US Department
of Transportation Federal Aviation Administration 1200New Jersey Ave SE West Building Ground Floor Room W12-140 Washington, D.C. 20590 COLUMBIA HELICOPTERS, INC. Rule from which exemption

is sought:14CFR § 61.63(d)91), 61.63(e)(1) and 61.157(g) Gentlemen: Columbia Helicopters, Inc (CHI) respectfully requestsan exemption from14CFR 61.63(d)(1), 61.63(e)(1) and 61.157(g)

in order toissue"VFR Only" type ratingsinthe BV-234. Specifically, this exemption would allow CHI pilot applicants to provide anaircraft capable of demonstrating the instrument maneuvers and be given the practical testtothe requirements for an"Aircraft Type Rating Limited toVFR"inthe ATP Practical Test Standards for Helicopters.The pilot would then be issued
aBV-234 type rating limited to"VFR Only"

. CHI recognizes thata type rating practical testtakenin actual orsimulated instrument conditions
as per § 61.62(d)(4) provides the most comprehensive examination

of an applicant. However, CHI contends that an equivalent level of safety would be met bythe conditions/limitations requested

inthis exemption. CHI requeststhat the natureand extentof this regulatory relief

: •Extend only to pilots employed by Columbia Helicopters

,Inc

. •Extend only tothose BV-234 helicopters owned and operated by Columbia Helicopters, Inc. •Permit Examiners toconduct type rating practical testsinthe BV-234 tothe requirements for an "Aircraft Type Rating Limited toVFR". •Authorize pilot applicants without aninstrument rating to apply for anaircraft type ratinginthe BV-234 limited to"VFR Only". Arguments

in support: In February 2015,theFTW AEG (Mark Fletcher) conducted
an analysis with Columbia Helicopters
onthe differences between the BV-234 and CH-47D. Although the restricted category47Ds arelimited toVFR only, the final determination wasthat there werenot enough differences between the twoaircraft to MAILING ADDRESS: P.O. Box 3500 Portland, Oregon 97208-3500 LOCATION: Aurora Airport Aurora, Oregon TELEPHONE: {503) 678-1222FAX: (503) 678-5841 WEBSITE: www.colheli.comwarrant separate type ratings. Conceivably

a pilot could take a practical test (for the issuance of a type rating) in the CH-47D, be issued
a BV-234 type rating limited to "VFR Only", then use these privileges to fly the 234 VFR with no further testing. At present there are no DPEs qualified to issue unlimited BV-234 type ratings. Per§ 135.293(c) "each competency check given in a rotorcraft must include

a demonstration

of the pilot's ability to maneuver the rotorcraft solely by reference to instruments." This implies that all pilots flying for compensation

or hire, to include those operating strictly VFR, are trained and checked on the instruments and procedures required for IFR flight. Notwithstanding, those who conduct IFR operations are obviously required to have unlimited type ratings and be qualified to do so. These requirements ensure that an equal level of safety to the existing rule is afforded to the public. CHI provides three BV-234 helicopters
to the USFS for firefighting operations and one to DoD in support of Operation Enduring Freedom

in Afghanistan. Continued support

is contingent on qualifying new pilots and, as such, is in the best interest of the public. Summary: Rule from which relief is sought: 14 CFR § 61.63(d)(1), 61.63(e)(1) and 61.157(g) Description
of relief sought: To permit pilot examiners
to conduct type rating practical tests in the BV234 to the requirements for an "Aircraft Type Rating Limited to VFR". In addition; authorize pilot applicants without an instrument rating to apply for an aircraft type rating in the BV-234 limited to "VFR Only". Thank you for your consideration. Si :? ChrisS. Gage Director of Flight Operations Columbia Helicopters, Inc. 503-678-1222 Ext. 277 cgage@colheli.com