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 an 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 operate 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: FLRB946D. Due to the lack of flying we are required to 

schedule every six months 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 currency ride due to the lack of DC-6 

Operators and FAA personnel 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 only 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 role 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 annual evaluation / check ride 

by an FAA representative at the same time the FAA observes a pilot-in-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 determining 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 because 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 

systems 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 times under our FAA approved maintenance 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 the granting of 

this exemption will 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 airplane 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 within 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 water 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 exemption 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 an 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 currency 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 been 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 official 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

 2 
 DC-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 Start- Battery only 6 1 each, every 2 months 

 

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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 Runway Computations 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 spark 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 months
Go around and rejected landing 2 1 each, every 6 months

Two engines- out procedures (Simulate and 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 control 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 generators 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