Michael D. Schiffer

November22, 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-; : - WilburWright Bldg., FOB10B 800 IndependenceAve. SW, Room 900E Washington, DC 20591

Dear Sir: 

# :**~~~** (J1**;~:;~:~ =~::::** 

### -·**~**-"! Exemption No.10142 ai'Qjffided'-" FAA Docket No. FAA-2010-0134

Thankyou forgranting and amending Exemption No. 10142. This is to request an extension of that exemption and small modificationstothe conditions and limitations. There has been no change in the conditions and reasons relative to public interest and safety thatwere the basis forgranting the original exemption and previous amendments. This exemption is valid only foroperations wherethe aircraft is dispensing benign substances such as pheromones or Bacillus thuringiensis (Bt). The requested changes areto conditions numbered 5 and 9 based upon aircraft manufacturer's data. To insure thatthis remains in the best interests ofthe public, we also request that number 6 be modified to require moreflying and agricultural experience. The conditions and limitations currently read as follows: 5. The approved CAP (CongestedArea 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 morethan 1 nautical mile away from the point atwhich turnaround over a congested area will begin. In each CAP, the operator must showthat 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 ofan engine failure. 6. Each pilot must hold a commercial pilot certificate and be employed directly by the operator. In addition tothe requirements of§ 137.53, each pilot must have at least 50 hours ofpilot in command (PIC) time in the designated model AirTractorairplane to be flown; 100 hours of PIC time in single-engine turbopropeller-powered airplanes; and 500 hours of PIC time dispensing agricultural materials orchemicals. 9. Each turnaround over a congested area must begin at an indicated airspeed of 140 mph, at a minimum altitude of200feet AGL.lhe requested change for No. 5 is that the emergency landing area be changed from "no more than 1 nautical mile" to "no morethan 1.4 nautical miles". Coupled with this is the request to change No. 9, thatthe beginning ofa turnaround over a congested area be reduced from 200 feetAGLto 100 feet AGL. The glide data provided bythe manufacturer, AirTractor, calculates the average distance covered during an enginefailure to be 1.66 nm (10,087 feet) for a starting altitude 200feet AGL. The manufacturer's data is included as an attachmenttothis submission. The data also showthat theAT-5028 hasthe lowest 

### UD glide performance (11.71/1) ofall the AirTractor models Al'sAerial Spraying. LLC operates. This means that in event ofan engine failure, aftertheAT -5028 performs the feather/pitch-up/climb maneuvertrading speed for altitude, it can travel a distance of 1171 feetforthe loss ofeach 100feet ofaltitude at best glide speed. Therefore, ifthe aircraft has 100 feet less altitude to descendfrom atthe top ofits feather/pitchup/climb maneuver, its glide distance will only be reduced by 1171 feet. TheAirTractordata derived distance of 1.66 nm (10,087 feet) minus 1171 feet equals 8916 feet (1.467 nm). Our requested changeto 100feetAGLwill still provide a 1.4 nm gliding distance and is supported by the datafor all ofthe AirTractor models operated byAl's Aerial Spraying, LLC. In orderto insure that ourairplanes are flown within the confines ofthis exemption and operated at speeds and altitudes specified by the manufacturerthat 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 increasethe Administrator's confidence that our pilots are able to achieve this glide performance, we propose that the FAA also makethis requirement. 6. Each pilot must hold a commercial pilot certificate and be employed directly bythe 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 AirTractorairplane to be flown; 1000 hours of PIC time in single-engine turbopropeller-powered airplanes; and 2500 hours of PIC time dispensing agricultural materials orchemicals. 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 orchemicals be raised to 2500 hours. Al'sAerial Spraying, LLC's decision making regarding pilot experience is based upon 2006- 2010 accident data compiled bythe National Agricultural Aviation Association (see attachment). An extraction is shown below. It is clearthat at2,500 hours ofexperience the accident rate is substantially less than that ofthe 100 hours ofdispensing experience. This does notjust equal the current standards required by FAR 137.53(b), it drastically increases the safetyfactor ofour operation.

Al's Aerial Spraying, LLC, Exemption 10142 Docket FAA-2010-0134Hours 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 thatthe conditions and limitations of Exemption No.10142 be modified to read asfollows:
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 morethan 1.4 nautical mile away from the point at which turnaround over a congested area will begin. In each CAP, the operator must showthat 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 ofan enginefailure. 6. Each pilot must hold a commercial pilot certificate and be employed directly bythe operator. In addition tothe requirements of§ 137.53, each pilot must have at least 50 hours ofpilot in command (PIC) time in the designated model AirTractorairplane to be flown; 1000 hours of PIC time in single-engineturbopropeller-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 100feetAGL. Al's Aerial Spraying, LLC has been and will continue tofly in full compliance with Exemption No.10142. Ifthe Administrator does not see

### frt to grant some orall ofthese changes tothe conditions and limitations, we request that he please renewthe exemption.in its currentform. Thankyou foryour 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 SNOWENGINEERINGCO. 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 ORimNALISSI.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 SNOWENGIN}!:ERING CO. REPORT 

# FY 2275 ·I WICHITAFALI..S, TEXAS I j ORDER MODEL TITLE I BY CHK'D See Below

:QLIDEPERFORMANCEClaire 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** ofthis repprt is to document and compare the glide performance ofthe ATw400, 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 flighttest data, drag polars were derived and used todeterminethe rate of**de~cent** correspondifllg .to the best LID ratio on a standard day. The weight ofeach 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 ofdescent at95mph. ! 

### 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'sAerial 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 NAAAfrom the Part 137 NTSB accident reports forthefive-year period from 2006through 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/1000 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 orfurther detail is required_
Sincerely,

# x04J';LKenneth W. Degg NAAA Director of Education & 

### Safety

1440 DukeStreet • Alexandria,VA 22314-3403 Tel: (202) 546-5722 • Fax: (202) 546-5726 • www.agavinlinn.org