P.O. Box 1139

Patterson, Louisiana 70392

(319) 640-1935 ● adam@parkerbennecorp.com ● www.parkerbennecorp.com

January 15, 2015

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 its intended purpose. Airborne Support, 

Inc. asks to be able to conduct training in restricted category aircraft outside of its intended 

purpose of the application of oil dispersant through aerial application. 

Furthermore we ask that the 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 that 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 exemption would benefit the public as a whole because our operations are critical to oil spill 

clean-up operations. Our clients in the oil & gas 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 competency 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 proven 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

Summary:

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 emergency which could potentially harm persons or property 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 their 

aircraft in compliance with Federal Regulations. As a whole these operators are making an effort to 

fly safely, there are several articles published that explain the benefits of training and why it is 

important for the operations of restricted category aircraft. 

This is a time-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