Air Tractor Inc. P.O. Box 485 Olney, Texas 76374 January 12, 2017 Douglas J. Lundgren Aviation Safety Inspector 940-564-5616 940-564-5612 (Fax) www.airtractor.com

Airman Ce1iification and Training Branch AFS-81 0 Federal Aviation Administration 

### 1-IQ 800 Independence Avenue Washington, DC 20591 Douglas.lundgren@faa.gov Office: 202-267-0150 Telework office: 301-969-0536

Dear Mr. Lundgren, Thank you for giving us your time on the phone conference last week. The infonnation that was shared was very helpful and inf01mative to us, and we hope to your office as well. Air Tractor would like to formally request fmiher reliefon several Conditions and Limitations of the Exemption No 5651 Q, issued on November 29, 2016. I. Condition and Limitation No. 9 was amended to now require a Factory Authorized Instructor to hold an Advanced Ground Instmctor certificate or a Flight Instructor ceiiificate. Air Tractor would like to formally request that this new requirement be removed from the Type Rating Exemption. There are several important factors involved in this request:
a. Experienced AT-802 pilots with a CFI certificate are scarce - Many ofthe "first generation" ofAT -802 pilots are approaching retirement age now. These are the pilots in our industry who have tens ofthousands ofhours in the airplane, and care a great deal about the long-term success ofthe ag aviation industry. These are the people that the industry hopes will pass along their "tribal knowledge" to the new generation ofAT-802 pilots. Most are not Ce1iified Flight Instmctors, and have no aspirations ofbecoming one. A poll ofdealers and customers, conducted by Air Tractor last week, indicates that only about I0-15% ofqualified 802 pilots are CF!s. Air Tractor believes that the experienced Air Tractor pilots, the ones who operate the airplanes on a daily basis, are the mostAir Tractor Inc. P
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. Box 485 Olney, Texas 76374 940-564-5616 940-564-5612 (Fax) www.airtractor.com qualified at passing along good training, good habits, and helpful advice, whether they hold an Instructor certificate or not. b. We have already been granted relieffrom the CFI requirement- A Flight Instructor requirement was part ofthe original Exemption granted in 1993. Air Tractor provided the evidence ofgood cause for relieffrom this requirement, and was granted relieffrom it.
c. Not in pursuit ofa pilot rating- Transitioning from a smaller ag plane to an AT802/802A is never done in pursuit ofa pilot rating. d
. AT-802/802A Pilots are stepping up from the smaller Air Tractor models - In almost all cases, a pilot becoming qualified in an AT-802/802A is transitioning into that airplane from one ofthe smaller Air Tractor models. All models ofAir Tractor airplanes have very similar flying characters, share most ofthe same systems, and are equipped in an almost identical way.
e. Many Highly Experienced AT-802/802A Pilots Will Stop Teaching - Becoming a CFI is no small chore, and requires a significant amount ofa person's time and resources. Air Tractor suspects that most ofthe "first generation" of AT-802/802A pilots are within a few years ofretirement age, and will chose to just stop teaching rather than go to the trouble ofadding a CFI rating. This will have negative effect on our indust ry's overall safety, as quality training becomes more difficult to find
. f. There is no good way for Air Tractor to rescind a previously-approved Trainer Pilot's credentials- Air Tractor would like to verify that previouslyauthorized pilots' and previously-authorized Instructors' operational approvals will remain valid, even as the requirements ofthe Exemption continue to change. Several years ago Air Tractor developed a process for vetting new AT-802/802A Trainer Pilots for factory authorization. This process includes requesting:
• copies ofpilot certificates and medical certificates to show proper licensing • Flight Experience Resumes to document flight experience that is pertinent to the request, most notably ag time, turbine time, tailwheel time, and training time. • letters ofrecommendation from employers or ChiefPilots to add a higher level of scrutiny to the applicant' s summary offlight experience • industry references to help determine that the applicant has a good record of professional conduct relative to the operation ofairplanes in our industryAir Tractor Inc. P.O. Box 485 Olney, Texas 76374 940-564-5616 940-564-5612 (Fax) www.airtractor.com As discussed during our phone call, Air Tractor is compiling a comprehensive list ofall Factory Approved AT-802/802A Trainer Pilots. Our plan is to submit this list when applying for extension ofthe Type Rating Exemption, and to also publish this list so that a prospective AT-802/802A pilot can easily determine the best place to receive quality training from an Authorized Trainer Pilot. Please confirm 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. Also, please reconsider the addition of the new CFIIAGI requirement because this requirement adds an additional roadblock to quality training, prevents many highly experienced pilots from passing along their valuable knowledge about the airplane and the industry, and presents a significant economic impact on the industry. 2. This Exemption tics the operational approval ofAT-802/802A PILOTS to the ongoing approval ofthe TRAINING PROGRAM. Air Tractor feels that these two separate issues should not be tied together. Please note that there is no recurrent pilot training requirement included as pmt ofthis Exemption. Once a pilot has been trained, he is trained. Air Tractor can easily envision a time in the future where the biennial Training Program renewal submittal and approval process takes longer than expected, and Air Tractor hopes that the FAA does not create a situation that jeopardizes all AT-802/802A pilots' operational authorities by making it dependent on that process. Air Tractor would like to request that a qualified Air Tractor AT-802/802A pilot's operational approval NOT hinge on the FAA's ability to review, process, and approve biennial submissions of the tmining program.
Air Tractor closely monitors and tracks the accidents that involve our airplanes. An Air Tractor Accident Investigator travels to the site ofevery fatal accident involving Air Tractor airplanes to assist the FAA and NTSB in detennining accident causes. Our accident records show that the accident rate ofAT-802/802A airplanes is statistically equivalent to the accident rates ofour smaller models, which aren't bound to any sort of additional requirement for training. Future requests for the extension ofExemption 5651 will likely include some additional accident data to assist FAA with detetmining current trends with regard to Air Tractor operation. There are several passages in the new Exemption where FAA references an equal level of safety with FAR 61.31 (a). Please be aware that although AT-802/802A airplanes meet the definition ofAir Tractor Inc. P.O. Box 485 Olney, Texas 76374 940-564-5616 940-564-5612 (Fax) www.airtractor.com a "large airplane" , they are not complex airplanes from an operational or a systems standpoint. AT-802/802A airplanes are operated under Restricted Category, and are usually flown as a single pilot, single occupant mission. Passengers are not allowed, and the restrictions imposed by the Restricted Category operation inherently protect the general public
. The FAA has realized that airplane weight doesn't necessarily imply complexity, and seems to be addressing that new direction with the Part 23 re-write, where future airplanes will be certified based on complexity, rather than simply based on weight. As FAA examines the specific factors pertaining to the on-going issuance ofthe Type Rating Exemption, Air Tractor requests that FAA recognize the operational nature ofAir Tractor airplanes and the inherent equivalent levels ofsafety that are currently in place when issuing new requirements on our industry. We feel strongly that this request for reliefis in the public interest, and does not compromise safety in any way.
Please feel free to contact me with any questions or comments regarding this matter.

Air Tractor, Inc. P.O. Box 485 Olney, TX 76374 (940)564-5616 ext. 319 mrhodes@airtractor.com
Attachment: Letter from Conair ChiefPilot Tim Garrish, re: Exemption No. 5651

cc: Andrew Moore, National Agricultural Aviation Association Ken Degg, National Agricultural Aviation Association Lauren L. Haertlein, General Aviation Manufacturers AssociationTim Garrish Check Pilot 

# ·-- Mike Rhodes ChiefTest Pilot Air Tractor, Inc
. CONAtR GROUP INC

. 1510 Tower Street Abbotslord, BC Canada V2T 6H5 Offi ce: 604-855 - 1171 **~DIUfl**
**~** 

# ----1411,.

Cell: 403-609-0777 24 November 2016 E-mail : tgarrish@telusplanet.net Mike, I havejust reviewed the recently issued FAA Exemption 5651P for the AT

-802. The changes in the exemption are ofconsiderable concern to me as the impact directly on my ability to provide pilot training on the AT

-802/802A. In particular the requirement for AT-802 training pilots to hold an Instructor R ating. I have been flying the AT

-802/802A continuously since 1995 on fire contracts in Canada and internationally. I also spend several months each year providing both initial and recurrent ground and flight training to both initial and recurrent 802 pilots
. The bulk ofthe training I do is for Conair in Abbotsford, BC. I also have provided contract ground and flight training on the AT-802 to operators in Europe and the Middle East. To date I have done initial AT

-802 training for over 50 pilots
. Unfortunately ifthe requirement for an Instructor Rating remains part ofExemption 5651P I will no longer be able to provide these services. I do not plan on getting an instructor rating nor do I f eel it would add any value to the training I provide on the AT-802. I have also been a Transport Canada Approved Check Pilot (ACP) since 1987 with authorization to do specific type ratings, Pilot Proficiency Checks (PPCs) along with issuing and renewing Instrument Ratings. There is no requirement in Canada to hold an Instructor Rating to be approved for these duties. You have my total support in petitioning the FAA to have the Instructor requirements removed from the Exemption Letter. In addition it would be most helpful ifthe FAA would make a simplified exemption a permanent one. This would save the administrative time spent annually updating manuals and training materials etc.

Timothy Garrish Hemlock Aviation Services 921 Spillway Road 4048 Oliver, BC Canada VOH 1T8 Cell 403-609-0777 www.conair.ca