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One Hornet Way, XE6D50/D2 

El Segundo, California 90245-2804 

18 January 2012 

Docket Management Facility 

U-S. Department of Transportation 

1200 NewJersey Avenue, S.E. 

West Building Ground Floor, Room W12-140 

Dear Sir or Madam: 

Northrop Grumman Systems Corporation {NOZA888K} requests an exemption to 14 CFR 135.247(a)(3) for night 

currency requirements to include type-rated aircraft, operated by a two-pilot crew. 

The primary contact for this petition is: 

James Wayne 

Chief Pilot 

Northrop Grumman Systems Corporation 

(310) 332-0151, mobile (310) 200-3354 

iames.wavne@ngc.com 

Specific Section of FAR 

14 CFR 135.247(a)(2) requires night currency in an aircraft and in essence states: 

No person may serve as pilot in command of an aircraft carrying passengers at night unless they have made at 

least 3 takeoffs and landings at night in the past 90 days in that category and class; and type, if the aircraft 

requires a type rating. 

14 CFR 135.247(a)(3) provides exceptions to (a)(2) above, if a pilot meets specific conditions in a type rated, two-pilot 

bv certification aircraft. 

Extent of Relief Requested 

Northrop Grumman requests the approval to use the exceptions provided in 135.247(a)(3) in a type rated, two-pilot 

by operations aircraft. 

Supporting Documentation and Public Benefit 

Northrop Grumman operates two BE-1900 aircraft, a type-rated aircraft requiring one pilot crewmember by 

certification. The BE-1900 is one of only a few aircraft types that require a type rating, yet are certified to operate 

with only one pilot under specific circumstances. Northrop's operating standards require that all company aircraft are 

operated with two-pilot crews. Including the BE-1900, at all times. All Northrop corporate pilots complete annual 

recurrent aircraft training under a Part 142 simulator training program at Flight Safety International using only twopilot crews. Northrop's BE-1900 aircraft are based in southern California and the nearest BE-1900 simulator is located 

in Seattle, Washington; thus making the use of a simulator for night currency every 90 days impractical. The only 

other option Is to use the actual aircraft for accomplishing the night takeoff and landingsevery 90 days which is not 

only an economic burden, but further congests the already congested airspace in the Los Angeles area. 

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Safety Standards 

Type-rated aircraft requiring two pilots are an obvious improvement in the level of safety over single pilot operations. 

Aircraft that already benefit from the exceptions in 14 CFR 135.247(a)(3) require two-pilot crews. Requiring two-pilot 

crews by company operational standards instead of by aircraft certification provides an equivalent level of safety. 

This exemption would allow Northrop Grumman to use the provisions for type rated, two-pilot aircraft by requiring 

this type rated, one-pilot aircraft (i.e. the BE-1900) to be trained and operated only by a two-pilot crew to meet this 

requirementr --"-

Thank you for your consideration. 

Respectfully, 

Oames Wayne 

Flight Department Safety Officer 

Northrop Grumman Systems Corporation 

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