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 

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 of 
the B727 to be used to satisfy the 50 hours every six months to retain flight engineer currency. All 

dual qualified pilots and flight engineers will continue to receive an annual pilot proficiency check 

under 14 CFR 61.58 as well as an annual flight engineer proficiency check under 14 CFR 91.529. 

Background 

RSAS has operated the RMT (B727 Testbed) since 2003 and accumulated over 4500 test hours 

on this airplane. The airplane operates over sparsely populated areas during test flights normally in 

off-shore warning areas (W291) or on-shore restricted areas (R-2508}. The airplane has been 

modified to meet the requirements for testing Raytheon systems and, as a result, some of the 

operating procedures have been modified. These procedures have been reviewed and accepted by 

the LAX Flight Standards District Office (LAX FSDO). 

Recently, RSAS has elected to dual qualify some of our Raytheon flight crew as pilots and flight 

engineers. This was done in order to increase the overall flight time (either as a pilot or flight 

engineer) for our flight crew in order to keep all crew members more proficient and current in the 

airplane. However, given the limited flight hours the RMT flies in a typical year, it is very likely that 

most of our dual qualified flight engineers will be unable to attain the required 50 hours in a six month period of flight engineer time to comply with 14 CFR 91.529(b). However, they will be able to 

attain more than 50 hours combined as a pilot and flight engineer in a six month period. 

In sending flight engineers back for re-currency training when they fail to meet the 50 hour 

requirement, we are often required to send them back without an RMT support crew. This is due to 

the limited number of pilots we have on staff and the demands that may occur to fulfill test projects 

under government contract. Because of this, the re-currency check is often conducted with support 

pilots that are unfamiliar with Raytheon's special procedures unique to our modified B727. Thus, our 

flight engineers are denied the opportunity to train utilizing these special procedures during these 6-

month checks. This results in suboptimal training during this re-currency training and does not serve 

the purpose for which the regulation was designed. 

When acting as a crew member on the 727, the pilots and flight engineers closely monitor the 

performance of each position while working as a crew. In the case of dual qualified crew members, 

they thoroughly know the responsibilities of each crew station. Therefore, using the combined hours 

to satisfy the 50 hour flight engineer currency rule makes sense in that the system familiarity and 

proficiency reinforcement that is the intent of the rule is accomplished while serving as either a flight 

engineer or pilot. 
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 
Respectfully Submitted, t:t'~ ~ Chief Pilot 

Raytheon Space and Airborne Systems 

6150 West Century Blvd. 

Los Angeles, CA 90045 

310-227-3569