Michael D. Schiffer 

November 22, 2013 

AL'S 

AERIAL SPRAYING, LLC 

Spraying - Fertilizing - Seeding 

3473 N. Shepardsville Rd. 

Ovid, Ml 48866 

(989) 834-5067 

Fax(989)834-5098 

Albert E. Schiffer 

Acting Director, Flight Standards Service 

Federal Aviation Administration 

VIA FEDERAL EXPRE~~ ::;.:_:· :::;'. '"·~~:::: li·' ·t-; : -

Wilbur Wright Bldg., FOB10B 

800 Independence Ave. SW, Room 900E 

Washington, DC 20591 

Dear Sir: 

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Exemption No.1 0142 ai'Qjffided'-" 

FAA Docket No. FAA-2010-0134 

Thank you for granting and amending Exemption No. 10142. This is to request an extension of 

that exemption and small modifications to the conditions and limitations. 

There has been no change in the conditions and reasons relative to public interest and safety 

that were the basis for granting the original exemption and previous amendments. 

This exemption is valid only for operations where the aircraft is dispensing benign substances 

such as pheromones or Bacillus thuringiensis (Bt). 

The requested changes are to conditions numbered 5 and 9 based upon aircraft manufacturer's 

data. To insure that this remains in the best interests of the public, we also request that number 

6 be modified to require more flying and agricultural experience. The conditions and limitations 

currently read as follows: 

5. The approved CAP (Congested Area Plan) must identify applicable emergency 

landing areas in compliance with§ 137.51(b)(4)(iii). The identified emergency landing 

areas must be located away from congested areas, no more than 1 nautical mile away 

from the point at which turnaround over a congested area will begin. In each CAP, the 

operator must show that at any time during a turnaround over a congested area, the 

airplane could reach an emergency landing area that is not congested in the event of an 

engine failure. 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of§ 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 100 hours of PIC time in single-engine turbopropeller-powered airplanes; and 500 

hours of PIC time dispensing agricultural materials or chemicals. 

9. Each turnaround over a congested area must begin at an indicated airspeed of 140 

mph, at a minimum altitude of 200 feet AGL. 
lhe requested change for No. 5 is that the emergency landing area be changed from "no more 

than 1 nautical mile" to "no more than 1.4 nautical miles". Coupled with this is the request to 

change No. 9, that the beginning of a turnaround over a congested area be reduced from 200 

feet AGL to 1 00 feet AGL. 

The glide data provided by the manufacturer, Air Tractor, calculates the average distance 

covered during an engine failure to be 1.66 nm (10,087 feet) for a starting altitude 200 feet AGL. 

The manufacturer's data is included as an attachment to this submission. 

The data also show that the AT-5028 has the lowest UD glide performance (11.71/1) of all the 

Air Tractor models Al's Aerial Spraying. LLC operates. This means that in event of an engine 

failure, after the AT -5028 performs the feather/pitch-up/climb maneuver trading speed for 

altitude, it can travel a distance of 1171 feet for the loss of each 100 feet of altitude at best glide 

speed. 

Therefore, if the aircraft has 1 00 feet less altitude to descend from at the top of its feather/pitchup/climb maneuver, its glide distance will only be reduced by 1171 feet. The Air Tractor data 

derived distance of 1.66 nm (10,087 feet) minus 1171 feet equals 8916 feet (1.467 nm). Our 

requested change to 100 feet AGL will still provide a 1.4 nm gliding distance and is supported 

by the data for all of the Air Tractor models operated by Al's Aerial Spraying, LLC. 

In order to insure that our airplanes are flown within the confines of this exemption and operated 

at speeds and altitudes specified by the manufacturer that insure the required performance, Al's 

Aerial Spraying, LLC employs pilots with significantly more experience that what is required by 

the regulation or Exemption No. 10142 in its current form. To increase the Administrator's 

confidence that our pilots are able to achieve this glide performance, we propose that the FAA 

also make this requirement. 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of § 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 1000 hours of PIC time in single-engine turbopropeller-powered airplanes; and 

2500 hours of PIC time dispensing agricultural materials or chemicals. 

The requested changes are that the current requirement of 100 hours of PIC time in singleengine turbopropeller-powered airplanes be increased to 1000 hours PIC and 500 hours of PIC 

time dispensing agricultural materials or chemicals be raised to 2500 hours. 

Al's Aerial Spraying, LLC's decision making regarding pilot experience is based upon 2006-

2010 accident data compiled by the National Agricultural Aviation Association (see attachment). 

An extraction is shown below. It is clear that at 2,500 hours of experience the accident rate is 

substantially less than that of the 100 hours of dispensing experience. This does not just equal 

the current standards required by FAR 137.53(b), it drastically increases the safety factor of our 

operation. 

Al's Aerial Spraying, LLC, Exemption 10142 

Docket FAA-2010-0134 
Hours in T~ee Accidents eer 1000 hours 

10,000. 38,859 1.4 

5,000-9,999 7.6 

2,500-4,999 13.7 

-- I 

100-249 289.2 

0-49 995.5 

To summarize, Al's Aerial Spraying, LLC requests that the conditions and limitations of 

Exemption No.10142 be modified to read as follows: 

5. The approved CAP must identify applicable emergency landing areas in compliance 

with §137.51(b)(4)(iii). The identified emergency landing areas must be located away 

from congested areas, no more than 1.4 nautical mile away from the point at which 

turnaround over a congested area will begin. In each CAP, the operator must show that 

at any time during a turnaround over a congested area, the airplane could reach an 

emergency landing area that is not congested in the event of an engine failure. 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of § 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 1000 hours of PIC time in single-engine turbopropeller-powered airplanes; and 

2500 hours of PIC time dispensing agricultural materials or chemicals. 

9. Each turnaround over a congested area must begin at an indicated airspeed of 140 

mph, at a minimum altitude of 100 feet AGL. 

Al's Aerial Spraying, LLC has been and will continue to fly in full compliance with Exemption 

No.1 0142. If the Administrator does not see frt to grant some or all of these changes to the 

conditions and limitations, we request that he please renew the exemption.in its current form. 

Thank you for your assistance. 

Respectfully submitted, 

Michael D. Schiffer, Partner 

Al's Aerial Spraying, LLC 

3473 North Shepardsville Rd. 

Ovid, Michigan 48866 

Attachments: 4 

Al's Aerial Spraying, LLC, Exemption 10142 

Docket FM-2010-0134 
ENGINEERING NIJM;BER REV 

SNOW ENGINEERING CO. 

WJCH!TAPALLS, TEXAS REPORT 

~ # 1328 - ORDER MODlll 

TJTLE BY OlX'D AT-502B 

Flight Evaluation Alan East LS ~1!RII\I. 

Power:-Off Glide Performance ORimNAL ISSI.I< OA1'E 

~AGI: OP 

5/12/04 1 1 

REVISION LOG: 

-

PURPOSE: 

This report: documents the results of a cursory flight evaluation of the Air 

Tractor AT-502B. The purpose of this report is to determine an estimated 

distance covered along the ground following a simulated loss of power. 

PROCEDURE: 

Four trail flights were conducted to determine an estimated power-off glide 

distance per. 200' of altitude loss following a simulated engine failure. 

Two trails were flown on a westerly heading along a ground reference line, 

followed by two more trails flown on an easterly heading along t'he same 

ground reference line. Using a GPS receiver, accurate measurements of 

d.istance covered along the ground track were made. 

For all trails, an indicated airspeed of 140 mph was flown at a press\t:re 

altitude of 4500' MSL, which represents a typical working airspeed for the 

AT-502B. The temper~ture during the evaluation was 67"F. The aircraft was 

loaded with full fuel tanks and 400 gallons of water in the hopper. Pilot 

weight was 230 lbs. 

For the test, an engine failure was simulated, the GPS position was 

immediately initialized, the propeller was placed into full feather 

position, and a pitch'-up maneuver was initiated along with a simultaneous 

jettison of the entire hopper load. Following the pitch-up maneuver, a 

reference glide speed of 90 mph was maintained along a straight ground 

track. The total distance covered after a net loss of 200' (as the 

aircraft passed through 4300' MSL) was recorded for each trial. 

The measured ground track distance for the four trials was averaged, 

effectively canceling out any headwind or tailwind component. 

Table 1 summarizes the results of this flight evaluation. 

r--· T'rial 1 Trial 2 Trial 3 Trial 4 

Heading Flown West West E:ast East 

Distance covered after 200' 1. 40 nm 1.52 nm 1.89 nm 1.82 nm 

net altitude loss 

Maximum altitude achieved 360 1 280' 320' 380' 

following pitch-up maneuver 

Average Distance covered 1.66 run 

Average altitude gain 335' 

following pitch-up 

Table 1 

I 

I ENGINEERING NUMBER l 

SNOW ENGIN}!:ERING CO. REPORT FY ·I WICHITA 2275 FALI..S, TEXAS I 

j ORDER MODEL 

TITLE I BY CHK'D See Below 

: QLIDE PERFORMANCEClaire Meschkat JH SERIAL 

DATE ALL . AT -400/402B/502/502B 1/2/12 PAGE 1 OF 1 

' I . 1: 

REFERENCES: 

r ' 

' 

[1] Ai~Qiane Aerody:namics and Performance, C.E. Lan & Jan Roskam ,, 

PURPbSE: 

Th~ p~rp~se of this repprt is to document and compare the glide performance of the AT w400, AT402Bi,(A"f-502, and AT-5028. 1 

SUM~ARY: I 

The aircraft to be compared in this report are based on the geometric parameters listed in Table 1. 

j 

l Table 1: Configuration Geometry I. 

; 

tcpnfiguration AT-400 AT-4028 AT-502 AT-5028 

I \)Y:it:lgspan [ft] 45 51 50 52 

'Wir:ig Area [ff2] 270 306 300 31.2 

~sp>ect Ratio 7..50 8.50 8.33 8.67 

.I 

I 

~~ 

The smallest glide angle is obtained when flying at the maximum possible lift-to-drag ratio. Based on 

the g49metry .in Table 1 and flight test data, drag polars were derived and used to determine the rate 

of de~cent correspondifllg .to the best LID ratio on a standard day. The weight of each aircraft was 

calcul~t~d with an empty hopper arid 160 gallons. offuel. Some earner mOdel AT -400s .and AT -502s 

had 1 ?6 ~a!ilon fuel tan~s. To be conservative, the gHde performance calculated in this report is 

based':on the aircraft having 170 gallon capacity fuel tanks and assuming a minimum of 10 gallons 

were illsed before the descent is performed. Table 2 below shows the LID ratios and rates of descent 

at 95mph. ! 

i Table 2: Glide Performance 

.i 

j ' Configuration AT-400 AT-4028 AT-502 AT-5028 

LID 11.74 11.83 11.80 11.71 ,, 

~ate of Descent [ftlmin] 712 707 708 714 I !: 

L 

Typlc*lly, airplanes with high aspect ratios and low zero-lift drag coefficients have the shallowest 

glides\~ From Table 2, it is evident that parasite drag is a major influential factor affecting the rate of 

desc~ht 'among the compared aircraft. 

I 

! 

l 

j 

1: 1, 
Mike Schiffer 

Al's Aerial Spraying, LLC 

3473 N Shepardsville Road 

Ovid, Ml 48866 

Dear Mike, 

November 13, 2013 

Thank you for your inquiry about accident data we presented in the 2012-2013 

PAASS program. This information was compiled by the NAAA from the Part 137 

NTSB accident reports for the five-year period from 2006 through 2010. The 

hours depicted are those listed on the accident reports as the pilot's flight time 

total in the make/model aircraft involved. 

I have shown the information on the graph below: 

Hours in type Accidents/1 000 hours 

10,000-38,859 1.4 

5,000-9,999 7.6 

2,500-4,999 13.7 

1 ,000-2,499 48.8 

750-999 22.7 

500-749 46.1 

250-499 112.6 

100-249 289.2 

50-99 193.3 

0-49 995.5 

Please contact me if any additional information or further detail is required_ 

Sincerely, 

x04J';LKenneth W. Degg 

NAAA Director of Education & Safety 

1440 Duke Street • Alexandria, VA 22314-3403 

Tel: (202) 546-5722 • Fax: (202) 546-5726 • www.agavinlinn.org