(CHIA' MISSION POSSIBLE. 

AVIATN®N 

16 January 2015 

US Department of Transportation 

Federal Aviation Administration 

1200 New Jersey Avenue 

SE West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Construction Helicopters Inc. DBA CHI Aviation, Holder of Certificates, iTAA, ITAL, 

and TTAG — FAA Authorization to use a restricted category CH-47 for 

trai" checking for initial types/ 61.55/ 61.58 checks. 

Reference (a) 14 CFR 91.313 (a, and b) 

(b) 14 CFR 61.31, 61.55, and 61.58 

CHI Aviation requests an exemption from §91.313(a, and b) to conduct training and check 

flights as required by §61.31, 61.55, and 61.58 in a restricted category aircraft. Specifically, we 

request authorization to use (BFS) CH-47D's, certificated under TC R0011DE, to complete type 

rating training and check flights required by §61.31, 61.55, and 61.58. 

With the limited number of BFS CH-47D aircraft operating in the United States, aircrew training 

and check flights as required by Part 61 are unobtainable. CHI Aviation is supporting the United 

States government in fire suppression operations, which requires training and check flights for 

our pilots. 

Justification 

Our aircraft are operated under a special Airworthiness certificate in the restricted category. 

Per 14 CFR 91.313 (b), the operator also is granted the ability to perform training in these 

missions. These restricted category aircraft have an extensive history with millions of Safe flight 

hours conducting training and check rides. 

Only recently, the restrictions on the airworthiness certificate and those found in 14 CFR 91.313 

have been interpreted to restrict the aircraft use for type rating training and PIC checks. 

CH I Aviation • 3679 Boweii Road • Howell, Michiyan 48855 • TEL: 800.521.5130 • FAX: 800.521.4275 - chiaviation.com 
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MISSION POSSIBLE. 

The operator has conducted type rating training and PIC checks per 14 CFR 61.31, 61.55, and 

61.58 for many years. CHI Aviation holds that such training and checking is safe and in 

accordance with all applicable regulations. CHI Aviation requests an exemption to perform type 

rating training, type rating checks and currency checks for industry pilots. Such training 

presents no additional risk to the public and is in the public interest. 

CHI Aviation requests exemption from the following regulations: 

Section 91.313(a) prescribes, in pertinent part, that no person may operate a restricted 

category civil aircraft for other than the special purpose for which it is certificated; or in an 

operation other than one necessary to accomplish the work activity directly associated with 

that special purpose. 

Rationale for exemption: The aircraft, maneuvers and location of the requested training and 

checking are identical to those that have been accomplished by the operator in the past. 

Performing the same operations under the oversight of an FAA DPE/Inspector/PPE in 

accordance with all provisions of 91.313, presents no additional risk to the public. 

Section 91.313(b) prescribes, in pertinent part that operating a restricted category civil aircraft 

to provide flight crewmember training in a special purpose operation for which the aircraft is 

certificated is considered to be an operation for that special purpose. 

Rationale for exemption: No additional maneuvers or operations other than those already 

performed by the operator are to be performed in connection with the requested 61.31 or 

61.58 training. Additionally, the location of the requested training is identical to that used by 

the operator. The requested training therefore does not present additional risk to the public 

and is in the public interest. 

CHI Aviation requests an exemption from §91.313(a, and b) to conduct type rating training and 

check flights per §61.31, 61.55, and 61.58 in a restricted category aircraft, BFS CH-47D. These 

flights pose no additional risk to the public and are in the public interest. A copy of the 

approved exemption will be carried in the aircraft at all times training or checking is being 

conducted. 

Please see exemption number 10863, regulatory docket number FAA-2013-0476. This is an 

example of Sikorsky Helicopters exemption from §91.313 (a, and b) of title 14, code of federal 
(CHI 

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AVIATION 

regulations (14CFR) to the extent necessary to allow Sikorsky to conduct part 61 training and 

checking in a restricted category aircraft. 

For clarification about this request, please contact the undersigned at (517-376-8772), or email 

mvanpelt@chiaviation.com 

Very truly yours, 

Matt Van Pelt 

Director of Operations, AII Parts.