U.S. Department of Transportation

Docket Operations We st Building Ground Floor Room W1 2

– 140 1200 New Jersey Avenue, SE. Wa shington, 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, Wa shington 98053 and is in the business of supplying flig ht 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 c onfiguration 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 qualif y 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 a ll 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 cert ification 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 t his 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 enginee r, 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 i nteraction 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 perform ance. 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 necessa rily 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 dif ferent 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. Weinsist we train together for safety purposes so there is no confusion on procedures used, nomenclature, crew coordination, etc.**The Public Interest**

Webelieve 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 with out 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 operat ions.

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 re quest, 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 opera ting 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 si ngle flight engineer.

**Waiv er for the 120 public comment period** 

Wewould 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 ext remely 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 opera tions 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 c heck 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 a viation 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 wi ll 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, W A 98053