SE West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Rule requirement from which exemption is sought: 14 CFR § 91.313(a) 

Gentlemen: 

Columbia Helicopters, Inc respectfully requests an exemption from 14 CFR § 91.313(a) in order to meet 

the requirements of§ 61.31 in their fleet of Restricted Category CH-47Ds. Specifically, this exemption 

would allow CHI pilot applicants to receive the requisite training and practical check required by§ 

61.63(d). 

CHI recognizes that airworthiness standards for Restricted category aircraft do not meet the same level 

of safety that is required of Standard or Transport category helicopters. The operating limitations set 

forth in 91.313(a) were justly established to compensate for this and to provide the necessary level of 

safety for special purpose operations. However, CHI contends that an equivalent level of safety would 

be met by the conditions/limitations requested in this exemption. 

CHI requests that the nature and extent of this regulatory relief: 

• Extend only to pilots employed by Columbia Helicopters, Inc. 

• Extend only to those aircraft owned and maintained by Columbia Helicopters i.a.w. TCDS 

R00051SE. 

• Permit proficiency training for pilots seeking to take a practical test for a type rating in the CH47D. 

• Allow for practical tests to be performed necessary to issue a type rating. 

• That the exemption be valid until such time as a Transport category CH-47D becomes available 

to Columbia Helicopters. 

Discussion: 

1. The FAA recently reversed its ruling regarding an interpretation of 14 CFR § 91.313(a). This 

reversal now (re-)authorizes training and checkrides required by§ 61.58 in Restricted category 

aircraft. "These flights, such as flights needed to satisfy the PIC proficiency checks required by§ 

61.58, are considered necessary to accomplish the work activity directly associated with the 

aircraft's special purpose and would not require regulatory exemption." (FAA Exemption No. 

11180). 

MAILING ADDRESS: P.O. Box 3500 Portland, Oregon 97208-3500 LOCATION: Aurora Airport Aurora, Oregon 

TELEPHONE: (503) 678-1222 FAX: (503) 678-5841 WEBSITE: www.colheli.com 
3. There are no Standard or Transport category CH-47Ds in the US inventory. Type rating practical 

tests must be given in a Restricted category aircraft. 

4. Columbia Helicopters is contracted by the USFS for wild land fire suppression. Since 2011, CHI has 

flown over 6000 hours in support of these operations. They are clearly in the best interest of the 

public. 

5. Exemption No. 11180 was given to Billings Flying Service under identical circumstances. A similar 

exemption was given to Sikorsky for their Restricted category S-61s (Exemption No. 10863). 

Given that Columbia Helicopters' petition does not set precedence and is identical in nature to 

Exemption No. 11180, its inclusion in the Federal Register is not warranted. In addition, any delay in 

granting this exemption will have a detrimental effect on Columbia Helicopters' ability to qualify pilots 

and serve the public during the upcoming fire season. 

Sincerely, 

Chris S. Gage 

Director of Flight Operations 

Columbia Helicopters, Inc. 

503-678-1222 Ext. 277 

cgage@colheli.com