US Department of Transportation 

Federal Aviation Administration 

1200 New Jersey Ave 

SE West Building Ground Floor 

Room W12-140 

Washington, D.C. 20590 

Rule from which exemption is sought: 14 CFR § 61.63(d)91), 61.63(e)(1) and 61.157(g) 

Gentlemen: 

Columbia Helicopters, Inc (CHI) respectfully requests an exemption from 14 CFR 61.63(d)(1), 61.63(e)(1) 

and 61.157(g) in order to issue "VFR Only" type ratings in the BV-234. Specifically, this exemption would 

allow CHI pilot applicants to provide an aircraft capable of demonstrating the instrument maneuvers 

and be given the practical test to the requirements for an "Aircraft Type Rating Limited to VFR" in the 

ATP Practical Test Standards for Helicopters. The pilot would then be issued a BV-234 type rating limited 

to "VFR Only". 

CHI recognizes that a type rating practical test taken in actual or simulated 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 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 BV-234 helicopters owned and operated by Columbia Helicopters, Inc. 

• Permit Examiners to conduct type rating practical tests in the BV-234 to the requirements for an 

"Aircraft Type Rating Limited to VFR". 

• Authorize pilot applicants without an instrument rating to apply for an aircraft type rating in the 

BV-234 limited to "VFR Only". 

Arguments in support: 

In February 2015, the FTW AEG (Mark Fletcher) conducted an analysis with Columbia Helicopters on the 

differences between the BV-234 and CH-47D. Although the restricted category 47Ds are limited to VFR 

only, the final determination was that there were not enough differences between the two aircraft to 

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 
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