U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12–140

1200 New Jersey Avenue, SE.

Washington, DC 20590

Subject: Request for Exemption 

Ref: CFR 14 Federal Aviation Regulations Part 91.529 – Flight Engineer 

Currency Requirements

Dear Sirs:

This request for Exemption is being submitted by Captain Dale M. Ranz, owner 

and operator of Ranz Aviation, LLC, whose main office is located at 19933 NE 

85th St, Redmond, Washington 98053 and is in the business of supplying flight 

test pilots and flight test flight engineers on a contractual basis to business 

entities such as Boeing, Raytheon, Aviation Partners, Razebeck Engineering and 

other such companies for the purpose of conducting experimental flight tests of 

aircraft for configuration or modification of various aircraft structures, systems or 

powerplants and the gathering of test data for aircraft certification.

The aircraft being flight tested are often highly modified from the original 

manufacturers configurations, which includes engines, flight controls, hydraulics, 

electrical or additions of structures, such as winglets, fairings etc., to the 

airframes. Operation of the aircraft in test configurations requires extensive 

experience and knowledge of the aircraft to qualify for selection as pilot or flight 

engineer during flight test operations. Flight crew selected by Ranz Aviation is 

comprised of individuals who have a more than 25-year history of operating the 

specific aircraft, and are often those who conducted initial certification flight tests 

of the original model.

This letter is a petition for exemption from the requirements of CFR 14 of the 

Federal Aviation Regulations, part 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 person has had at least 50 

hours of flight time as a flight engineer on that type airplane or has been 

checked by the administrator on that type airplane and is found to be 

familiar and competent with all essential current information and operating 

procedures.”
Relief Sought

This request for exemption is to permit limited operations of flight engineer 

activity for flight test certification purposes with an annual flight engineer 

proficiency check concurrent with the 14 CFR FAR Part 61.58 Pilot In Command 

check required for pilots in lieu of the 50 hours in 6 calendar months or 6 month 

flight engineer proficiency check requirement.

Background

Ranz Aviation is a small business devoted solely to certification flight testing, a 

narrow segment of the overall aviation community fulfilling a necessary function 

in an expanding world of flight test operations for new technology experiments in 

environmental and fuel saving programs. Individuals involved in this community 

are required to have an extensive flight test background accumulated over 

decades, in order to adequately collect and evaluate new ideas in terms of past 

performance.

Of those aircraft evaluated by Ranz Aviation that require a flight engineer, most 

are older aircraft (747-200) that have been modified to test a new engine variant, 

new types of engine generators, hydraulic system modifications (5000 psi 

systems) and other appendages for example, winglets.

Prior to each test flight, extensive interaction is conducted between the 

manufacturer of the equipment and the flight test crew to review procedures, 

expectations, safety contingencies, emergency mitigation protocols and other 

information relative to the modified aircraft and expected performance. This 

review includes a review of all normal, abnormal and emergency procedures as 

would be expected in any training scenario. 

Due to the nature of the flight test business, test programs do not run often 

enough to allow a flight engineer to necessarily obtain 50 hours of flight engineer 

time in 6 months. This requires a flight engineer to interrupt the schedule to travel 

to a training facility for the flight engineer proficiency check in a normal airplane 

for which, the procedures are often very different than what the flight engineer is 

responsible for in the test program and thereby, becomes a problem as well as 

an added expense for a small business. In other words, it does not serve the 

purpose, in our view, for which the regulation was written.

An additional burden is the requirement for the flight test pilots to accompany the 

flight test flight engineers for training every 6 months as opposed to the rule for 

annual proficiency checks under 14 CFR, FAR Part 61.58. We insist we train 

together for safety purposes so there is no confusion on procedures used, 

nomenclature, crew coordination, etc.
The Public Interest

We believe this request is in the public interest, as it will reduce the cost of 

technology introduction with no potential for harm to the public safety and in fact 

will enhance public safety by assuring a more coordinated flight crew operation in 

the flight test aircraft operations. 

This request will also reduce the cost of operations for a small business by 

increasing efficiency without potential harm to the traveling public. It reduces the 

paperwork required for tracking training, frees simulator time for more 

appropriate training operations and reduces the potential for flight crew confusion 

on procedures used for flight test operations.

Approval of this request will also reduce the operating cost of a small business 

significantly, which allows a more efficient operation of the business for the good 

of the traveling public.

Effect on Safety

As mentioned earlier, we believe this request, if granted, will enhance flight test 

safety by enabling our flight test crews to train as a crew on an annual basis, 

usually at the start of a flight test program, where all of the aircraft systems, 

limitation and procedures are reviewed as an operating crew...and not having a 

program interruption to send a flight engineer to a FAA 142 facility and potentially 

have to train with a crew they have never met and review procedures that are 

often different, depending on the facility able to accommodate a single flight 

engineer.

Waiver for the 120 public comment period

We would like to request a waiver from the 120 day public comment period 

based on the position that this exemption will affect 2-5 flight engineers operating 

in flight test operations; an extremely small segment of the industry. These 

operations are always operated in controlled conditions over unpopulated areas 

and do not subject the traveling public to any increased risk.

Summary

Ranz Aviation, a small business conducting flight test operations for aircraft 

modification firms, manufacturers and others, requests an exemption from 14 

CFR, PAR Part 91.529 to permit limited operations of flight engineer activity for 

flight test certification purposes with an annual flight engineer proficiency check 

concurrent with the 14 CFR FAR Part 61.58 Pilot In Command check required for 

pilots in lieu of the 50 hours in 6 calendar months or 6 month flight engineer 

proficiency check requirement.
Flight test operations are an extremely small segment of the aviation community 

and by the nature of their business, often have to interrupt flight operations to 

send flight engineers to a FAR 142 facility to receive a proficiency check using 

procedures that seldom relate to test operations being conducted. Safety will be 

enhanced by allowing the flight engineers to train with the pilots as a crew on an 

annual basis, most often at the beginning of any test program.

Respectfully submitted,

Dale M. Ranz

President

Ranz Aviation

19933 NE 85th St,

Redmond, WA 98053