# (CHI A' 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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AVIAI'ION 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

~ MISSION POSSIBLE.



### 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.