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 relief on 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 of the 

"first generation" of AT -802 pilots are approaching retirement age now. These 

are the pilots in our industry who have tens of thousands of hours in the airplane, 

and care a great deal about the long-term success of the ag aviation industry. 

These are the people that the industry hopes will pass along their "tribal 

knowledge" to the new generation of AT-802 pilots. Most are not Ce1iified Flight 

Instmctors, and have no aspirations of becoming one. A poll of dealers and 

customers, conducted by Air Tractor last week, indicates that only about I 0-15% 

of qualified 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 most 
Air Tractor Inc. P.O. 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 relief from the CFI requirement- A Flight 

Instructor requirement was part of the original Exemption granted in 1993. Air 

Tractor provided the evidence of good cause for relief from this requirement, and 

was granted relief from it. 

c. Not in pursuit of a pilot rating- Transitioning from a smaller ag plane to an AT802/802A is never done in pursuit of a 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 of the smaller Air Tractor models. All models of Air 

Tractor airplanes have very similar flying characters, share most of the 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 of a person's 

time and resources. Air Tractor suspects that most of the "first generation" of 

AT -802/802A pilots are within a few years of retirement age, and will chose to 

just stop teaching rather than go to the trouble of adding a CFI rating. This will 

have negative effect on our industry'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 of the 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 of pilot 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 of recommendation from employers or Chief Pilots to add a higher level of 

scrutiny to the applicant's summary of flight experience 

• industry references to help determine that the applicant has a good record of 

professional conduct relative to the operation of airplanes in our industry 
Air 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 of all 

Factory Approved A T-802/802A Trainer Pilots. Our plan is to submit this list when 

applying for extension of the 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 of AT -802/802A PILOTS to the ongoing 

approval of the 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 of this 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 of every fatal accident involving Air Tractor airplanes to 

assist the FAA and NTSB in detennining accident causes. Our accident records show that the 

accident rate of AT -802/802A airplanes is statistically equivalent to the accident rates of our 

smaller models, which aren't bound to any sort of additional requirement for training. Future 

requests for the extension of Exemption 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 of 
Air 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 of the Type Rating 

Exemption, Air Tractor requests that FAA recognize the operational nature of Air Tractor 

airplanes and the inherent equivalent levels of safety that are currently in place when issuing new 

requirements on our industry. We feel strongly that this request for relief is 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 Chief Pilot 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 Association 
Tim Garrish 

Check Pilot 

·--

Mike Rhodes 

Chief Test Pilot 

Air Tractor, Inc. 

CONAtR GROUP INC. 

1510 Tower Street 

Abbotslord, BC 

Canada V2T 6H5 

Office: 604-855-1171 

~DIUfl ~ ----1411,. 

Cell: 403-609-0777 

24 November 2016 E-mail: tgarrish@telusplanet.net 

Mike, 

I have just reviewed the recently issued FAA Exemption 5651P for the AT-802. The 

changes in the exemption are of considerable 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 Rating. 

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 of the training I do is for Co na ir 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 if the requirement for an Instructor Rating remains part of Exemption 

5651P I will no longer be able to provide these services. I do not plan on getting an 

instructor rating nor do I feel 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 if the 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 1 T8 Cell 403-609-0777 

www.conair.ca