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

February 2, 2015

U.S. Department of Transportation

Docket Management System, Room PL 401

400 7th Street, Southwest

Washington, D.C.

Petition for Exemption from 14 CFR Part 125.265 and 14 CFR Part 91.529

Substance of Rule from which Exemption is sought:

Florida Air Transport seeks an exemption from the 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 and 14 CFR Part 91.529. We currently operate one DC-6 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 check rides.

It has become difficult to schedule these Flight Engineer check rides due to the lack of DC-6 Operators 

and FAA personnel available. We are requesting that our Flight Engineers be approved to maintain 

current under the same requirements as our pilots under §125.285 Pilot qualifications. 

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Interest of the Petitioner:

Florida Air Transport has one Douglas DC-6 which requires a Flight Engineer; 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. We request that our flight engineers 

be allowed to meet the qualification requirements the same as the other flight crew members; as out 

lined in §125.285 Pilot qualifications: Recent experience. This aircraft plays a critical role in the U.S. 

Emergency Response System for Oil Spills in our oceans.

Equivalent Level of Safety:

Florida Air Transport is requesting the removal of the Flight Engineer requirements under §125.265 

and that they be replaced by the requirements for the pilots under §125.285 Pilot qualifications: 

Recent experience. 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. 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.

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.

Summary:

Florida Air Transport seeks an Exemption from 14 CFR Part 125.265 and 14 CFR Part 91.529.

We are requesting that our Flight Engineers be able to maintain currency under the same requirements 

as our pilots are required under §125.285 Pilot qualifications. 

Expedited Handling:

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

required.

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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 deviation and in particular to consider any adjustments 

that might address agency requirements. The undersigned can be reached at (305) 218-0619 or 

(305)593-8847.

Sincerely,

Carlos Gomez

Vice- President

Director of Maintenance

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§91.529 Flight engineer requirements.

(a) No person may operate the following airplanes without a flight crewmember holding a current 

flight engineer certificate: 

(1) An airplane for which a type certificate was issued before January 2, 1964, having a maximum 

certificated takeoff weight of more than 80,000 pounds. 

(2) An airplane type certificated after January 1, 1964, for which a flight engineer is required by the 

type certification requirements. 

(b) No person may serve as a required flight engineer on an airplane unless, within the preceding 6 

calendar months, that person has had at least 50 hours of flight time as a flight engineer on that type 

airplane or has been checked by the Administrator on that type airplane and is found to be familiar and 

competent with all essential current information and operating procedures

§61.57 Recent flight experience: Pilot in command.

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a 

pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one 

pilot flight crewmember unless that person has made at least three takeoffs and three landings within 

the preceding 90 days, and—

(i) The person acted as the sole manipulator of the flight controls; and 

(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and 

type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the 

takeoffs and landings must have been made to a full stop in an airplane with a tailwheel. 

(2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act as 

a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are 

carried on board the aircraft, other than those necessary for the conduct of the flight. 

(3) The takeoffs and landings required by paragraph (a)(1) of this section may be accomplished in a 

flight simulator or flight training device that is—

(i) Approved by the Administrator for landings; and 

(ii) Used in accordance with an approved course conducted by a training center certificated under part 

142 of this chapter.

§125.265 Flight engineer requirements.

(a) No person may operate an airplane for which a flight engineer is required by the type certification 

requirements without a flight crewmember holding a current flight engineer certificate. 
(b) No person may serve as a required flight engineer on an airplane unless, within the preceding 6 

calendar months, that person has had at least 50 hours of flight time as a flight engineer on that type 

airplane, or the Administrator has checked that person on that type airplane and determined that person 

is familiar and competent with all essential current information and operating procedures.

§125.285 Pilot qualifications: Recent experience.

(a) No certificate holder may use any person, nor may any person serve, as a required pilot flight 

crewmember unless within the preceding 90 calendar days that person has made at least three takeoffs 

and landings in the type airplane in which that person is to serve. The takeoffs and landings required 

by this paragraph may be performed in a flight simulator if the flight simulator is qualified and 

approved by the Administrator for such purpose. However, any person who fails to qualify for a 90-

consecutive-day period following the date of that person's last qualification under this paragraph must 

reestablish recency of experience as provided in paragraph (b) of this section.

(b) A required pilot flight crewmember who has not met the requirements of paragraph (a) of this 

section may reestablish recency of experience by making at least three takeoffs and landings under the 

supervision of an authorized check airman, in accordance with the following:

(1) At least one takeoff must be made with a simulated failure of the most critical powerplant.

(2) At least one landing must be made from an ILS approach to the lowest ILS minimums authorized 

for the certificate holder.

(3) At least one landing must be made to a complete stop.