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

November5, 2012

Docket Management Facility US Department ofTransportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590

Dear Sir

## I Maam: ; ;

ButlerAircraft Services held Exemptions forspecific operations of DC-6 and DC-7 aircraft in the performance offire 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 greaterthan the maximum landing weight forthe aircraft in T.B.M.'s operating limitations and up tothe aircraft's design maximum landing weight. Exemption 10031A (Docket# FAA-2002-11937): To conduct ferryflights with one engine inoperative on its DC-6/DC-7 aircraft (registration numbers N401US, N6353C, N756Z, and N838D) without obtaining a special flight permitforeach flight. Exemption 10043A (Docket# FAA-2001-10283): To operate its Boeing Douglas DC-6 and DC-7 airplanes without aflight engineer duringflightcrewtraining, ferry operations, and testflights that are conducted to prepare forfirefighting operations carried out under 14 CFR part 137.
Aero Air, LLC, dba as Erickson Aero Tanker, LLC, has acquired the assets ofButlerAircraft Services to include the DC-6 and DC-7 aircraft of ButlerAircraft Services. These aircraftwill be operated on Aero Air's 14CFR part 137 Firefighting Certificate (091G003Y). As such Aero Air, LLC requests these exemptions be approved and extended to ouroperation.

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

Sincerely,

# ~~- Steve Boyce Director of Maintenance Aero Air, LLCAERO 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 ofTransportation 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 ofCorsairTwo, LLC, has acquired the operating assets of Butler Aircraft, LLC which includes three DC-7 series aircraftfor use in firefighting activities. As afollow on to exemption 9463 {2745C) Aero Air, LLC requests this exemption be granted to Aero Air, LLC, the current owner/operator ofthe firefighting aircraft identified below and included in the original exemption.
In a letterdated December 1, 1978,T.B.M., Inc., petitioned the Administratorofthe FAA to exempt certain DC-7 type airplanes from a 1500 pound decrease in maximum landingweight as an operating limitation underCFR 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 underthis 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 ofexternal tanks and associated equipmentto 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 bythe external tank installation, a 1500 pound decrease in the maximum takeoffweight was imposed on these "firebombers". Likewise, to assure that no acoustical change occurred duringthe approach phase offlight, 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 quantifythe increase in drag due tothe external tank installation. In the absence ofquantifiable data and to preclude more costly and time consuming analyses and testing, the FA and T.B.M. agreed tothe 1500 pound reduction in both the maximum takeoffand maximum landing weights as an operating limitation underCFR 36.1581{d).
Aero Air, LLC seeks relieffrom the decreased maximum landing weight limitation only. As "fire bombers", these aircraft are required to stand by with afull load of retardant and 2.5 hours offuel which brings the aircraft weightto approximatelythe design maximum gross landing weight. Some fire fighting missions are cancelled shortly aftertakeoff. 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 landingweightto meet the "lesser than design" landingweight. These options are: (1) continue flying to consume fuel, (2) jettison fuel, or (3) jettison part ofthefire retardant chemical payload. Granting this exemption will conserve fuel and will be environmentally beneficial, in addition to reducing the cost offire protection ofState Land areas. Fuel will be conserved in thatthese airplanes will not have to continue flying solely toreduce weight orto dump fuel while airborne and pollute the air. Likewise, the dumping offire retardant chemicals pollutes the airand contaminates the land areas and/or persons exposed tothese chemicals. Furthermore, because the limited flighttesting originally accomplished failed to show that increased engine powerwas required on thefinal 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) ofthese modified airplanes. The environmental impact would be increased noise on those occasions when the aircraft takes offbut does notdrop its cargo. There would be relatively few and isolated occurrences with no significant overall impact.
Adenial ofthis exemption would not be in the public interestforeconomic, fuel conservation, and environmental reasons. Retaining the 1500 pound decrease in landingweight as an operating limitation will require aircrews to continue on or more ofthe following: (1) continue flyingto consume fuel, (2) jettison fuel, or (3) jettison part ofthe fire retardant chemical payload. Options 1and 2 amountto a needless consumption ofaviation fuel. All three options negatively impactthe air quality and increase the American taxpayers' bill forfire protection ofState Land areas.

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

Sincerely,

# sb:v-e~~ Steve Boyce 

# cS

Director ofMaintenance Aero Air, LLC