Busi ness Office : 1320 Brookwood Dr

. Littl e Rock AR 72202 T- 800.413.4445 F- 866-839-8595
www

. vdci

. net ' 1V1osquito Control Specialists

1US. Department of Transportation Federal Aviation Administration 800 Independence Ave. SW Washington D.C. 20591
In 2011 Vector Disease Control was issued a dump exemption which expired Sep 2013. I requested to have this extended but never heard back. The exemption is attached. So please accept this letter as a request to extend or issue a new exemption. Vector Disease Control International (VDCI) is requesting an exemption for all seven of our multiengine mosquito control aircraft ( PA23/250

- N415CC , N40200 , N203 OM , N311 BB N68MW and Cessna 402C

- N251 RC ) In conjunction with conducting agricultural operations for control of disease caring mosquitoes. The specific section of title 14 code of Federal Regulation part 137.53 (C) (2) aircraft must be equipped with a device capable of jettisoning one half of the maximum authorized load of agricultural material within 45 seconds. The reason for the exemption request is to not endanger person's property by jettisoning chemicals over congested areas. The reason granting the request would be in the public interest is that no person or property would be exposed to a uncontrolled chemical release in the event of a partial or complete engine failure. The plane would be able to exit the spray area without releasing uncontrolled chemical. The reason the exemption would not adversely affect safety is the aircraft is required to operate conforming too FAR 137.51 (b) (S)(ii) ' 'No person may operate a multiengine airplane at a weight greater than the weight that, with the critical engine inoperative , would permit a rate of climb of at least 50 feet per minute at an altitude of at least l ,000 feet above the elevation of the highest ground or obstruction within the area to be worked or at an altitude of 5 ,000 feet, whichever is higher. For the purposes of this subdivision, it is assumed that the propeller of the inoperative engine is in the minimum drag position; that the wing flaps and landing gear are in the most favorable positions ; and that the remaining engine or engines are operating at the maximum continuous power available. " Following FAR 137.51 (b) (5)(ii) at all times the pilot would be able to exit the spray area without uncontrolled releasing of pesticide over a populated area there by increasing the safety of persons or property and this would increase the level of safety. Another reason to approve this request is: I. VDCl has a Training and Initial check out plan listed in our Flight Operation Manual Pg 13 -14 " Training and Initial check out " Each pilot goes through a yearly check out with the chief pilot and is sign off that the pilot is competent to perform all emergency and normal procedures. This includes weight and balance , single engine performance at different altitude s and temperatures. 2. All aircraft are tested and demonstrated each year to make sure they will meet all

# sincere,:£zre;~**~** Malcom

## ~{a~s 

# (**Managef/\~al** Division and Chef Pilot VDCI) MALCOM WILLIAMS Chief Pilot Vector Disease Controllnternationai , LLC mwilliams@vdci

. net PH 318-372-4073US

.Deportment of Tran s portation Federal Aviation Administration Sept em ber 29, 20 I I

Mr. Malcom William s Chief Pilot Vector Disease Control Interna tion al, LLC 13 20 Brookwood Drive Little Rock , AR 72202
Dear Mr. Williams: Exemption No. I 0369 800 Independenc e Ave

. S W Wash ingron

. DC 20591

Regulatory Docket No. F AA-20 I 1-0660

This letter is to inform you th at we have granted your request for exe mption

. It transm its o ur decision, explain s its basis , and give s you the condition s and limitati ons ofthe exemption , including th e date it end s.
The Basis for Our Deci s ion By letter dated June 20 , 20 II , you petitioned the Federal Aviatio n Administration (FAA) on behalf of Vector Disease Contro l Internati onal , LLC (Vector Disease Con trol) for an exem ptio n from § 137. 53(c)(2) ofTitl e 14, Code of federal R egu lati ons (14 CF R). Secti o n 137.53(c)(2) r eq uires that an aircraft (other th an a helicopter) th at is being operated over a conges t ed area be equipped "wi th a device capable ofjcttisoning at lea st one-half of the aircraft ' s maximum authori zed load of agric ultural material within 45 seconds." The exe mption that you requested would , if granted , allow Vector Disease Contro l to conduct aerial app li cations of in secti cide materials for the purp ose o f mosquito control without the aircraft being eq uipp ed with the dev i ce speci fi ed in§ 137.53(c)(2) when operating over a co n gested area. The exe mptio n would apply to the following aircraft:

Af' S -11 -3 61- ERegistration Number N415CC N40200 N737WP N251RC Make/Model Piper PA

- 23-250 Piper PA-23-250 Piper PA-23-250 Cessna 402C
The FAA has determined that good cause exists for not publishing a summary ofthe petition in the federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to Vector Disease Control.
The FAA's analysis/summary is as follows:
Part J 37 sets out rules governing the safety of agricultural aircraft operations and the dispensing ofmaterials that is conducted during these operations. This part was adopted to prescribe adequate and uniform regulations not on ly for the safety of flight but for the protection of the persons and property on the ground. The intent of§ 137.53(c)(2) is to provide the pilot with a means ofdumping chemicals from the aircraft if an emergency situation occurs. 2

The FAA has previously granted a simi lar exemption from the requ irements of§ l37.53(c)(2). In Exemption No. 4820 (copy enclosed) , the FAA found that the petitioner's operation would provide a level of safety equivalent to the level required by the regulations because: (I) the aircraft used in the operation would have a significant level ofreliability; (2) the aircraft would be operated with a gross weight considerably less than the maximum allowed; and (3) the pilots used in the operation wou ld have experience in excess of the regulatory requirements. The FAA also found that a grant of the exemption would be in the public interest because it would provide more effective control of widespread insect infestations in and around congested areas.
In this case, Vector Disease Control ' s exemption request is similar to the circumstances that the FAA addressed in Exemption No. 4820. First , the aircraft used in this operation have twoengine reliability and single-engine performance capability , which permit the aircraft to fly to a safe area in the event ofengine failure. Second , under the conditions imposed by this exemption, aircraft wou l d be limited to a maximum gross weight that will ensure singleengine climb performance capability of at least 200 -f eet-per

- minute positive rate at the prevailing density altitude. Third , the conditions imposed by this exemptio n wou ld require that the pilots used in the ope r ation have experience that is in excess of the r egulatory requirements.
In consideration of the foregoing , I find that a grant of this exemption would provide a level of safety equivalent to the level required by the regulations. I also find that a grant of this exemption wou ld be in the public interest because it would provide more effective insect control in and around congested areas.Our Decision Under the authority contained in 49 U

. S.C. 40113 and 44701, which the FAA Administrator has delegated to me, I hereby grant Vector Disease Control an exemption from 14 CFR 

### § 137.53(c)(2) to the extent necessary to conduct aerial app li cations of insecticide materials without the aircraft being equipped with a device that is capable of jettisoning at least one-ha lf ofthe aircraft's maximum authorized load of agricultural materials within 45 seconds when operating over a congested area, subject to the conditions and limitations described below.
Conditions and Limitations

I. This exemption is limited to Piper PA-23-250 and Cessna 402C model aircraft operated by Vector Disease Control International, LLC (operator).
2. This exemption is valid only when conducting agricultura l aircrafl operations under 14 CFR part 137. 

### 3

3. Aircraft operated under this exemption are limited to a maximum gross weight that will ensure single

-engine climb performance capability of at least 200-feet-per-minute positive rate at the prevailing density altitude. 4. Prior to each flight, the operator or pilot in command (PIC) must prepare a document showing the weight mid balance calculations and the single-engi ne climb performance for the forecast operating density alti tude. The document must be retained by the operat or for at l east 30 days and presented to the Administrator upon request. 5. Each PIC of an aircrafl operated under this exemption must have a total of at least 1,200 hours of flight time as pi lot, including at least 200 hours PIC time in pistonpowered multiengine aircraft, 50 hours of which must have been in part 13 7 operations

. 6. The operator must provide a copy ofthis exemption to each PIC who operates under the term.:; of this exemption. 7. A copy of the exemption must be carried on the aircraft while conducting operations under the terms of this exemp ti on. 8. Prior to operating under this exemption, each PIC must have successfully completed flight instruction from an appropriately rated flight instructor on single-engine operations, performance, and handling characteristics of the Piper PA-23-250 or Cessna 402C model aircraft (as appl icable). The instruction must be provided in each model of aircraft the PIC will operate under this exemption. A record of this instruction must be made available by the PIC upon request of the Administrator.9. The operator mu s t provide a copy of thi s exempti o n t o its part 137 cer tific ate -holding Fli ght Sta nd ard s Di strict Office
. I0. T hi s exempti on is not va lid f or operations ou tsi de of the United S t at

es.
Th is exempti on t erm inates o n Septem ber 30 , 20 13 , un less soon er superseded or resci nded.
S incerely ,



# ~tvWI~ John W

. McGraw Acting Director, Flight Standards

Service E

ncl osu re 4