Amerijet International, Inc.

FAA-2007-27617 - Petition for Exemption from 14 CFR 63.37(b)(1) and 63 Appendix C (a)(3)(iv)(a)

March 13, 2007

Petition of Amerijet International for an exemption from 14 CFR Section 63.37(b)(1) and 63 Appendix C (a)(3)(iv)(a)

Amerijet submits that the aircraft flight time requirement of Part 63 is unnecessary; fails to recognize advances in simulator training technology and techniques; is wasteful; creates unnecessary risk and danger to the trainee, the flight crew and others; imposes unnecessary burdens arid expense on Amerijet is otherwise inconsistent with the public interest.

When the flight engineer training program set forth in Part 63 was adopted by the FAA four decades ago, simulation training was in its infancy. Since that time, great strides have been taken to the point that today simulators generally are thought of as superior to actual flying as a training device. Today's modern simulators are far more advanced than those described in Appendix C and offer far more diverse, rigorous and sophisticated training than could ever be achieved on the flight deck of a flying aircraft. In short, unlike the simulators of the 1960s, today's simulation training is markedly better than the training that can be provided through the use of an actual aircraft. Thus, the underlying premise for the Part 63 five‑hour rule, that actual flight time must be part of the flight engineer training regime, is no longer valid.

Counsel: John Richardson, 202-371-2256, jrichardson@johnlrichardson.com