# Florida Air Transport Inc

.

5820 Miami Lakes Drive East

Miami Lakes, Florida 33014

Telephone: 305

- 863

- 3108 Fax: 305

- 871

- 1622

Email:floridaairtransport@earthlink.net

May 23 , 2015

U.S. Department of Transportation

Federal Aviation Administration

1601 Lind Ave SW

Renton, WA 98057

Mr. Thomas J Leahy

Petition for Exemption from 14 CFR Part 125.265 (a ) (b) and 14 CFR Part 91.529 (a) (b).

Substance of Rule from which Exemption is sought:

Florida Air Transport seeks a n exemption from 14 CFR Part 125.265 (a) (b) and 14 CFR Part

91.529 (a) (b), “ Flight engineer requirements of 50 hours of flight time within 6 calendar months on

type airplane ”

.

Nature and Extent of Relief Sought

– Summery per FAR 11.81(f):

Florida Air Transport requests an exemption from the Flight Engineer requirements of 14 CFR

125.265 (a) (b) and 14 CFR Part 91.529 (a) (b)

. We currently oper ate one DC

- 6 , Serial Number 43720,

Registration N70BF aircraft on an Oil Spill contract; this aircraft is maintained and operated under our

Part 125 Operating Certificate Number: FLRB 946D. Due to the lack of flying we are required to

schedule every six mon ths for an FAA examiner. At the moment there is only one FAA examiner in

Alaska that is qualified to perform these Currency check rides.

It has become difficult to schedule this Flight Engineer c urrency ride due to the lack of DC

- 6

Operators and FAA perso nnel available . We are requesting that our Flight Engineers be approved to

maintain currency by using an Event Based Currency (EBC) program rather than obtaining 50 hours of

operating experience or completing a competency check every 6 months.1

Interest of the Petitioner:

Florida Air Transport has one Douglas DC

- 6 , Serial Number 43720, Registration N70BF which

requires a Flight Engineer during revenue flights ; we are the onl y DC

- 6 operator remaining in the

Continental U.S. This aircraft is under contract with National Response Corporation (NRC) for

emergency oil spill response such as what occurred in the Gulf of Mexico. This aircraft is on standby

24/7, we conduct quarterly training flights to keep our crew current. At best this aircraft is operated

less than 50 hours per year and it is impossible to maintain a current flight engineer with the current

flight engineer regulation requirements. This aircraft plays a critical rol e in the U.S. Emergency

Response System for Oil Spills in our oceans. It is used to protect our coastal water and beaches from

a similar disaster which occurred in the Gulf of Mexico. It is in the U.S. National interest to insure out

oceans are protected.

Florida Air Transport would establish an EBC program that would consist of training and

recordkeeping for our DC

- 6 airplane FE’s who would be subject to an annu al evaluation / check ride

by an FAA representative at the same time the FAA observes a pilot

- i n

- command proficiency check in

the airplane. The EBC program would consist of demonstrated normal, abnormal and emergency

operations; the use of checklists; and the computation of airplane performance. This program would

provide alternate method of determi ning each FE’s competency in the airplane. Attached to this

request is a copy of the proposed EBC program. This EBC program would be implemented should the

exemption be granted.

Equivalent Level of Safety:

The DC

- 6 airplanes were certified with an FE be cause of their complexity, however the Airplane

Flight Manual allows for a two pilot operation when the flight is non

- revenue. All the systems that the

FE was responsible for are easy accessible to the two pilots while seated at their stations and other

sy stems have been removed or deactivated which reduces the work load for the two pilots. All of our

flight engineers are also A&P mechanics who work on the aircraft constantly to maintain it in

airworthy conditions at all time s under our FAA approved mainten ance inspection program

. Our

company check airman is also a flight engineer and will be able to conduct the proficiency rides to our

flight engineers as well as our pilots. We feel this is an equivalent level of safety and t he granting of

this exemption wi ll have no adverse impact whatsoever. The FAA has granted a similar request in the

past, please see Exemption No. 7255 attached, no precedents will be made by granting this exemption

request.

Each Flight crew member assigned to perform FE duties on our ai rplane must:

a) Each of our flight engineer will hold an FE certificate with a reciprocating engine powered rating.

b) Have completed Florida Air Transport qualification and recurrent events based flight and ground

training program for the DC

- 6 airplane w ithin the previous 12 calendar months

c) Perform duties while the pilot crewmembers perform three takeoffs and three landings to a full stop

within the previous 180 days before serving as an FE.Public Interest :

A grant of this exemption serves the public interest in several ways:

1. This aircraft is on standby 24/7 for any emergency oil spills that may occur in the Gulf of Mexico or

in the Atlantic Ocean.

2. It is used to protect our wate r and environment.

3. Safety will not be compromised in any way whatsoever.

4. Florida Air Transport is a small minority owned FAR 125 Air Operator.

5. Granting this exemption is essential to our operation and would remove the hardship.

6. A similar exemp tion has been granted in the past (Exemption 7255).

7. Florida Air Transport is an All

- Cargo Part 125 Operator; we do not carry any passengers.

Summary:

Florida Air Transport seeks a n Exemption from 14 CFR Part 125.265 (a)(b) and 14 CFR Part

91.529 (a)(b)

. We are requesting that our Flight Engineers be able to maintain curren cy under our EBC program.

Expedited Handling :

Florida Air Transport is requesting that the exemption request be expedited ; Public input should not be

required; similar exemption has b een granted in the past.

Communication with Florida Air Transport :

Within the limits of applicable FAA policy, I will be available to clarify or discuss this petition with

FAA o fficial responsible for processing this exemption and in particular to consider any adjustments

that might address agency requirements. I may be reached at (305) 218

- 0619 or (305)593

- 8847.

Sincerely,

Carlos Gomez

Vice

- President

Director of Maintenance

2DC

- 6 Flight Engineer Event Based Currency Program

(EBC)

Event Number of Other Than a

Events per Year yearly event

Review power settings, Climb, METO and Takeoffs 2 1 each, every 6 months

Engine Sta r t

- Battery only 6 1 each

, every 2 months

____________________________________________________________ _____________________ Engine Run

- up 6 1 each

, every 2 months

Engine analyzer usage (Check engine and spark plugs) 6 1 each

, every 2 months

Carburetor deice and anti

- ice checks 2 1 each

, every 6 months

Hydraulics System, Brake system (alternate and normal) 1

Flap usage in taxing 1

Takeoffs 6 1 each

, every 2 months

Power and R unway C omputations 6 1 each

, every 2 months

Set up of fuel takeoffs 6 1 each

, every 2 months

Setting power takeoffs 6 1 each, every 2 months

Propeller control and manual toggles 4 1 each, every 3 months

Auto

- Feather (if installed) 2 1 each, every 6 months

Engine power setting

- METO and Climb 6 1 each, every 2 months

Cruise 6 1 each, every 2 months

Engine power setting

- cruise 6 1 each, every 2 months

Engine Manual leaning and sp ark advance (if installed) 4 1 each, every 3 months

Fuel management

– cruise 3 1 each, every 4 months

Propeller setting using manual toggles 3 1 each, every 4 months

Engine analyzer to synchronize propellers 2 1 each, every 6 months

Abnormal and Emergency Procedures

Engine Shutdown in flight (Simulated shutdown) 2 1 each, every 6 months

Feather 1 Simulated shutdown

Unfeather 1 Simulated Restart

Drill: 2 engines left and right 2 1 each, every 6 months

Simulated once each side (Zero thrust

- pair)

Engine out procedures

Approach 2 1 each, every 6 months

Landing 2 1 each, every 6 months

Touch and Go 2 1 each, every 6 monthsGo around and rejected landing 2 1 each, every 6 months

Tw o engines

- out procedures (Simulate an d discussion between left and right side engine out events)

Left Engine 1

Right Engine 1

Go Around 1

Over

- Speed propeller 1

Uncontrollable and runaway propeller 1

Propeller contro l with failed tachometer 1

Fuel leak in flight 1 Discussion only

Hydraulic system 2 1 each, every 6 months

Hydraulic pump failure 1

Hydraulic system contaminated 1

Hydraulic failure troubleshooting 1

Manual extension of the landing gear 1 Discussion and actual

Manual Extension of the flaps 1 Discussion and actual

Landing with unsafe landing gear 1 Discussion

Fire warning system 1 Discussion

Knowledge of fire procedures 1

Knowledge of smoke evacuation procedures 1

Knowledge of pressurization (if installed) 1

Knowledge of air conditioning (if installed) 1

Electrical system generator failure 2 1 each, every 6 months

Loss of all gene rators 1

Inverter failure 2 1 each, every 6 months

Review of fuel dump procedure 2 1 each, every 6 months

Fuel Dump computation 1

Fuel dumping discussion 2 1 each, every 6 months

Fuel dumping actual 1

Discontinue after fuel vapor is seen from that tank’s dump chute