US Department of Transportation Dated 1/14/2015

Federal Aviation Administration

1200 New Jersey Avenue

SE West Building Ground Floor 

Room W12-140

Washington, DC 20590

Billings Flying Service – FAA Authorization to use a restricted category S-61 and CH-47 for 

training/checking for initial types/61.58 checks 

Reference (a) 14 CFR 91.313 (a,b)

(b) 14 CFR 61.31 and 61.58

Billings Flying Service requests an exemption from §91.313(a,b) to conduct training and check flights as 

required by §61.31 and 61.58 in a restricted category aircraft. Specifically, we request authorization to 

use Billings Flying Service S-61A, N561SC; CH-47D, 401AJ, 561AJ, and 562AJ to complete type rating 

training and check flights required by §61.31 and 61.58.

With the limited number of Billings Flying Service CH-47D and S-61 aircraft operating in the United 

States, aircrew training and check flights as required by Part 61 are unobtainable. Billings Flying Service

is supporting the United States government in fire suppression operations which requires training and 

check flights for our pilots. 

Justification

Our aircraft are operated under a special Airworthiness certificate in the restricted category. Per 14 CFR 

91.313 (b), the operator also is granted the ability to perform training in these missions. These restricted 

category aircraft have an extensive history with millions of Safe flight hours conducting training and check 

rides. 

Only recently, the restrictions on the airworthiness certificate and those found in 14 CFR 91.313 have 

been interpreted to restrict the aircraft use for type rating training and PIC checks.

Type rating training and PIC checks per 14 CFR 61.31 and 61.58 have been conducted by the operator

for many years. Billings Flying Service holds that such training and checking is safe and in accordance 

with all applicable regulations. Billings Flying Service requests an exemption to perform type rating 

training, type rating checks and currency checks for Billings Flying Service pilots. Such training presents 

no additional risk to the public and is in the public interest. 

Billings Flying Service requests exemption from the following regulations:

Section 91.313(a) prescribes, in pertinent part, that no person may operate a restricted category civil 

aircraft for other than the special purpose for which it is certificated; or in an operation other than one 

necessary to accomplish the work activity directly associated with that special purpose. 

Rationale for exemption: The aircraft, maneuvers and location of the requested training and checking

are identical to those that have been accomplished by the operator in the past. Performing the same 

operations under the oversite of an FAA DPE/Inspector/PPE in accordance with all provisions of 91.313, 

presents no additional risk to the public. 

Section 91.313(b) prescribes, in pertinent part that operating a restricted category civil aircraft to provide 

flight crewmember training in a special purpose operation for which the aircraft is certificated is 

considered to be an operation for that special purpose.

Rationale for exemption: No additional maneuvers or operations other than those already performed by 

the operator are to be performed in connection with the requested 61.31 or 61.58 training. Additionally, 

the location of the requested training is identical to that used by the operator. The requested training 

therefore does not present additional risk to the public and is in the public interest.
Billings Flying Service requests an exemption from §91.313(a,b) to conduct type rating training and check 

flights per §61.31 and 61.58 in a restricted category aircraft, Billings Flying Service S-61A and Ch-47D’s, 

N561SC, N401AJ, N561AJ, N562AJ. These flights pose no additional risk to the public and are in the 

public interest. A copy of the approved exemption will be carried in the aircraft at all times training or 

checking is being conducted. 

Please see exemption number 10863, regulatory docket number FAA-2013-0476. This is an example of 

Sikorsky Helicopters exemption from §91.313 (a,b) of title 14, code of federal regulations (14CFR) to the 

extent necessary to allow Sikorsky to conduct part 61 training and checking in a restricted category 

aircraft.

For clarification about this request, please contact the undersigned at (406) 579-1195, or email 

jeff@flybfs.com

Regards,,

Jeff Cook

Billings Flying Service