# Florida Air Transport Inc

. 5820 Miam i Lakes Drive East Miam i Lakes, Florida 33014 Telephone: 305

- 863

- 3108 Fax: 305

- 871

- 1622

Em ail:floridaairtransport@earthlink.net February 2 , 2015 U.S. Department of Transportation Docket Management Sy stem, Room PL401 400 7 th Street, Southwest Washington, D.C.

**Petition for Exemption**  **from 14 CFR Part 125.265 a nd 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 ty pe 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 currentl y operate one DC

- 6 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 fl yi ng 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 pilo ts under §125.285 Pilot qualifications

.

1**Interest of the Petitioner:**

Florida Air Transport has one Douglas DC

- 6 which requires a Flight Engineer; we are the onl y DC

- 6 oper ator 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 f lights to keep our crew current. At best this aircraft is operated less than 50 hours per ye ar and it is impossible to maintain a current flight engineer with the current flight engineer regulation requirements. We request that our flight engineers be allo wed 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 play s 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 require ments 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 time s . Our compan y check airman is also a flight engineer and will be able to conduct the proficiency rides to our flight engi neers as well as our pilots. We feel this is an equivalent level of safet y 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 way s: 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. I t 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 Fl ig ht Engineers be able to maintain curren cy 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.

**2 Communication with Florida Air Transport**  :

Within the limits of applicable FAA policy , I will be available to clarify or discuss this petition with FAA off icial responsible for processing this deviation and in particular to consider an y adjustments that might address agency requirements. The undersigned can be reached at (305) 218

- 0619 or (305)593

- 8847.

Sincerel y,
Carlos Gomez Vice

- President Director of Maintenance

3§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 ty pe certificate was issued before January 2, 1964, having a maximum certificated takeoff weight of more than 80,000 pounds. (2) An airplane t ype certificated after January 1, 1964, for whi ch a flight engineer is required b y the ty pe 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 t ype airplane or has been checked by the Administrator on that ty pe 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 mad e at least three takeoffs and three landings within the preceding 90 day s, 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 ty pe (if a t ype 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 pa ragraph (a)(1) of this section, a person may act as a pilot in command of an aircraft under day VFR or day

I FR, provided no persons or propert y are carried on board the aircraft, other than those necessary for the conduct of the flight. (3) The takeoffs and landings required b y paragraph (a)(1) of this section may be accomplished in a flight simulator or flight training device that is

— (i) Approved b y the Administrator for landings; and (ii) Used in accordance with an approved course conducted b y a tr aining 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 t ype 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 t ype airplane, o r the Administrator has checked that person on that ty pe 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 certificat e holder may use any person, nor may

any person serve, as a required pilot flight crewmember unless within the preceding 90 calendar day s that person has made at least three takeoffs and landings in the t ype airplane in which that person is to serve. The t akeoffs and landings required by this paragraph may

be performed in a flight simulator if the flight simulator is qualified and approved b y the Administrator for such purpose. However, an y person who fails to qualify for a 90

- consecutive

- day

period followi ng 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 sect ion may

reestablish recency

of experience b y 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 crit ical 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.