of unacceptable quality include copy

- machine copies of photographs, videotape systems without random and rapid access capability, or any other pictorial system that is markedl y inferior to use of a static airplane. (g) For testing, sets of pictures should be used which comprise some of those used in training, and additional pictures used exclusively for testing. (h) For testing, abnormal features should not be shown in pictur es intended to depict normal aircraft conditions. (i) Unless an abnormal condition is intentionally depicted for testing, the following guidelines shall apply:

a. All permanent parts, such as windows and doors, windshield wipers, and antennas, should be in place and in normal condition. b. All removable parts, such as engine cowls and access panels, should be in place and in normal condition; engine inlets should be shown with covers removed. i. Wh eel well doors, flaps, slats and aerodynamic surfaces and other devices should be in the normal on

- ground, prior

-to

-flight configuration, and ii. People and equipment associated with assembly or maintenance work should not be pictured. (j) For testing, enough pictures of abnormal conditions should be maintained to p ermit comprehensive coverage, particularly of those abnormal conditions which are likely to be encountered during preflight inspection and those which are potentially unsafe.(k) For testing, aircraft should be pictured which are typical or representativ e of the

specific aircraft on which the pilot certification is to be conducted. For example, slides of a B

- 737

- 300 should not be used for a certificate applicant trained under a B

- 737

- 200 curriculum; and vice versa. (3) Standard References. The FAA

- appro ved preflight procedures contained in the manufacturers aircraft flight manual, or in the air carriers aircraft flight manual, are the standard references for the preflight visual inspection. Those manuals detail the essential preflight items and the sequ ence in which those items should be inspected. (4) Strategy and Courseware. W hen using pictorial means, for optimum effectiveness, the courseware should be used differently in training and in testing. In general, static pictorial displays (pamphlets, murals, etc.), videotape, and interactive computer

- based instruction (CBI) systems work well in training. On the other hand, slides work well in testing. Similarly, when using pictorial means the training strategy is different from the testing strategy. In ge neral, during training the trainee should view preflight items in normal configurations. This method conveys positive imprinting to a trainee, and it is the same method followed when a static airplane is used. (However, it is beneficial to discuss abnormal conditions in training). On the other hand, during testing abnormal conditions should be introduced in a sufficient number to permit a reliable evaluation of the applicant ` s preflight ability. **Exemption not Precedent Setting** Swift Air understands that the FAA has granted several exemptions to individual operators for similar relief sought by this request. Therefore, since granting the exemption is not precedent setting, Swift Air requests that publication of our petition in th e Federal Register be waived in accordance with Section 11.27(j)(3) as a delay for publication and comment procedures in the Federal Register would be detrimental to Swift Air.
Respectfully,
Douglass Chouinard Chief Pilot Swift Air, LLC. I5EA212N dchouinard@flyswiftair.com