TO: Federal Aviation Administration 

Office of the Chief Counsel 

800 Independence Ave, S.W., 900 East 

Washington, D.C. 20591 

1.) PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION §63.39 (a) AND (b) (1}, 

(2}, (3} ALONG WITH THE THREE PHASE PRACTICAL TEST REQUIREMENT OUTLINED IN FAA-S-8081-21 

WITH CHANGES 1, 2, AND 3 BASED ON MILITARY COMPETENCE 

2.) PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION §61.213 (a) (3} BASED 

ON MILITARY COMPETENCE 

PETITIONER: 6TH AIR REFUELING SQUADRON 

FLIGHT ENGINEER SECTION 

585 HICKAM AVE 

BLDG: 181 

TRAVIS AFB, CALIFORNIA 94535 

Primary POC: MSgt John McCarty 

Work: 707-424-7608 

Cell: 707-853-6607 

Email: john.mccarty.1@us.af.mil 

Secondary POC: SSgt Alex D. Reynolds 

Work: 707-424-7608 

Cell: 813-389-5882 

Email: alex.reynolds.1@us.af.mil 
PETITION FOR EXEMPTION 

The U.S Air Force KC-1 0 flight engineer community seek an exemption from Title 14 C.F .R 

Section §63.39 (a) and (b), (1), (2), and (3) along with the three phase practical test requirement 

outlined in FAA-S-8081-21 with Changes 1, 2, and 3 based on military competence for a person 

who is a military flight engineer or former military flight engineer of the U.S. Armed Forces. 

This petition seeks to request an evaluation of Air Force flight engineer training courses leading 

to certification as a military flight engineer using the established standards for the civilian sector 

to the extent necessary to allow current and former members meeting the requirements of 

sections §63.31, §63.33 (a), §63.35, and §63.37 along with supporting documents determined by 

the administrator to be granted a Federal Aviation Administration Flight Engineer Certificate 

with the appropriate aircraft rating based on military competence specific mission design series 

(MDS). The above petition serves to mirror the current standards set forth in § 61.73 Military 

pilots or former military pilots: Special rules. 

The U.S Air Force KC-1 0 Instructor flight engineer community also seeks an exemption from 

Title 14 C.F.R Section§ 61.213 (a) (3) based on military competence for a person who is a U.S 

military instructor flight engineer or U.S military flight engineer evaluator or a former instructor 

flight engineer or evaluator flight engineer. This exemption would allow current and former 

members meeting the requirements of sections §61.213 (a) (1 ), (2), and ( 4) as appropriate along 

with supporting documents determined by the administrator to be granted a Federal Aviation 

Administration Ground Instructor Certificate based on military competence. The above petition 

serves to mirror the current standards set forth in §61.73 (g) Military pilots or former military 

pilots: Special rules. 
The members of KC-1 0 flight engineer community are confident that they have met and 

exceeded the training standards outlined in the applicable C.F.R I P.T.S specifically §63.39 (a) 

and (b) (1), (2), and (3) and FAA-S-8081-21 with Changes 1, 2, and 3 expanded task areas for 

flight engineers and§ 61.213 (a) (3) for ground instructors (Fundamental of Instructing) by 

attending the following Air Force training courses: Aircrew Fundamentals- Flight Engineer 

w/Physiological Training, Basic Flight Engineer-Undergraduate Flying Training, KC-1 0 Flight 

Engineer Basic Pre-Qualification, KC-10 Flight Engineer Initial Qualification (Phase 1A and 

1 B), KC-1 0 Flight Engineer Mission Qualification/ Mission Certification Training, KC-1 0 

Continuation Training, KC-1 0 Academic Instructor Course, Flight Engineer Instructor CoursePhase 1A, and Instructor Flight Engineer Qualification - Phase lB. Members would also be 

required to present a passing knowledge test report for flight engineers based on§ 63.35 (a) (b) 

and for ground instructors based on § 61. 213 (a) ( 4) as appropriate for the rating sought. The 

knowledge test report would not exceed 24 calendar months since being valid. Please see 

documents provided for a complete breakdown of each training curriculum in regards to the 

exemptions sought. 

This petition serves to recognize the hard work and dedication of our flight engineer service 

members who have underwent months of intensive Air Force training and who possess 

comparable knowledge and skills as defined by the administrator in the various documents 

appropriate to the certificate sought. This would be of benefit to the public as those individuals 

who have completed military flight engineer training courses would have their credentials 

evaluated using the same criteria found in the civilian sector. Also by using the established 

standards applicable to the civilian sector, the administrator could be confident that safety would 

not be jeopardized. Unlike military pilots who have a separate competence examinations tailored 
to their situation, the current FAA written test administered to the civilian sector would suffice 

for military flight engineer and instructor flight engineer or evaluator's wanting to take the 

written test to demonstrate their respectively knowledge skill areas of 63.35 (a) (b) and 61.213 

(a) (4) as applicable. Furthermore this would motivate enlisted aircrew veterans to continue with 

a career in aviation after the military, thus using their knowledge to strengthen training and 

operational standards throughout the aviation industry thereby giving back to the public sector. 

An exception to the current Code of Federal Regulation being sought would not degrade current 

or future aviation safety standards as Air force flight engineer are held to very high standards of 

initial and continuation training. The intent of this petition does not serve to lessen the standards 

set forth in current directives, as member would still be required to accomplish the written test 

for both flight engineer and ground instructor (aeronautical knowledge areas) and meet or exceed 

the passing score of 70%. Furthermore current and former flight engineer members seeking to 

utilize this exception to satisfy the flight engineer requirements would have to show recent 

experience within the previous 12 calendar months. If not they would be required to complete a 

written and flight test appropriate to the rating sought. We are continually evaluated through a 

periodic evaluation system, mandatory annual check-rides annotated on AF Form 8 and are 

required to complete quarterly refresher training on emergency and abnormal procedures, aircraft 

systems, and CRM as a basic crew employing two pilots and a flight engineer in order to remain 

current and qualified to performed military flight engineer duties. This training is completed over 

a period of two days with each day comprising of a two hours of academics followed by four 

hours in a full motion simulator where emergency and abnormal procedures are expected to be 

accomplished at a proficient level. Members meeting the requirements of this petition and the 

administrator final rule would be able to provide evidentiary document showing they have not 
been removed from flying status for lack of proficiency or because of disciplinary action 

involving aircraft operations. Of particular note is the hardship in finding a current and qualified 

FAA flight engineer examiner or designated representative to complete the practical portion of 

the flight check. 

Please note that the documents provided do not represent the entire Air Force flight engineer 

training curriculum and as such this petition is only applicable to turbojet powered aircraft class 

rating specific to the KC-10. On the behalf of the U.S Air Force KC-10 Flight Engineer's, we are 

grateful to administrator for considering this exemption and look forward to a favorable 

rulemaking on this petition. Please forward any additional questions or concerns to Master 

Sergeant John McCarty or Staff Sergeant Alex Reynolds via the telephone numbers or emails 

listed above. Thanks. 

Very Respectfully, 

X 

John McCa , MSgt, USAF 

KC-10A Flight Engineer 

Alex D. Reynolds, SSgt, USAF 

KC-10A Flight Engineer