October 1Oth, 2013 

U.S. Department of Transportation 

Docket Operations, West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

To Whom It May Concern: 

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4530 Flighdine Drive 

Kingman, AZ 86401 

Tel: 928-757-1002 

Aero-Flite, Inc. is an FAA Part 137 Operating Certificate. We have been in the business of 

aerial firefighting since 1963. Currently we contract with the U.S. Department of the Interior 

and Agriculture along with State Governments. Aero-Flite, Inc. is expanding its fleet of aircraft 

to include BAE A vro RJ-85 jets, modified to dispense fire retardant. Aero-Flite, Inc. recognizes 

the need to provide a level of training to its flight crews on par with FAA Part 121 and 125 

operators. To achieve this level of training we need access to an Avro RJ-85 specific Level D 

simulator. Unfortunately there are none located in the United States. 

Swiss Aviation Training currently operates an Avro RJ-85 Level D simulator in Zurich 

Switzerland. This particular simulator was at one time certified by the FAA (FAA #0622). 

When U.S. based airlines discontinued using Avro RJ-85 aircraft in 2007, there was no need to 

maintain FAA certification of#0622. Our desire is to sponsor this simulator and get it recertified with the FAA, so that we may use it for crew training, certification check rides and 

annual currency check rides (FAR 61.58). Unfortunately FAA Part 60.7 prevents Aero-Flite, 

Inc. from being a sponsor of the simulator. 

We have interviewed the author ofF AA Part 60, and he confirms that at the time FAA Part 60 

was being developed, there were no FAA Part 13 7 operators utilizing large or transport category 

turbojet aircraft. Accordingly, it seemed to be inappropriate at that time to include FAA Part 137 

operators as potential sponsors of flight simulation equipment. Our request is to receive 

exemption from FAA Part 60.7 (a) and (b) which would allow us to sponsor the Swiss Aviation 

Training simulator #0622. 

It must be clear that in this petition for exemption Aero-Flite, Inc. is not requesting that we be 

exempt from all ofFAA Part 60, but only from 14 CFR FAA Part 60.7(a)(1) and 60.7(b)(1), 

thus allowing Aero-Flite, Inc. to sponsor this simulator. Aero-Flite, Inc. is currently in contact 

with the FAA National Simulator Program Manager (NSPM) and has started the process of 

certification. 

Aero-Flite's top priority is a safe and effective operation. A large part of that safe and effective 

operation is providing our flight crews with the proper training. Aero-Flite, Inc. recognizes 

the value of simulator based pilot flight training as the airlines have proven. The cost benefit 

of being able to be a sponsor and use the simulator as intended not only helps Aero-Flite, 

Inc., but those benefits are passed on to our customers within the government 

and to the public taxpayer in more efficient, effective, and safer flight crews. 

But until we can produce a sponsor, the certification is at a standstill. Aero-Flite, Inc. 

is currently the only U.S. based user of the Swiss Aviation Training Avro simulator. 

Over the past year we have developed an excellent working relationship with 

Swiss Aviation Training. Due to some of the unique aspects of our type of 
4530 Flightline Drive 

Kingman, AZ 86401 

Tel: 918-757-1001 

operation, we have additional training requirements beyond standard airline operations. With 

these points in mind we feel the need to act as the sponsor for this simulator. We also bring our 

quality Safety Management System (SMS) and our Quality Management System (QMS, FAA 

Part 60.5) into the sponsorship of this simulator. 

This request for exemption would have no negative effects on any small business, organization 

or any other entity. The impact of being granted exemption would be on Aero-Flite, Inc. and 

Swiss Aviation Training in regards to record keeping. All recordkeeping would fall on Aero-Flite, 

Inc. along with any other administrative duties associated with sponsorship of the simulator. 

Aero-Flite, Inc. works daily with the U.S. Dept. of the Interior and Agriculture and the paperwork 

associated with those agencies is common to our business. We also have a working relationship 

with our FAA Regional and local FSDO inspectors and are a custom to all duties and paperwork 

functions. An additional positive effect would be, enabling other FAA 137 operators the ability 

to use this simulator, raising the overall safety standards of our entire industry. 

To recap our Petition for Exemption to 14 CFR FAA Part 60.7: 

1. Aero-Flite, Inc. is a FAA Part 137 Operator, engaged in wild land fire suppression. 

2. Aero-Flite, Inc. is currently upgrading its fleet of aircraft 

3. Aero-Flite, Inc. is restricted from being a sponsor of a simulator under 14 CFR FAA Part 

60.7(a)(l) and 60.7(b)(1). 

4. The author ofF AA Part 60 explained that it was an oversight not to include FAA Part 

13 7 Operators. 

5. Granting Aero-Flite, Inc. this exemption would enhance the safety of our operation, and 

enable us to provide a superior product to the U.S. government and the tax paying public. 

6. Aero-Flite, Inc. has the expertise in aerial wildland firefighting and is well suited to be a 

sponsor of simulator FAA #0622. Aero-Flite, Inc. has a SMS and QMS in place for 

being a sponsor (FAA Part 60.5). 

7. It would be in the best interest of the public, our government, and our industry to grant 

Aero-Flite, Inc. this exemption. 

8. Aero-Flite, Inc. is aware of the duties and responsibilities that come with certifying and 

maintaining certification of this simulator, and has a working relationship with the FAA 

and Swiss Aviation Training. 

We believe this request for exemption is not only in the Public Interest but we believe it would 

provide competency and professional training to our pilots and enhance both the quality and the 

quantity of that training. Of course we stand ready to answer any question or provide any 

additional information you may require. 

Sincerely, 

Michael W. Lynn 

Safety Manager- Aero-Flite, Inc. 

Cc: John Duncan FAA- AFS 1 

Cc: Leslie Smith FAA- AFS 200 

Cc: Harlan Sparrow FAA - AFS 205