P.O. Box 1139 Patterson, Louisiana 70392 (319) 640

- 1935 ● adam@parkerbennecorp.com ● www.parkerbennecorp.com

January 1 5 , 201 5

Re: Petition for exemption of 14 CFR § 91.313

To Whom it May Concern :

I am writing on behalf of a client, Airborne Support, Inc. to request an exemption from 14

– CFR § 91.313(a)(1) and § 91.313(c).

Airborne Support, Inc. operates a fleet of aircraft of which four (4) are Restricted category for oil spill dispersant. Airborne Support, Inc. operates under an FAA Part 137 Commercial Operating
Certificate and is a “ critical business ”

.

The extent of the exemption to be that Airborne Support, Inc. be exempt from conforming to the regulation that only allows the aircraft to be operated for it s intended purpose. Airborne Support, Inc. asks to be able to conduct training in restricted ca tegory aircraft outside of its intended purpose of the application of oil dispersant through aerial application.

Furthermore we ask that th e exemption includes that any pilot(s) who fly the aircraft in the capacity listed in this exemption not have any violations imposed on them for doing so.

We also ask t h at this exemption covers check rides and type ratings in the aircraft . And that the check airmen conducting the training/ check rides/ type ratings be exempt from violations for conducting the aforementioned training / check rides/ type ratings in accordance with this exemption.

This ex emption would benefit the public as a whole because our operations are critical to oil spill

clean

- up operations. Our cl ients in the oil & g as field require us to complete certain training in our aircraft in order to maintain a contract with them for oil spill mitigation. This training also helps the pilots to maintain proficiency and compete ncy in the specific aircraft which is ultimately better for the public as a whole.

This exemption would not adversely affect safety because it would allow for us to complete training in the aircraft which there are no simulators for. Training has been pro ven as an effective way of reducing accidents and incidents in aviation. Furthermore, Airborne Support, Inc. has a Safety Management System and other systems in

- place to reduce the possibility of an accident or incident
in our aircraft.P.O. Box 1139 Patterson, Louisiana 70392 (319) 640

- 1935 ● adam@parkerbennecorp.com ● www.parkerbennecorp.com

S ummary:

We are requesting an exemption of the parts of 14CFR § 91.313 that would not allow us to be able to conduct the training that has proven to be effective in our operations. This training helps reduce
the risk of an em ergency which could potentially harm persons or pr operty if it were not done by Training the crewmembers who operate these aircraft to a level of competency so that they are aware of situations which require operator input, and by operating the aircraft as to exercise them to find any issues they may have so we can correct them immediately and not when the aircraft is working a mission.

Companies and private owners of Restricted Category aircraft have been diligent with keeping the ir aircraft in compliance with Federal Regulations. As a whole these operators are mak i ng an effort to fly safely, there are several articles published that explain the benefits of training and why it is important for the operati ons of restricted category aircraft.

This is a ti me

- critical request for exemption and would be prudent if this was granted as soon as possible.

Best Regards, 

# Adam L. Tjelmeland

Adam L. Tjelmeland

President & CEO Parker Bennecorp (319) 640

- 1935 adam@parkerbennecorp.com