1^-. 

February 3, 2010 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Exemption 14 CFR § 137.51 (b) (4) 

Dear Sirs: 

Pursuant to 14 CFR §11.81, ttiis is to request an exemption. 

We are: 

Al's Aerial Spraying, LLC 

3473 North Shepardsville Road 

Ovid. Ml 48866 

989-834-5067 worl< 

989-834-5098 fax 

Mike502B@aol.com 

AI400@aol.com 

Al's Aerial Spraying, LLC is a small disciplined agricultural operation. We have been in 

business for thirty two years. Our pilots have thousands of hours of agricultural 

application experience. We strictly operate turboprop powered Air Tractor aircraft, 

purpose built for agricultural operations. 

The specific section from which we request relief is; 

§ 137.51 Operation over congested areas: 

(b) No person may operate an aircraft over a congested area 

except in accordance with the requirements of this paragraph. 

(4) Single engine aircraft must be operated as follows: 

(i) Except for helicopters, no person may takeoff a loaded 

aircraft, or make a turnaround over a congested area. 

The extent of relief Al's Aerial Spraying, LLC seeks is an exemption to be allowed to use 

our single engine turboprop powered Air Tractor aircraft purpose built for agricultural 

application to takeoff and make turnarounds over congested areas in a loaded 

configuration. The reason that we seek this relief is that as owners, engineers and 

highly experienced pilots, we have determined that we are safer taking off or turning our 

turboprop Air Tractor aircraft over a congested area than if we were operating piston 

powered multi-engine airplanes for the same task. 
PUBLIC INTEREST 

The reasons why granting our request would be in the public interest and would benefit 

the public as a whole are as follows: 

Al's Aerial Spraying, LLC's pilots making takeoffs with loaded Air Tractor turboprop 

aircraft, and turning over congested areas are safer than operating the multi-engine 

piston powered airplanes currently directed by 14 CFR § 137.51. The later portion of 

this request will utilize publications issued by the Federal Aviation Administration (FAA) 

and statistics provided by both the FAA and National Transportation Safety Board 

(NTSB) to substantiate this fact. 

Additionally, many of Al's Aerial Spraying, LLC's contracts are to treat trees for Federal, 

State, and local governments. Pursuant to 14 CFR § 137.51 (b)(3), Al's Aerial Spraying, 

LLC submits a congested area plan that includes public relations news media release of 

application date and time information. The public is informed that agricultural aircraft 

will be applying material to prevent pests from destroying their trees. When the average 

person sees a piston powered multi-engine airplane flying low overhead he or she 

assumes that the airplane is in trouble and a crash is imminent. Use of the multi-engine 

aircraft causes both concern and complaints. 

Air Tractors have a distinctive look and turboprop engines are much quieter. When an 

average person sees our bright yellow Air Tractors in operation, they are able to make 

the connection to the press release. Significantly fewer calls are made to emergency 

services during Air Tractor aerial application, which allows 911 services to provide help 

to those who actually need it. 

Al's Aerial Spraying, LLC operates Air Tractor aircraft powered by Pratt and Whitney 

PT-6 turbo-prop engines. These aircraft are significantly more reliable and quieter than 

multi-engine piston powered airplanes. This reduces and/or eliminates noise complaints 

that are produced by operation of multi-engine piston powered airplanes. 

The United States Forest Service has extensively researched the effective swath width 

of the Air Tractor and other aircraft. The average swath or spray pattern of a multiengine piston powered airplane is 100 feet or less. The swath of an Air Tractor is 150 

feet. This equates to fewer passes and fewer turns overhead. This is less of an 

annoyance to property owners, more efficient, and once again much safer. 

Multi-engine powered airplanes are purpose built to travel and operate at higher speeds 

than aircraft purpose built for agricultural operations. Multi-engine airplanes must be 

flown at speeds that allow them to retain control of the airplane if an engine fails. These 

higher speeds translate to less saturation and penetration of the agricultural material 

being applied. By comparison, the Air Tractor high lift wing operates safely at a lower 

speed and the wake vortices created by the wing insure excellent coverage and 

penetration. The customer, who is frequently the taxpayer, gets the best results for the 

service he paid for. 
SAFETY 

There are many reasons why granting the exemption would not adversely affect safety. 

In fact this exemption would provide a higher level of safety than that provided by 14 

CFR §137.51. 

14 CFR § 137 was promulgated in 1967. At that time, the aircraft used for agricultural 

application were built for other purposes and modified to become Restricted Category 

aerial applicators. Civil Aeronautics Manual (CAM) 8, the regulation that was in place at 

that time lists example aircraft such as Aeronca 7AC, Boeing 75 (Stearman), and Piper 

J3 Cub as airplanes that could become Restricted Category for use in aerial application. 

In practice, many of these airplanes were worn out, used up trainers that gave the aerial 

application business a bad reputation. 

Since 1967, the technology of aerial application has advanced but the law has stood 

still. Millions of dollars have been spent on research and computer modeling of the 

spray droplets exiting aircraft and the measurement of spray drop spectrums produced 

by aircraft. Millions more are spent each year to trap, survey, and delineate the exact 

areas that will be targeted by an application to control a specific pest. 

The use of differentially corrected global positioning systems provides the accuracy to 

target hundreds of smaller application blocks scattered within a city instead of blanket 

spraying the entire population. Many products used to control pests are specific to one 

pest at only one growth stage. The window for effective application may be less than 

three days. The end result provides better control with less pesticide used and infinitely 

less environmental damage. It also means the application now consists of many 

smaller blocks requiring precise applications and many more turns. 

In order to property support these expensive efforts, there are now aircraft that are 

purpose built for agricultural application. Premier among these is the turboprop Air 

Tractor. Whether the job is spraying, seeding, fertilizing, or firefighting, more operators 

choose Air Tractor because they get the most productive, highest quality and costeffective agricultural planes available anywhere, at any price. Air Tractors provide 

superb visibility, light control forces, speed, and maneuverability for the pilot. 

Modified vs. Purpose Built - Wina Desian 

The function of almost all airplanes, especially multi-engine airplanes, is to travel. 

Aircraft are designed to takeoff, climb, and descend safely but trade-offs are made so 

that they will cruise efficiently. This is the case with aircraft modified to perform aerial 

application. 

The purpose built Air Tractor aircraft operated by Al's Aerial Spraying, LLC are built 

purely for Aerial Application purposes, Wing design is focused on the ability to turn 

safely low to the ground. 
Multi-engine aircraft are built to be stable. This makes them safe to fly in instrument 

meteorological conditions and comfortable to fly on long trips. These airplanes resist 

being turned or climbed as part of that inherent stability. This causes the airplane to lag 

behind pilot control inputs to turn or climb. This built-in 2 second lag time can be the 

difference between life and death when trying to avoid collision with another airplane or 

obstacle (AC 90-48, Appendix 1, Pilots' Roll in Collision Avoidance). 

The Air Tractor was deliberately built without this inherent control lag. Purpose built for 

agricultural operations, the Air Tractor reacts immediately to pilot control input. This 

enhances the pilot's ability to avoid collision with another airplane or the many obstacles 

encountered flying at 50 feet above tree top level. 

Modified vs. Purpose Built - Visibility 

The principal of "see and avoid" is fundamental to all flight in visual meteorological 

conditions. Fundamental to the "avoid" portion of that principal is having enough time to 

react to the sight of another aircraft or obstacle. The higher speeds that multi-engine 

aircraft must fly in order to retain control in the event of an engine failure diminish the 

multi-engine pilots' time to "see and avoid". 

Multi-engine aircraft are designed to fly high and fast. Because of this, they may be 

pressurized and or their windshields may be heated. Because of these systems and due 

to higher speed capabilities, the window posts of a multi-engine airplane must be wide 

to accommodate systems wiring and structural loads. These wide window posts 

become dangerous blind spots. (FAA PT-8740-51. How to Avoid a Midair Collision). 

By comparison, the Air Tractor has superb visibility for the pilot. The Air Tractor has 

more windows and they are larger. Window posts are narrow. Degrees of view up and 

down, and left and right are much better. The pilot sits with his head and shoulders 

over the instrument panel further eliminating blind spots below the wing. This 

outstanding visibility gives the Air Tractor pilot the edge in seeing and avoiding collision 

with other aircraft and the numerous obstacles encountered flying at 50 feet above tree 

top level. 

Reciprocating vs. Turboprop Engines 

When 14 CFR § 137 was promulgated in 1967, all of the airplanes modified into 

Restricted Category agricultural aircraft were equipped with piston engines also known 

as reciprocating engines. The multi-engine aircraft that were used then, and that can be 

legally used for agricultural application now are also equipped with reciprocating 

engines. 

Eventually, restricted category agricultural aircraft were retrofit with turboprop engines 

and finally manufacturers of purpose built agricultural airplanes made the turboprop 

engine standard equipment as is true with Al's Aerial Spraying, LLC's Air Tractors. The 
FAA's Airplane FIving Handbook (H-8083-3A) describes the turboprop engine as 

follows: 

Both piston (reciprocating) engines and gas turbine engines are internal corr^bustion 

engines. They have a similar cycle of operation that consists of induction, compression, 

combustion, expansion, and exhaust. In a piston engine, each of these events is a 

separate distinct occurrence in each cylinder. Also, in a piston engine an ignition event 

must occur during each cycle, in each cylinder. Unlike reciprocating engines, in gas 

turbine engines these phases of power occur simultaneously and continuously instead of 

one cycle at a time." 

The development of the turboprop engine w/as an attempt to combine in one engine the best 

characteristics of both the turbojet, and propeller driven reciprocating engine. 

The turboprop engine offers several advantages over other types of engines such as: 

• Light weight. 

• Mechanical reliabilitv due to relativelv few moving parts. 

' Simplicitv of operation. 

• Minimum vibration. 

• High power per unit of weight (emphasis added) 

Mechanical reliability and simplicity of operation equate to safety. The statistics provided 

in the later part of this request, show that turboprop engines are substantially less likely 

to fail than reciprocating engines. 

Al's Aerial Spraying, LLC's Air Tractors are powered by Pratt & Whitney PT-6 turbo-prop 

engines. These engines are built for high reliability. Additionally, Al's Aerial Spraying, 

LLC complies with manufactures' recommended overhaul periods or FAA approved 

intervals. Al's Aerial Spraying, LLC's PT-6 engines are operated on an inspection 

program to increase reliability, durability and safety. 

Therefore, Al's Aerial Spraying, LLC's Air Tractors powered by Pratt & Whitney PT-6 

turbo-prop engines are less likely to experience an engine failure than the multi engine 

piston powered aircraft allowed by this rule. 

Single Engine vs. Multi-Enoine 

Logically, the purpose of having two engines instead of one is that, in the event of an 

engine failure, the multi engine airplane should be able to be flown to an airport where it 

can land safely. This may or may not be achievable depending on the situation at hand. 

With the exception of centeriine thrust, what is ALWAYS true when a multi engine 

pilot experiences an engine failure is that he must first take several steps to 

prevent himself from completely loosing control of the airplane. The following is 

directly excerpted from FAA publication P 8740-19, Flvina Light Twins Safely: 

The major difference between flying a twin engine and a single engine airplane is 

knowing how to manage the flight if one engine loses power for any reason. Safe flight 

with one engine-out requires an understanding of the basic aerodynamics involved as 

well as proficiency in engine-out procedures. 
Loss of power from one engine affects both climb performance and controllabilifv of any 

light twin, (emphasis added) 

Climb performance depends on an excess of power over that required for level flight. 

Loss of power from one engine obviously represents a 50% loss of power but, in virtually 

all light twins, climb performance is reduced by at least 80%. 

The amount of power required for level flight depends on how much drag must be 

'overcome' to sustain level flight. It's obvious, that if drag is increased because the gear 

and flaps are down and the prop windmilling, more power will be required. Not so 

obvious, however, is the fact that drag also increases as the square of the airspeed while 

power required to maintain that speed increases as the cube of the airspeed. 

Thus, climb performance depends on four factors: 

* Airspeed - too little or too much will decrease climb performance. 

* Drag - gear, flaps, cowl flaps, prop and speed. 

* Power - amount available in excess of that needed for level flight. 

* Weight - passengers, baggage and fuel load greatly affect climb 

performance. 

Multi-engine aircraft modified for aerial application have the additional burden of drag 

produced by spray booms and other agricultural appliances mounted on the exterior of 

the airplane. Performance data provided by the multi engine aircraft manufacturer might 

show that it can climb with an engine failure but this is based on ideal conditions, no 

additional externally mounted equipment, and the pilot doing everything exactly right. 

Pilots are licensed by the FAA in accordance with their Practical Test Standards (PTS). 

The FAA Commercial Multi-Engine PTS FAA-S-8081 includes the following note: 

Examiners shall select an entn^^ altitude that will allow the single engine demonstrations to 

be completed no lower than 3.000 feet f920 meters) AGL or the manufacturer's 

recommended altitude, whichever is higher, (emphasis added) 

This note shows that the FAA cleariy recognizes the danger that an engine failure poses 

to the controllability of a multi-engine airplane operated at an altitude lower than 3000 

feet above ground level (AGL). Aerial application requires that these same airplanes be 

operated at 50 feet above tree top level. 

The FAA Practical Test Standard delineates that the pilot of a multi-engine aircraft that 

experiences an engine failure while involved in aerial application 50 feet above tree top 

level must: 

Recognize an engine failure promptly, maintain control, and utilize 

appropriate emergency procedures. 

Reduce drag raising the landing gear or flaps as appropriate. 

Identify and verify the inoperative engine. 

Feather the propeller on the inoperative engine. 
Establish VYSE (Best rate of climb with one engine inoperative); If 

obstructions are present, establish VXSE (Best angle of climb with one 

engine inoperative) or VMC (minimum control speed with the critical 

engine inoperative) +5 knots, whichever is greater, until obstructions are 

cleared. Then transition to VYSE. 

Bank toward the operating engine as required for best performance. 

Monitor the operating engine and make adjustments, as necessary. 

Recognize the airplane's performance capabilities. If a climb is not 

possible at VYSE, maintain VYSE and return to the departure airport for 

landing, or initiate an approach to the most suitable landing area available. 

Secure the inoperative engine. 

Complete an emergency checklist. 

The pilot must accomplish all of these tasks without colliding with the ground below, 

another airplane or one of the many obstacles encountered flying at 50 feet above tree 

top level. Many of these tasks require that the pilot keep his eyes inside the cockpit for 

an extended period of time. 

By comparison, in accordance with FAA H-8083-3, Airplane FIving Handbook, the pilot 

of a single engine aircraft that experiences an engine failure while involved in aerial 

application fifty feet above ground level must: 

Establish and maintain the recommended best glide airspeed, ±10 knots. 

Select a suitable landing area. 

Follow the appropriate checklist. 

You don't have to be a Human Factors expert to see that at 50 feet above the tree top 

level, which of these scenarios is most likely to have the better outcome. Further, in the 

case of an Al's Aerial Spraying, LLC Air Tractor, the aircraft will be operating at greater 

than best glide speed and the pilot will be able to climb, trading that speed for altitude 

and time. Additionally, Al's Aerial Spraying, LLC's Congested Area Plans provide 

emergency landing areas to their pilots. These areas are reviewed pre-flight every day 

of operation and their pilots know where they are in relation to these areas at all times. 

Therefore, despite a multi engine piston powered airplane having the second engine 

available, it is still more likely to crash in the event of an engine failure than the single 

engine Air Tractor. In the relatively unlikely event an Al's Aerial Spraying, LLC Air 

Tractor experiences an engine failure, the pilot will be able to use the stored energy of 
the airspeed that he is flying to climb and travel according to Air Tractor Manufacturer's 

data, in excess of 1.5 miles to a pre-determined landing area and land. 

The Current Multi Engine Reguirement 

We have stated that operating a single engine turboprop powered Air Tractor aircraft 

purpose built for agricultural application to takeoff and make turnarounds over 

congested areas in a loaded configuration is safer. What needs to be further explored is 

that operating a multi engine airplane in this environment is not just less safe, it is 

dangerous. The current regulation states as follows: 

§ 137.51 Operation over congested areas: General 

(a) Notwithstanding Part 91 of this chapter, an aircraft may be operated over a 

congested area at altitudes required for the proper accomplishment of the 

agricultural aircraft operation if the operation is conducted -

(1) With the maximum safetv to persons and propertv on the surface, 

consistent with the operation; (emphasis added) 

The regulation requires that agricultural operators operate with the maximum safety to 

persons and property but in order to take off or turn in a loaded configuration, the rule 

requires that they utilize multi-engine aircraft. When we review the FAA's own Airplane 

Flying Handbook (FAA 8083), we find that this is inconsistent with 14 CFR 137.51 (b) 

(5). 

§ 137.51 Operation over congested areas: General. 

(b) No person may operate an aircraft over a congested area except in 

accordance with the requirements of this paragraph. 

(5) Multiengine aircraft must be operated as follows: 

(ii) No person may operate a multiengine airplane at a weight 

greater than the weight that, with the critical engine inoperative, 

would permit a rate of climb of at least 50 feet per minute at an 

altitude of at least 1.000 feet above the elevation of the highest 

ground or obstruction within the area to be worked or at an altitude 

of 5.000 feet whichever is higher. For the purposes of this 

subdivision, it is assumed that the propeller of the inoperative 

engine is in the minimum drag position; that the wing flaps and 

landing gear are in the most favorable positions; and that the 

remaining engine or engines are operating at the maximum 

continuous power available, (emphasis added) 

The regulatory requirement for a climb with the critical engine inoperative is expressed 

as "a rate of climb of at least 50 feet per minute". The FAA's Airplane Flying Handbook 

(FAA 8083) explains the certification standards for reciprocating engine powered multi 

engine airplanes: 

8 
VMC - Minimum control speed with the critical engine inoperative. There is no 

reouirement in this determination that the airplane be capable of climbing at this airspeed. 

VMC only addresses directional control. 

The current 14 CFR part 23 single-engine climb performance requirements for 

reciprocating engine powered multiengine airplanes are as follows. 

• 6,000 pounds or less maximum weight and VSO 61 knots or less; the singleengine rate of climb at 5,000 feet MSL must simply be determined. The rate of 

climb could be a necative number. There is no requirement for a single-engine 

positive rate of climb at 5.000 feet or any other altitude. For light-twins type 

certificated February 4,1991, or thereafter, the single engine climb gradient 

(positive or negative) is simply determined. Rate of climb is the altitude gain per 

unit of time, while climb gradient is the actual measure of altitude gained per 100 

feet of horizontal travel, expressed as a percentage. An altitude gain of 1.5 feet 

per 100 feet of travel (or 15 feet per 1,000, or 150 feet per 10,000) is a climb 

gradient of 1.5 percent, (emphasis added) 

In accordance with 14 CFR Part 23, small multi engine airplanes have no FAA 

certification requirement for a singie engine positive rate of ciimb. Aircraft 

performance to comply with FAA certification standards is based on climb gradient. 

This makes the agricultural operator or for that matter FAA Inspector's ability to 

detennine whether a multi engine airplane can comply with 14 CFR § 137.51 (b) (5) 

improbable. 

Above and beyond that, it is also apparent that 14 CFR § 137.51 (b) (5) holds no 

requirement for these multi-engine aircraft used in agricultural operations flying 50 feet 

above tree top level to maintain engines within the manufacturer's overhaul times. 

There is no requirement for them to have a low fuel warning system or systems that 

provide pilots with information while the pilot keeps his eyes outside the aircraft. There 

is no requirement that the pilots have additional training regarding engine failures low to 

the ground at low speeds in steeply banked turns. 

The faster an aircraft is flying, the larger the turn radius. Conversely, the slower an 

aircraft is flying, the smaller the turn radius. A major factor of flying an agricultural 

application in a congested area is the need for multiple turns to be made in a very small 

radius. This necessitates that the multi engine airplanes required by this regulation to be 

flown at a low speed and turned at higher than standard bank angles. Once again the 

FAA's Airplane Flying Handbook (FAA 8083) is instructive. 

Engine failures well above the ground are handled differently than those occurring at 

lower speeds and altitudes. Cruise airspeed allows better airplane control, and altitude 

may permit time for a possible diagnosis and remedy of the failure. 

To maintain directional control of a multiengine airplane suffering an engine failure at low 

speeds (such as climb), momentarily bank at least 5'', and a maximum of 10° towards the 

operative engine as the pitch attitude for VYSE is set. This maneuver should be 

instinctive to the proficient multiengine pilot and take only 1 to 2 seconds to attain. It is 

held just long enough to assure directional control as the pitch attitude for VYSE is 

assumed. 
A multi engine airplane that is in a slow steeply banked turn and suffers failure of the 

engine on the inside of that turn at 50 feet above tree top level is going to crash. In 

order to maintain control, the pilot would be required to bank the airplane at least 5° to 

10° towards the operative engine. When an engine fails and the aircraft is banked at 

least 45*^ towards the inoperative engine, it is unlikely that the pilot will even detect the 

engine failure before the operating engine rolls him into the ground and he dies. Once 

again the FAA's Airplane Flying Handbook (FAA 8083) is enlightening. 

In One Engine Inoperative (OEI) flight at low altitudes and airspeeds such as the initial 

climb after takeoff, pilots must operate the airplane so as to guard against the three major 

accident factors: (1) loss of directional control, (2) loss of performance, and (3) loss of 

flying speed. All have egual potential to be lethal, (emphasis added) 

No doubt, in 1967 the authors of this regulation believed that logically two engines are 

better than one without knowledge of the physics involved or benefit of FAA training 

publications or another 43 years of development and statistics. 

Statistics 

The statistics further prove that that we are safer taking off or turning our turboprop Air 

Tractor aircraft over a congested area than if we were operating piston powered multiengine airplanes for the same task. The following safety information is summarized from 

the contents of a report prepared by: Robert E. Breiling Associates, Inc., Boca Raton, 

FL, based on the information available from NTSB and FAA sources. 

SINGLE TURBOPROP POWERPLANT AIRCRAFT RELIABILITY 

Summary/Findings 

Powerplant Reliability Comparative Data - Five Year Average. 1992-1996 

Accidents per 100,000 hours by major aircraft type, 5 year average 1992-1996 

Single engine reciprocating powered aircraft 9.26% 

Multi-engine reciprocating powered aircraft 5.68% < 

Multi-engine turboprop powered aircraft 4.34% 

Single engine turboprop aircraft 1.46% M 

Percent of general aviation fixed wing aircraft accidents attributed to 

power loss - all causes - 5 year average, 1992-1996 

Single engine reciprocating powered aircraft 33.5% 

Multi-engine reciprocating powered aircraft 27.6% -4 

Multi-engine turboprop powered aircraft 8.0% 

Single engine turboprop aircraft 0% M 

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Breiling concludes: 

Based on the review and analysis of accident data involving multi and single 

reciprocating and turboprop powerplant malfunction / failure accidents and analysis of the 

various powerplant reliability data available, a single turboprop powered aircraft, with 

adeouate backup systems provided in it's design, will be more reliable, involved in fewer 

powerplant malfunction / failure related accidents than that of single or multi reciprocating 

powered fixed wing aircraft and comparable to the reliabilitv of a multi-turboprop powered 

aircraft, (emphasis added) 

Precedent 

At one time the FAA prohibited 14 CFR § 135 single engine (SE) operations under 

instrument flight rules (IFR) and night operations in both reciprocating and turbinepowered aircraft. In May 1998 regulations were revised to expand SE operating 

authority, with the proviso that additional maintenance, equipment requirements, aircrew 

training and experience levels were met. 

Many factors influenced the decision, including data showing the Cessna C208 Caravan 

turboprop to have a high level of reliability and Canada's positive experience with SE 

IFR. Cessna C208 Caravan fatal accidents in the USA, 1985-1996 (2.6 million flight 

hours), were 0.56 per 100,000 hours; fatal accidents due to mechanical failures of the 

engine were zero. Al's Aerial Spraying, LLC's Air Tractor aircraft are equipped with the 

same Pratt & Whitney PT-6 turboprop engine as the Cessna C208 Caravan, 

Al's Aerial Spravinq. LLC Maintenance. Eouipment. and Aircrew Experience Levels 

Al's Aerial Spraying, LLC is a small disciplined agricultural operation. We have been in 

business for thirty two years. Compared to the FAA 100 hour requirement, our pilots 

have at a minimum 2,500 hours of agricultural time, minimum of 6,500 hours total time 

and average 14,500 hours of flying time. Our pilots have chosen to make aerial 

application their profession. They have worked with our firm for several years and have 

all worked on thousands of acres over congested areas. 

The Air Tractor is the only aircraft that Al's Aerial Spraying, LLC operates. The design of 

the Air Tractor is the cornerstone that provides the necessary visibility, maneuverability, 

reliability, and excellent glide distance that has made our impeccable safety record 

possible. Pratt and Whitney PT-6 turbines provide the power-plant for all our Air 

Tractors. Their reliability is well documented in the aviation industry. 

Air Tractor Inc. in OIney, Texas provides superior product support. Their proactive 

testing of aircraft is extensive and ongoing. Air Tractor's Service Bulletin system 

anticipates service difficulties and provides solutions before problems occur. Al's Aerial 

Spraying, LLC's Air Tractors also have cabin heat and air conditioning to reduce pilot 

fatigue. 

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In addition to compliance with airworthiness directives and inspections, our firm also 

complies with manufactures' recommended overhaul periods or FAA approved 

intervals. Our firm holds a 135 certificate, and maintains our Air Tractors to the same 

high standards. 

Al's Aerial Spraying, LLC's PT-6 turboprop engines are operated on inspection 

programs. These programs are aggressive inspection system designed to find problems 

in their eariy stages and correct them promptly. Early correction of engine problems 

leads to increased reliability, durability and safety. 

All of Al's Aerial Spraying, LLC's Air Tractors are equipped with a Supplemental Type 

Certificate (STC) that permits single point refueling. This feature permits our pilots to 

verify that the Air Tractors are full of fuel and prevents them from being mis-fueled. 

Further, this STC provides fuel totalizers, flow meters, and low fuel lights so we know 

how much fuel we are burning and can verify fuel remaining. This provides our pilots 

with the necessary information to prevent fuel starvation. 

Each Al's Aerial Spraying, LLC's Air Tractor is equipped with a SATLOC Differentially 

corrected Global Positioning System (DGPS). This tool provides the pilot with the 

location of the closest non-congested area at all times. Additionally, each Air Tractor 

has a Garmin 496 to provide our pilots with weather and airspace information. Both of 

these tools provide our pilots with the best situational awareness in the business. 

Al's Aerial Spraying, LLC maintains two discrete radio frequencies purchased from 

Aviation Spectrum Resources Inc. to facilitate communications. This enhances the 

necessary communication between our application aircraft without concern for 

frequency congestion. 

Al's Aerial Spraying, LLC's congested area plans include daily scheduled briefings for 

our pilots. These briefings provide our pilots' a clear picture of the congested area plan 

and refresh their memory for the flights scheduled that day. Aerial photos of the areas to 

be sprayed are posted in our operations trailer and are reviewed. If the areas are 

complex, then smaller aerial photos are provided to the pilots for use in the cockpit. 

Additionally, Al's Aerial Spraying, LLC conducts daily post flight briefings. This provides 

us with real time feedback regarding the congested area plans and all aspects of our 

operation. Our pilots know they can bring up any experience for discussion. If changes 

are warranted, they can and will be made. These briefings are a "check your egos at 

the door" and "learn from each others' mistakes" type sessions and have helped us 

maintain the safety record we have today. These post flight briefings are an important 

component of our culture of safety that we work to promote each and every day. 

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SUMMARY 

The rule from which Al's Aerial Spraying. LLC seeks exemption: 

§ 137.51 Operation over congested areas: 

(b) No person may operate an aircraft over a congested area 

except in accordance with the requirements of this paragraph. 

(4) Single engine aircraft must be operated as follows: 

(i) Except for helicopters, no person may takeoff a loaded 

aircraft, or make a turnaround over a congested area. 

This is to request relief from § 14 CFR 137.51(b) (4) (i). This request proposes to 

enhance safety by allowing Al's Aerial Spraying, LLC to utilize single engine Pratt & 

Whitney PT-6 turboprop powered Air Tractor aircraft, purpose built for agricultural 

application to takeoff and make turnarounds over congested areas in a loaded 

configuration. Information and data provided by Al's Aerial Spraying, LLC show that this 

is in the public interest and provides a higher level safety than what currently exists in 

the present regulation. 

Thank you for your assistance in this matter. 

Sincerely, 

Michael D. Schiffer, Partner 

Al's Aerial Spraying, LLC 

3473 North Shepardsville Road 

Ovid, Ml 48866 

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