A.! ! ! ! ! ! ! ! ! ! ! ! June 27, 2015

U.S. Department of Transportation

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

RE: Petition for Exemption, Regulation Part 61.73G

Dear Sirs:

Regulation Part 61.73G, as it is written, does not reference the position of Instructor Copilot. During the 1960’s, the Strategic Air Command (SAC), was rapidly building a fleet of flight simulators for training and checking programs to offset the deployment of many resources that were required for the operations in South East Asia. SAC was the only Major Command that launched a program to select certain high time copilots to be trained to USAF instructor pilot standards and assigned to instructor duties, i.e. Instruc

tor Copilots . As required by USAF standards and as outlined in AF Manual 50-9, these selected copilots were trained and certified as pilot instructors, certified as First Pilots in the KC-135 flight simulators, and put on orders as pilot Instructors to perform the training and evaluations for fellow pilots.

My supporting documents, AF orders, AF logged time, AF check rides, etc., show both Instructor Copilot and First Pilot designations for the years I was involved with this ex

tra duty. Without reference to this type of instructor position ( Instructor Copilot ) in Part

61.73G

, my request for Mil Comp CFI status has been denied.

I believe my instructor qualifications in both first pilot and copilot positions in the KC-135 flight simulator and aircraft meet the necessary requirements to obtain the Mil Comp CFI.

Granting the exemption to Part 61.73G to recognize the position of Instructor Copilot for the CFI (Military Competence) requirements would allow me to train and mentor in

dividuals with various levels of pilot experience, and help them reach their goals as professional pilots. With my USAF instructing background and 33 years of major air

line experience in line flying and training functions, I feel well qualified to motivate pilots to improve their skills and professionalism, and with this effort, these individuals devel

-A. op into more confident and disciplined pilots, and be better mentors for their fellow pi

lots.

Allowing a experienced professional pilot with my instructor background to be involved with pilot development and training would be of benefit to the overall goal of building the most professional group of pilots possible for the aviation industry. Ultimately, the benefit would be passed on to the traveling public as a whole because the training would encourage providing the highest level of safety and professionalism.

Granting my request would not adversely affect safety primarily because my goal would be to enhance flight safety philosophies that I have learned in my 50 years of accident free flying. My USAF background as a pilot and instructor provided me with a path to American Airlines where I experienced a 33 year career of line flying and many years of Check Airman and FAA Designee status on several aircraft types. After retire

ment I continued with instructional duties for Boeing, Flight Safety International, and the FAA Technical Center in Atlantic City, New Jersey, where I was involved with train

ing development projects for the FAA.

Summary: 14 CFR Part 61.73G regulation dealing with CFI issued on the basis of Mili

tary Competency. The regulation fails to include the fact that selected copilots, while serving in the Strategic Air Command, were trained and awarded Instructor status on the KC-135 Jet Tanker. I’m requesting this assignment would satisfy the requirements

of Part 61.78G.!!!!!!!!!!!!! To support this petition, I have attached USAF documents and statements to support my request for exemption to Part 61.73G definition of ‘ Instructor ’, and to include in

structor copilots who were trained and qualified to perform instructor duties. The fol

lowing documents are selected relevant documents that I have preserved, the others I have retained are available to further document my background.

A. Statements from a retired career officer regarding the practice of ‘on base’ mandat

ed instructor training, and assignment to instructor duties that were the practice dur

ing those war years.

B. Completed USAF Form 8s showing both First Pilot and Instructor Copilot check rides that I completed for the Instructor status assignment. Stan/Eval Assignment check ride was the requirement to be assigned to the Standboard/Evaluation

Branch at a USAF base for the purpose of instructing and evaluations during recur

rent training of the crews.A.

C. USAF form 5 showing both first pilot and instructor copilot time logged.

D. USAF Special Orders, M-37, designating Instructor status after completion of re

quired instructor training.

E. USAF documents showing the origination of copilots being selected for instructor duties and qualifications for selection process. The program morph from initial copi

lot training to base level recurrent training and checking as the experience proved successful in completing the requirements at the base/squadron level.