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 Authoriz ation 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 reques ts 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

traini ng 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 S ervice 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 Ai rworthiness certificate in the r estricted category. Per 14 CFR 91.313 (b), the operator also is granted the ability to perform tr aining in these missions. These restr icted category aircraft have an extensive history with millions of Safe flight hours conducting training and check

rides.

Only recently, the r estrictions 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 check s 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 rati ng 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) prescrib es, 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 tha t 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 a n 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 i n a special purpose operation for which t he 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 per formed 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 requ e sts 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 1086 3, 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 re stricted category

aircraft.

For clarification about this request, please contact the und ersigned at (406) 579

- 1195 , or email jeff @ flybfs. com

Regards,

,

Jeff Cook Billings Flying Service