AFS-14-156-E

April 25, 2014

 Exemption No. 5651M

 Regulatory Docket No. FAA-2002-11498

Mike Rhodes

Chief Test Pilot

Air Tractor, Inc.

P.O. Box 485

Olney, TX 76374

Dear Mr. Rhodes:

This letter is to inform you that we have granted your petition to extend Exemption No.

5651M, as amended. It explains the basis for our decision, describes its effect, and lists the 

conditions and limitations.

The Basis for Our Decision

By letter dated January 21, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Air Tractor, Inc. (Air Tractor) for an extension of Exemption No. 5651, as 

amended. That exemption from § 61.31(a)(1) of Title 14, Code of Federal Regulations (14 

CFR) allows Air Tractor and pilots of AT-802, AT-802A, AT-1002, or AT-1002A airplanes 

to operate those airplanes without holding a type rating, although the maximum gross weight 

of the airplanes exceeds 12,500 pounds. 

In your petition, you indicate that 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.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Air Tractor.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 5651M

remains valid with respect to this exemption and is in the public interest. 

The FAA notes that AT-1002/AT-1002A aircraft types were first added to Exemption 5615K 

on November 23, 2009, at the request of Air Tractor. The request was made due to pending 

type certification for the AT-1002/AT-1002A. The FAA notes that at present there are no 

AT-1002 and AT-1002A aircraft that are type certificated. The FAA notes that we may 

remove the references to the AT-1002 and AT-1002A aircraft in the future, depending on the 

status of the pending type certification project for these aircraft.

The FAA has also made amendments to the conditions and limitation of Exemption No. 

5651M that clarifies our original intent and refine our requirements. Specifically;

1. Condition/Limitation No. 1 was amended to clarify the types of operations allowed

under this exemption.

2. Condition/Limitation No. 2 was amended to require Air Tractor to have an approved 

training manual along with approval documentation from the FAA’s General Aviation 

and Commercial Division in order to exercise the privileges of this exemption. An 

FAA approved training manual is meant to ensure that Air Tractor is providing a 

training program that is accordant with FAA safety standards. In addition, the 

condition and limitation notes that the training manual must be made available to any 

representative of the FAA Administrator upon request.

3. Condition/Limitation No. 3 was amended to clarify and standardize this exemption 

with similar exemptions to include a review of the approved aircraft flight manual and 

cockpit familiarization checkout for each pilot prior to operation under this exemption.

4. Condition/Limitation No. 5 was added to clarify and standardize this exemption with 

similar exemptions to specify that any representative of the FAA Administrator may 

review Air Tractor’s record of training.

While the relief does not change substantially, all users of the exemption should thoroughly 

review the revised conditions and limitations. 

Under the authority provided by 49 U.S.C. § 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, I grant Air Tractor, Inc. and pilots of Air Tractor Models 

AT-802, AT-802A, AT-1002, and AT-1002A, relief from § 61.31(a)(1) to the extent 

necessary to operate these models without holding a type rating for the airplane, subject to the 

following conditions and limitations.
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Conditions and Limitations

1. This exemption applies to pilots operating AT-802, AT-802A, AT-1002, and AT1002A aircraft that hold a restricted category airworthiness certificate for operations 

involving agricultural, forest protection, and narcotic crop eradication flight 

operations.

2. Air Tractor must develop and maintain training manuals that include aeronautical 

knowledge training on the AT-802, AT-802A, AT-1002, and AT-1002A aircraft 

systems, performance, and handling characteristics. These training manuals must 

include characteristics that are unique to AT-802, AT-802A, AT-1002, or AT-1002A 

aircraft that are operated above 12,500 pounds. Air Tractor may exercise the 

privileges of this exemption only if it has documentation showing approval of its 

training manuals from the FAA’s General Aviation and Commercial Division, AFS800, 800 Independence Avenue, SW., Washington, DC 20591. The training manuals 

and approval documentation must be made immediately available to any representative 

of the FAA Administrator, upon request.

3. Except as provided in Condition/Limitation No. 4, before a pilot can serve as pilot in 

command (PIC) in the AT-802, AT-802A, AT-1002, or AT-1002A that pilot must 

have successfully completed familiarization ground training that includes a review of 

the approved aircraft flight manual and cockpit familiarization checkout. This 

checkout must include ground training on the aircraft’s systems, performance, and 

handling characteristics.

4. Pilots who have logged at least 100 hours of flight time, with at least 10 hours in the 

preceding 12 months, in an AT-802, AT-802A, AT-1002, or AT-1002A need not 

complete the training requirements of Condition No. 3. A record of this flight time 

must be made available by the pilot upon request by a representative of the FAA 

Administrator.

5. Air Tractor must -

a. Ensure each pilot logs the ground training in his or her logbook, or Air Tractor 

must record such training in the pilot’s training record; and

b. Make this record of training available for review to any representative of the 

FAA Administrator, upon request.

6. The person qualified to give training under this exemption must meet the following 

minimum qualifications:

a. Be authorized by Air Tractor to give this instruction;

b. Hold at least a commercial pilot certificate; and

c. Meet the following experience requirements:
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i. 500 hours of flight time in turbine-powered agricultural type airplanes; 

or

ii. 1,000 hours of flight time in agricultural type airplanes which includes 

at least 100 hours of flight time in an AT-502 or AT-802, AT-802A, 

AT-1002, or AT-1002A.

7. Air Tractor must make a copy of this exemption available to each pilot who serves as 

PIC in the AT-802, AT-802A, AT-1002, or AT-1002A.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 5651M, to April 30, 2016, unless 

sooner superseded or rescinded. 

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
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Project No.: AFS-14-156-E

Project Officer: _______________

ARM-201:SLong:02/18/14:Doc#38173

ARM-1/200/201:Program Office AFS-810

MIKE RHODES

CHIEF TEST PILOT

AIR TRACTOR, INC.

P.O. BOX 485

OLNEY, TX 76374