Raylllean Customer Success

Is Our Mission 20 November,
2015 U. S. Department

of Transportation Docket Operations West Building Ground Floor Room W12-140 1200 New Jersey Avenue,

SE. Washington,

D.C. 20590 Subject: Request

for Exemption

RMT Program Office El Segundo,

CA 310-334-3149 Ref: CFR 14 Federal Aviation Regulations

Part 91.529(b} ---Flight Engineer Currency Requirements Dear Sir or Madam: This request

for exemption

is being submitted

by Captain
Jim Brown lowe, Chief Pilot for the Raytheon Multi-program Testbed (RMT} that

is owned

by the Raytheon Space and Airborne Systems (RSAS} Company.

This airplane

is a Boeing 727-223 that has been modified

to test new systems being developed

by RSAS for use by the Government

and the Armed Forces.
The airplane operates under 14 CFR Part 91 and has

a Special Airworthiness Certificate

in the Experimental- Research

and Development Category.

In addition

to the primary flight crew, the airplane carries test engineers

and other personnel
that are essential

for the testing conducted

on the airplane.

The airplane does not carry passengers

or cargo for hire. The airplane

is flown

by pilots and flight engineers employed

by Raytheon.

The pilots are all former military pilots that have extensive experience

in the test and evaluation

of aircraft, both

in development

and operationally.

All pilots hold Airline Transport
Pilot Certificates

and attend annual proficiency training

in accordance

with 14 CFR 61.58 for Pilots

in Command

in the B-727. Currently, we have four pilots that are dual qualified

as flight engineers.

The airplane flies about 300 to 400 hours annually,

but the schedule often has peaks and valleys due to the flexibility
that

is required

to support test operations. This letter

is a petition

for exemption
from the requirements

of 14 CFR 91.529(b} which states: "No person may serve

as
a required flight engineer

on an airplane unless, within the preceding

6 calendar months, that

a person
has had
at least
50 hours

offlighttimeasaflightengineeronthattypeairplaneorhasbeencheckedbytheAdministratoronthattypeairplaneandisfoundtobefamiliarandcompetentwithallessentialcurrentinformationandoperatingprocedures."ReliefSoughtThisrequestforexemptionistopermitthecombinedhoursattainedasapilotandflightengineerintheB727tobeusedtosatisfythe50hourseverysixmonthstoretainflightengineercurrency.Alldualqualifiedpilotsandflightengineerswillcontinuetoreceiveanannualpilotproficiencycheckunder14CFR61.58aswellasanannualflightengineerproficiencycheckunder14CFR91.529.BackgroundRSAShasoperatedtheRMT(B727Testbed)since2003andaccumulatedover4500testhoursonthisairplane.Theairplaneoperatesoversparselypopulatedareasduringtestflightsnormallyinoff-shorewarningareas(W291)oron-shorerestrictedareas(R-2508}.TheairplanehasbeenmodifiedtomeettherequirementsfortestingRaytheonsystemsand,asaresult,someoftheoperatingprocedureshavebeenmodified.TheseprocedureshavebeenreviewedandacceptedbytheLAXFlightStandardsDistrictOffice(LAXFSDO).Recently,RSAShaselectedtodualqualifysomeofourRaytheonflightcrewaspilotsandflightengineers.Thiswasdoneinordertoincreasetheoverallflighttime(eitherasapilotorflightengineer)forourflightcrewinordertokeepallcrewmembersmoreproficientandcurrentintheairplane.However,giventhelimitedflighthourstheRMTfliesinatypicalyear,itisverylikelythatmostofourdualqualifiedflightengineerswillbeunabletoattaintherequired50hoursinasixmonthperiodofflightengineertimetocomplywith14CFR91.529(b).However,theywillbeabletoattainmorethan50hourscombinedasapilotandflightengineerinasixmonthperiod.Insendingflightengineersbackforre-currencytrainingwhentheyfailtomeetthe50hourrequirement,weareoftenrequiredtosendthembackwithoutanRMTsupportcrew.Thisisduetothelimitednumberofpilotswehaveonstaffandthedemandsthatmayoccurtofulfilltestprojectsundergovernmentcontract.Becauseofthis,there-currencycheckisoftenconductedwithsupportpilotsthatareunfamiliarwithRaytheon'sspecialproceduresuniquetoourmodifiedB727.Thus,ourflightengineersaredeniedtheopportunitytotrainutilizingthesespecialproceduresduringthese6-monthchecks.Thisresultsinsuboptimaltrainingduringthisre-currencytraininganddoesnotservethepurposeforwhichtheregulationwasdesigned.Whenactingasacrewmemberonthe727,thepilotsandflightengineerscloselymonitortheperformanceofeachpositionwhileworkingasacrew.Inthecaseofdualqualifiedcrewmembers,theythoroughlyknowtheresponsibilitiesofeachcrewstation.Therefore,usingthecombinedhourstosatisfythe50hourflightengineercurrencyrulemakessenseinthatthesystemfamiliarityandproficiencyreinforcementthatistheintentoftheruleisaccomplishedwhileservingaseitheraflightengineerorpilot.The Public Interest We believe this request

is in the public interest,

as it will reduce the overall cost required

to fulfill government contracts which support vital defense systems

for our Armed Forces. Costs savings include reduced simulator

and instructor
cost; reduced travel and labor cost; and reduction

in lost flight test productivity

time during training. More importantly,

this request
will enhance public safety

by allowing

for more effective training

on an annual basis using our Raytheon special procedures

as
a crew vice "generic" training using unfamiliar support crews during

ad hoc training sessions

to maintain currency under the existing requirement. Because
our systems

are unique

in some areas, failing

to train specifically

for our equipment
using "generic" training may build bad habit patterns
and potentially

lead to human factors errors. Effect
on Safety Changing

the requirement

to allow hours logged

in both the pilot and flight engineer seats
to count towards
the flight engineer currency requirement

will not have

a negative effect

on safety. The intent

of the requirement
under

14 CFR 91.529

is to ensure that those serving solely

as flight engineers

are "familiar

and competent
with
all essential current information

and operating procedures maintain

a minimum
level
of currency." When the regulation

was written,

it likely did not account

for dual qualified personnel.

Our dual qualified pilots will still be required

to log at least 50 hours combined
time

as
a pilot and

I or flight engineer each six month period, thus maintaining familiarity

and competence

with the airplane's systems
and operations. Additionally,

they will continue

to be checked

by the Administrator

as both

a pilot and flight engineer during their annual proficiency check. Furthermore,

as stated above, training annually

as
a crew will allow

us to use our unique procedures

and enhance Crew Resource Management training

as
a result. This will provide

a positive safety benefit. Waiver

of the 120 Day Public Comment Period We are requesting

a waiver

to the 120 day public comment period based upon this exemption will only affect our limited operation

and pertain only to our modified Boeing 727. Our operations are for research

and development purposes conducted under controlled conditions

and over sparsely populated areas that do not subject
the travelling public

to additional

risk. Summary Raytheon Space and Airborne Systems requests

an exemption
from the requirement

of 14 CFR 91.529

to permit our dual qualified Boeing 727 pilots and flight engineers

to use the combined hours logged

in the pilot and

I or flight engineer position

to meet the 50 hour every
six month requirement------------

----

- ---- ------ for flight engineer currency.
Each dual qualified pilot and flight engineer

will continue

to be checked by the Administrator annually during

an annual proficiency check

in both positions. Because

of the nature

of our operation, there

is no risk to the travelling public due to this exemption

and

it will likely increase
our level
of safety

by allowing

for better training opportunities

as a crew
on an annual basis vice ad hoc training driven

by the

6 month flight engineer currency requirement. Respectfully Submitted

, **~ t:t'~**  Chief Pilot Raytheon Space and Airborne Systems 6150 West Century Blvd. Los Angeles,

CA 90045 310-227-3569