Business Office: 

1320 Brookwood Dr. 

Little 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 altitudes 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 318-372-4073 
US. Deportment 

of Transportation 

Federal Aviation 

Administration 

September 29, 20 I I 

Mr. Malcom Williams 

Chief Pilot 

Vector Disease Control International, LLC 

1320 Brookwood Drive 

Little Rock, AR 72202 

Dear Mr. Williams: 

Exemption No. I 0369 

800 Independence Ave . S W 

Washingron. DC 20591 

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

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated June 20, 20 II, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Vector Disease Control International, LLC (Vector Disease Control) for an 

exemption from § 137.53(c)(2) ofTitle 14, Code of federal Regulations (14 CFR). 

Section 137.53(c)(2) requires that an aircraft (other than a helicopter) that is being operated 

over a congested area be equipped "with a device capable ofjcttisoning at least one-half of the 

aircraft's maximum authorized load of agricultural material within 45 seconds." The 

exemption that you requested would, if granted, allow Vector Disease Control to conduct 

aerial applications of insecticide materials for the purpose of mosquito control without the 

aircraft being equipped with the device specified in§ 137.53(c)(2) when operating over a 

congested area. The exemption would apply to the following aircraft: 

Af'S-11 -361-E 
Registration 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 of the 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 of materials that is conducted during these operations. This part was adopted to 

prescribe adequate and uniform regulations not only 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 of dumping chemicals from the aircraft if an emergency 

situation occurs. 

2 

The FAA has previously granted a similar exemption from the requirements 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 of reliability; (2) the aircraft 

would be operated with a gross weight considerably less than the maximum allowed; and 

(3) the pilots used in the operation would 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 of engine failure. Second, under the conditions imposed by this 

exemption, aircraft would be limited to a maximum gross weight that will ensure singleengine climb performance capability of at least 200-feet-per-minute positive rate at the 

prevailing density altitude. Third, the conditions imposed by this exemption would require 

that the pilots used in the operation have experience that is in excess of the regulatory 

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 would 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 applications of insecticide 

materials without the aircraft being equipped with a device that is capable of jettisoning at 

least one-half of the 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 agricultural aircrafl operations under 

14 CFR part 137. 

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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-engine climb performance 

for the forecast operating density altitude. The document must be retained by the 

operator for at least 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 pilot, 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 of this 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 exemption. 

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 applicable). 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 must provide a copy of this exemption to its part 137 certificate-holding 

Flight Standards District Office. 

I 0. This exemption is not valid for operations outside of the United States. 

This exemption terminates on September 30, 2013, unless sooner superseded or rescinded. 

Sincerely, 

~tvWI~ John W. McGraw 

Acting Director, Flight Standards 

Service 

Enclosure 

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