AT-802 type rating exemption endorsement changes

UPDATE 2/18/17:

AT-802 Exemption AMENDED!

The latest update from the FAA and Air Tractor regarding the changes to the AT-802 type rating exemption are:

• The CFI requirement for anyone who delivers the FAA Approved Ground Training Program remains intact. This requirement becomes effective November 30, 2017.
• The FAA has agreed to accept AT-502 experience in leu of only AT-802 time logged.
• The deadline for compliance with the AT-802 Type Rating Exemption No. 5651Q has been extended to May 30, 2017.

If any additional changes come along for the FAA exemption No 5651Q, it will be passed on to AgAir Update readers as received from the Air Tractor factory.

READ AIR TRACTOR RESPONSE HERE:

Incoming-AirTractor-12JAN2017

 

Original Article:

The AT-802 Air Tractor is capable of exceeding the 12,500-pound limitation that would require a type rating in the aircraft. The AT-802 has always had an exemption from the type rating requirement, however the FAA has changed the requirements and the current exemption expires April 30, 2017. This will require AT-802 pilots to meet the new requirements for the exemption for a type rating in the aircraft.

Basically, the pilot has two ways to be qualified to fly an AT-802 in accordance with the Type Rating Exemption No. 5651. He must document he has completed an approved training course and receives a certificate of completion, logbook endorsement and other “recognized way to document training”.

Or, he can use his prior experience of a minimum of 100 flight hours logged with at least 10 hours in an AT-802 in the last 12 months to waive the ground training requirement.

It’s important to note that prior to 2009, the Exemption allowed this prior experience time to be in an AT-502. In 2009, the wording was changed to only give credit for previous AT-802 time.

Air Tractor is currently revising the Training Manual to incorporate the new requirements and will have done, approved and posted to www.airtractor.com prior to the current Exemption expiring.

The following is the recommended logbook entry:

On this date, (date) , I, (name, pilot certificate, certificate number) certify that I have logged more than 100 hours of flight time in an Air Tractor AT-802/802A with (at least 10) hours in the preceding 12 calendar months. This experience makes me eligible to waive the Ground Training requirements of FAA Exemption No. 5651, as revised.

 

Signed: ______________________________ Date: ______________

The following link will provide detailed FAA communication with Air Tractor about the Exemption. 

2 Comments

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  1. Mike R
    February 15, 18:07 Mike R

    I’d like to add some clarification (or possibly some additional confusion!) to this article.

    “AT-502-series” experience credit toward 802 qualification was inadvertently removed from the Exemption in revision M (2014). Revision N was released just a month later with wording that “This allowance was granted to Air Tractor in previous grants of exemption and was INADVERTENTLY REMOVED from Exemption No. 5651M.” So Revision N returned to the original relief of allowing 502-series experience toward 802 qualification.

    This wording was changed again this year. We are under the assumption that this change was a mistake again. On Jan 12 of this year we asked FAA to clarify the changes to the new Exemption, and this was one of the items we are seeking clarification on. As of today 2/15/17, we have not gotten a letter of response, and our phone calls and emails asking for their response to our letter haven’t been returned. As soon as we get clarification on our questions about several of the new changes, we will publish the response for our customer’s information. I can communicate to Ag Air Update as well if that information would be valuable to your readers. Let me know. Mike R

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  2. Mike R
    February 17, 15:09 Mike R

    Additional information from Friday afternoon, 2/17/17:

    FAA issued the following letter to Air Tractor today:

    Dear Mr. Rhodes:

    This is an interim response to your letter of January 12, 2017, in which you pointed out several instances in the Air Tractor Exemption 5651Q Conditions and Limitations where corrections were appropriate, and where some amendments were being requested by the company.

    While your request for amendments would have to go through the formal rulemaking process, we did want to touch on the following points in your letter of January 12, 2017:
    1. Air Tractor has asked that the Condition and Limitations (C&L) No. 9 which requires that a factory- authorized Instructor hold an Advanced Ground Instructor or Flight Instructor certificate be removed. We have carefully considered the arguments and evidence put forward and weighed them against the interest of maintaining a level of safety equivalent to §61.31(a)(1), and have concluded that this requirement should remain in Exemption 5651Q. The FAA does take into account that the AT-802/802A does have unique characteristics in comparison to most large aircraft which require type ratings.

    We do recognize that the new requirement for instructor certification in C&L 9 may cause a burden upon Air Tractor and its factory-authorized and will require a reasonable implementation period. Therefore we are extending the date for the requirement for Air Tractor’s authorized training pilots to hold either a ground instructor or certificated flight instructor certificate until November 30, 2017. This will give Air Tractor a 12-month period in which to implement this new training pilot instructor qualification program from the issuance date of Exemption 5651Q.
    We will incorporate this change in a correction to Exemption 5651Q, C&L 10.
    2. Air Tractor has been given until April 30, 2017 to develop, submit for FAA review and approval, and to distribute a new AT-802/802A training manual. It is our intention to extend the required implementation date of the new training manual to May 30, 2017. This will give Air Tractor a 6-month period in which to implement this new training manual from the issuance date of Exemption 5651Q.

    C&L 2 currently states:
    “Air Tractor must use an FAA-approved pilot training program to comply with the terms of this exemption:
    a) Until April 30, 2017, Air Tractor may use the AT-802/802A Pilot Training Program dated March 1, 2015, for its required training manual.
    b) After April 30, 2017, Air Tractor must develop and maintain a training manual(s) (to include lesson times and courseware) that includes the following ground training topics for the AT-802 and AT-802A airplane covered by this partial grant of exemption…”
    The corrected text for C&L 2 will read:
    “Air Tractor must use an FAA-approved pilot training program to comply with the terms of this exemption:
    a) Until May 30, 2017, Air Tractor may use the AT-802/802A Pilot Training Program dated March 1, 2015, for its required training manual.
    b) After May 30, 2017, Air Tractor must develop and maintain a training manual(s) (to include lesson times and courseware) that includes the following ground training topics for the AT-802 and AT-802A airplane covered by this partial grant of exemption…”
    3. Air Tractor would like confirmation that all pilots who have previously been authorized, and have been acting in the capacity of an AT-802/802A instructor will not lose their authorization to continue acting in that capacity.

    Training conducted by Air Tractor authorized instructors conducted prior to the issuance of Exemption 5651Q is still valid. Training by Air Tractor authorized instructors under the provisions of this exemption, even those without an Advanced Ground Instructor or Flight Instructor certificate, conducted prior to November 30, 2017 is still considered to be valid. However, beginning December 1, 2017, Air Tractor authorized instructors will be required to hold either the Advanced Ground Instructor or the Flight Instructor certificate in order to deliver the ground training required by this exemption.
    4. Air Tractor has asked that the ongoing FAA biennial approval process for its training manual be decoupled from the Exemption 5651 itself.

    The FAA is not able to do this. An FAA-approved training manual is considered to be a necessary risk-mitigating factor in the issuance of an exemption from the requirements of §61.31(a)(1). However, the FAA does understand Air Tractor’s concern about the timeliness of the FAA review and approval process for its AT-802/802A training manual. We can assure Air Tractor that the FAA will be timely in its biennial review and approval process for the AT-802/802A training manual.
    5. Air Tractor has pointed out two errors in the Conditions and Limitations for Exemption 5651Q:

    a. C&L 6 currently states:
    “Except as provided in Condition/Limitation No. 6, before any pilot can serve as pilot in command (PIC) in the AT-802 or AT-802A airplane (as applicable), that pilot must have successfully completed the applicable training in accordance with Air Tractor’s approved training manual described in Condition and Limitation No. 2.”
    We concur that this text should read: “Except as provided in Condition/Limitation No. 7, before any pilot can serve in command (PIC) in the AT-802 or AT-802A airplane (as applicable), that pilot must have successfully completed the applicable training in accordance with Air Tractor’s approved training manual described in Condition and Limitation No. 2.”
    We will incorporate this change in a correction to Exemption 5651Q, C&L 6.
    b. C&L 7 currently states:
    Pilots who have logged at least 100 hours of flight time, with at least 10 hours in the preceding 12 months, in an AT-802 series airplane need not complete the training requirements of Condition No.2. A record of this flight time must be made available by the pilot upon request by a representative of the FAA Administrator.
    We concur that this text of C&L 7 should read: Pilots who have logged at least 100 hours of flight time, with at least 10 hours in the preceding 12 months, in an AT-502 series airplane need not complete the training requirements of Condition No.2.
    We will incorporate this change in a correction to Exemption 5651Q C&L 7.
    6. By email message dated 2/16/2017, Air Tractor asked that C&L 7 include the AT-504 model aircraft as well as the AT-502 series aircraft. The 502 series aircraft have been the only aircraft allowed for previous experience credit since the original exemption that was issued in 1993. We cannot add the AT-504 without going through the exemption amendment process. To now allow “credit” for a model not listed previously would be precedent setting and requires a petition to the docket, public comment period, and so on. However, the FAA is receptive to a petition through the normal submission process for amendment by Air Tractor to request the addition of the AT-504.
    Thank you for providing feedback regarding Exemption 5651, as amended, and for your patience in this process.

    Sincerely,

    Douglas J. Lundgren
    Aviation Safety Inspector
    Airman Certification and Training Branch AFS-810
    Federal Aviation Administration HQ
    800 Independence Avenue
    Washington, DC 20591
    Douglas.lundgren@faa.gov
    Office: 202-267-0150
    Telework office: 301-969-0536

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