US Department
of Transportation Federal Aviation Administration 1200 New Jersey Avenue 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. Columbia Helicopters, Inc respectfully requestsan exemption from 14 CFR § 91.313(a)

in order tomeet the requirements of§ 61.31 in their fleet of Restricted Category CH-47Ds. Specifically, this exemption would allow CHI pilot applicants
toreceive the requisite training and practical check required by§ 61.63(d). CHI recognizes that airworthiness standards for Restricted category aircraft do notmeetthe samelevel 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 necessarylevel 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 natureand extentof this regulatory relief: •Extend only to pilots employed by Columbia Helicopters, Inc. •Extend only tothose aircraft owned and maintained
by Columbia Helicopters i.a.w

.TCDS R00051SE. •Permit proficiency training for pilots seeking totake a practical testfor a type rating in the CH47D

. •Allow for practical teststobe performed necessarytoissue a type rating. •That the exemption
be valid until such time asa 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, areconsidered necessaryto accomplish the work activity directly associated with the aircraft's special purposeand 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.com2. Flight training and practical tests conducted
tomeet the§ 61.58 arethe samemaneuvers performed
toconduct initial type rating certification. Both are performed i.a.w. the ATP Practical Test Standards for Helicopter

.They are virtually the samecheckride- only oneis given by a Designated Pilot Examiner {DPE) for the addition of a type rating and oneis given by aPilot Proficiency Examiner (PPE) to determine proficiency. Furthermore,

a pilot cannotmeetthe requirements of§ 91.313(a) or§ 61.58 unless he has successfully completed

a type rating practical test

. 3. There arenoStandard or Transport category CH-47Ds
in the US inventory

.Type rating practical testsmustbe given in aRestricted category aircraft. 4 .Columbia Helicopters

is contracted
by the USFS for wild land fire suppression

.Since 2011, CHI has flown over6000 hours in supportof 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 notset precedence and is identical
in natureto Exemption No. 11180, its inclusion
in the Federal Register

is not warranted.

In addition, any delay in granting this exemption will have adetrimental effect onColumbia Helicopters' ability to qualify pilots and servethe 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