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! ! ! ! ! ! ! ! ! ! ! ! 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. Instructor 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 extra 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 individuals 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 airline 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-
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op into more confident and disciplined pilots, and be better mentors for their fellow pilots.

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 retirement 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 training development projects for the FAA.

Summary: 14 CFR Part 61.73G regulation dealing with CFI issued on the basis of Military 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 instructor copilots who were trained and qualified to perform instructor duties. The following 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’ mandated instructor training, and assignment to instructor duties that were the practice during 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 recurrent training of the crews.
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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 required 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 copilot training to base level recurrent training and checking as the experience proved 

successful in completing the requirements at the base/squadron level.