AERO AIR at the 

PORTLAND-HILLSBORO AIRPORT 

2050 NE 25TH AVENUE 

HILLSBORO, OR 97124 

TOLL FREE 800.448.2376 

TEL 503.640.3711 

FAX 503.681.6513 

WWW.AEROAIR.COM 

November 5, 2012 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Dear Sir I Maam: 

; ; 

Butler Aircraft Services held Exemptions for specific operations of DC-6 and DC-7 aircraft in the 

performance of fire fighting duties. These exemptions were: 

Exemption 9463, 2745C (Docket# FAA-2003-15405): Exemption to operate DC-6 and DC-7 aircraft in 

aerial fire suppression operations at landing weights greater than the maximum landing weight for the 

aircraft in T.B.M.'s operating limitations and up to the aircraft's design maximum landing weight. 

Exemption 10031A (Docket# FAA-2002-11937): To conduct ferry flights with one engine inoperative on 

its DC-6/DC-7 aircraft (registration numbers N401US, N6353C, N756Z, and N838D) without obtaining a 

special flight permit for each flight. 

Exemption 10043A (Docket# FAA-2001-10283): To operate its Boeing Douglas DC-6 and DC-7 airplanes 

without a flight engineer during flightcrew training, ferry operations, and test flights that are conducted 

to prepare for firefighting operations carried out under 14 CFR part 137. 

Aero Air, LLC, dba as Erickson Aero Tanker, LLC, has acquired the assets of Butler Aircraft Services to 

include the DC-6 and DC-7 aircraft of Butler Aircraft Services. These aircraft will be operated on Aero 

Air's 14 CFR part 137 Firefighting Certificate (091G003Y). As such Aero Air, LLC requests these 

exemptions be approved and extended to our operation. 

Please contact me at Aero Air should you have any additional questions or concerns. 

Sincerely, 

~~- Steve Boyce 

Director of Maintenance 

Aero Air, LLC 
AERO AIR at the 

PORTLAND-HILLSBORO AIRPORT 

2050 NE 25TH AVENUE 

HILLSBORO, OR 97124 

TOLL FREE 800.448.2376 

TEL 503.640.3711 

FAX 503.681.6513 

WWW.AEROAIR.COM 

November 5, 2012 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Ref: Exemption 9463 {2745C), Regulatory Docket No. FAA 2003-15405 

Dear Sir I Maam: 

Aero Air, LLC, the parent company of Corsair Two, LLC, has acquired the operating assets of Butler 

Aircraft, LLC which includes three DC-7 series aircraft for use in firefighting activities. As a follow on to 

exemption 9463 {2745C) Aero Air, LLC requests this exemption be granted to Aero Air, LLC, the current 

owner/operator of the fire fighting aircraft identified below and included in the original exemption. 

In a letter dated December 1, 1978, T.B.M., Inc., petitioned the Administrator of the FAA to exempt 

certain DC-7 type airplanes from a 1500 pound decrease in maximum landing weight as an operating 

limitation under CFR 36.1581{d). Aero Air, LLC requests exemption to 14 CFR 36.1581{d), a 1500 pound 

decrease in maximum landing weight imposed as an operating limitation under this rule. Aircraft 

affected by the limitation are N401US {DC-7), N6353C {DC-7), and N838D {DC-7-B). These transport 

category large airplanes, modified in accordance with STC No. SA 2709WE {DC-7, DC-7-B) are flown as 

"fire-bombers" under contract to state agencies. The modification includes the installation of external 

tanks and associated equipment to carry and dispense fire retardant chemicals. To compensate for any 

probable reduction in takeoff/climbout performance and to assure that no "acoustical change" as 

defined in CFR 21.93{b){1) resulted from the slight increase in drag created by the external tank 

installation, a 1500 pound decrease in the maximum takeoff weight was imposed on these "firebombers". Likewise, to assure that no acoustical change occurred during the approach phase of flight, 

the FAA imposed a 1500 pound decrease in the maximum landing weight ofthese aircraft. The 1500 

pound reduction was arbitrarily selected after some limited flight testing failed to quantify the increase 

in drag due to the external tank installation. In the absence of quantifiable data and to preclude more 

costly and time consuming analyses and testing, the FA and T.B.M. agreed to the 1500 pound reduction 

in both the maximum takeoff and maximum landing weights as an operating limitation under CFR 

36.1581{d). 

Aero Air, LLC seeks relief from the decreased maximum landing weight limitation only. As "fire 

bombers", these aircraft are required to stand by with a full load of retardant and 2.5 hours of fuel 

which brings the aircraft weight to approximately the design maximum gross landing weight. Some fire 

fighting missions are cancelled shortly after takeoff. In these cases, the aircraft landing weight is greater 
than the design maximum gross landing weight minus the 1500 pound operating limitation. Thus, three 

options are available to reduce the landing weight to meet the "lesser than design" landing weight. 

These options are: (1) continue flying to consume fuel, (2) jettison fuel, or (3) jettison part ofthe fire 

retardant chemical payload. 

Granting this exemption will conserve fuel and will be environmentally beneficial, in addition to reducing 

the cost of fire protection of State Land areas. Fuel will be conserved in that these airplanes will not 

have to continue flying solely to reduce weight or to dump fuel while airborne and pollute the air. 

Likewise, the dumping of fire retardant chemicals pollutes the air and contaminates the land areas 

and/or persons exposed to these chemicals. Furthermore, because the limited flight testing originally 

accomplished failed to show that increased engine power was required on the final approach with the 

external tank installation, there will be no appreciable change in approach zone noise exposure due to 

the 1500 pound increase (up to design landing weight) of these modified airplanes. The environmental 

impact would be increased noise on those occasions when the aircraft takes off but does not drop its 

cargo. There would be relatively few and isolated occurrences with no significant overall impact. 

A denial of this exemption would not be in the public interest for economic, fuel conservation, and 

environmental reasons. Retaining the 1500 pound decrease in landing weight as an operating limitation 

will require aircrews to continue on or more of the following: (1) continue flying to consume fuel, (2) 

jettison fuel, or (3) jettison part of the fire retardant chemical payload. Options 1 and 2 amount to a 

needless consumption of aviation fuel. All three options negatively impact the air quality and increase 

the American taxpayers' bill for fire protection of State Land areas. 

Please contact me at Aero Air should you have any additional questions or concerns. 

Sincerely, 

sb:v-e~~ Steve Boyce cS 

Director of Maintenance 

Aero Air, LLC