October 1Oth, 2013
U.S. Department ofTransportation Docket Operations, West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590

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## 8 P 2: 30 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 ofthe Interior and Agriculture along with State Governments. Aero-Flite, Inc. is expanding its fleet ofaircraft to include BAE Avro RJ-85jets, modified to dispense fire retardant. Aero-Flite, Inc. recognizes the need to provide a level oftraining to its flight crews on parwith FAAPart 121 and 125 operators. To achieve this level oftraining 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 simulatorwas 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 itrecertified with the FAA, so that we may use it for crew training, certification check rides and annual currency checkrides (FAR 61.58). Unfortunately FAA Part 60.7 prevents Aero-Flite, Inc. from being a sponsor ofthe simulator.

We have interviewedthe author ofF AA Part 60, and he confirmsthat at the time FAA Part 60
was being developed, there were no FAAPart 137 operators utilizing large ortransport category turbojet aircraft. Accordingly, it seemed to be inappropriate atthat time to include FAAPart 137 operators as potential sponsors offlight simulation equipment. Ourrequest is to receive exemption from FAA Part 60.7 (a) and (b) which would allow us to sponsorthe Swiss Aviation Training simulator#0622.
It mustbe clearthat in this petition for exemption Aero-Flite, Inc. is not requesting that we be exempt from all ofFAAPart 60, but only from 14 CFRFAA Part 60.7(a)(1) and 60.7(b)(1), thus allowing Aero-Flite, Inc. to sponsorthis simulator. Aero-Flite, Inc. is currently in contact with the FAA National SimulatorProgram Manager (NSPM) and has started the process of certification.
Aero-Flite's top priority is a safe and effective operation. A large part ofthat safe and effective operation is providing ourflight crews with the propertraining. Aero-Flite, Inc. recognizes the value ofsimulator based pilot flight training as the airlines have proven. The cost benefit ofbeing 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.
Butuntil we can produce a sponsor, the certification is at a standstill. Aero-Flite, Inc. is currently the only U.S. based user ofthe Swiss Aviation Training Avro simulator. Overthe past yearwehave developed an excellent working relationship with Swiss Aviation Training. Due to some ofthe unique aspects ofourtype of4530 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 sponsorfor this simulator. We also bring our quality Safety Management System (SMS) and our Quality Management System (QMS, FAA Part 60.5) into the sponsorship ofthis simulator.
This request for exemption would have no negative effects on any small business, organization
or any other entity. The impact ofbeing granted exemption would be on Aero-Flite, Inc. and SwissAviation Training in regards to record keeping. All recordkeeping would fall on Aero-Flite, Inc. along with any other administrative duties associated with sponsorship ofthe simulator. Aero-Flite, Inc. works daily with the U.S. Dept. ofthe Interior and Agriculture and the paperwork associated with those agencies is common to ourbusiness. We also have a working relationship with ourFAARegional and local FSDO inspectors and are a custom to all duties and paperwork functions. An additional positive effect would be, enabling otherFAA 137 operators the ability to use this simulator, raising the overall safety standards ofourentire industry.

Torecap our Petition for Exemption to 14 CFRFAAPart 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 ofaircraft 3. Aero-Flite, Inc. is restricted from being a sponsor ofa simulatorunder 14 CFRFAAPart 60.7(a)(l) and 60.7(b)(1). 4. The author ofF AAPart 60 explained that it was an oversight not to include FAA Part 137 Operators. 5. Granting Aero-Flite, Inc. this exemption would enhance the safety ofour operation, and enable us to provide a superior productto the U.S. government and the taxpayingpublic. 6. Aero-Flite, Inc. has the expertise in aerial wildland firefighting and is well suited to be a sponsor ofsimulatorFAA#0622. Aero-Flite, Inc. has a SMS and QMS in place for being a sponsor (FAA Part 60.5). 7. Itwould be in the best interest ofthe public, our government, and our industry to grant Aero-Flite, Inc. this exemption. 8. Aero-Flite, Inc. is aware ofthe duties and responsibilities that come with certifying and maintaining certification ofthis 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 ofthattraining. Ofcourse 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