AFS-15-384-E 

May 5, 2015 

 Exemption No. 11470 

 Regulatory Docket No. FAA-2015-0110 

Mr. Adam L. Tjelmeland 

President & CEO 

Parker Bennecorp 

P.O. Box 1139 

Patterson, LA 70392 

Dear Mr. Tjelmeland: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated January 15, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Airborne Support, Inc. (Airborne) for an exemption from §§ 91.313(a)(1) and (c) 

of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow Airborne 

to conduct operations needed to satisfy crewmember training, type rating requirements, and 

proficiency requirements found in part 61 for restricted category aircraft. 

Section 91.313(a) limits operation of a restricted category aircraft to: (1) the special purpose 

operation for which it is certificated; and (2) an operation necessary to accomplish the work 

activity directly associated with that special purpose. While the petitioner has only requested 

relief from § 91.313(a)(1), the FAA is construing this request as a one for relief from 

§ 91.313(a) in its entirety. Based on previous analysis contained in similar grants of 

exemption, the FAA does not believe that § 91.313(a)(1) can be separated from 91.313(a)(2) 

in any meaningful way. 

Section 91.313(c) prescribes in pertinent part, that no person may operate a restricted category 

civil aircraft carrying passengers or property for compensation or hire. Further, for the 
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purpose of this section, a special purpose operation involving the carriage of persons or 

material necessary to accomplish that operation[s] for the purpose of providing flight 

crewmember training in a special purpose operation, are not considered to be the carriage of 

persons of property for compensation or hire. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to Airborne. 

The FAA contacted the petitioner on February 24, 2015, to clarify the aircraft that Airborne 

would operate under the requested relief. The petitioner responded via e-mail the same day 

and noted the aircraft registration numbers Airborne would use under this exemption. 

Additionally, the FAA contacted the petitioner on March 31, 2015, for clarification on the 

relationship between the petitioner and the aircraft operator. The petitioner responded via 

e-mail the same day clarifying that the operator which would exercise relief under a grant of 

exemption is Airborne Support, Inc. Both records of conversation capturing this information 

were placed in the docket. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 11245 (copy enclosed), the FAA 

found that an exemption was appropriate to allow Neptune Aviation Services to conduct 

practical tests, proficiency training, and associated flights in restricted category aircraft. 

Having reviewed your reasons for requesting an exemption, I find that: 

 They are similar in all material respects to relief previously requested in the enclosed 

Grant of Exemption No. 11245; 

 The reasons stated by the FAA for granting the enclosed Grant of Exemption No. 11245 

also apply to the situation you present; and 

 For the reasons stated in Grant of Exemption No. 11245, a grant of exemption is in the 

public interest. 

Our Decision 

Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701 

delegated to me by the Administrator, I grant Airborne Support, Inc. (Airborne) an exemption 

from 14 CFR §§ 91.313(a) and (c) to the extent necessary to allow Airborne to conduct 

operations needed to satisfy crewmember training, type rating requirements, and proficiency 

requirements found in part 61 for restricted category civil C-54D-DC, C-47, C-47A and 

DC3C series aircraft, subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. The privileges of this exemption are limited to the following aircraft: 

a. C-54D-DC: N67024 
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b. C-47: N64766 

c. C-47A: N64767 

d. DC3C: N932H 

2. Airborne must be in full operational control of any aircraft operated using the 

privileges of this exemption. 

3. The relief from § 91.313(c) is only granted to the extent necessary to allow for the 

operations described in Condition/Limitation No. 4. 

4. Airborne may only use the aircraft for the special purposes identified on the 

restricted category airworthiness certificate for the aircraft in Condition/Limitation 

No. 1 and the following operations: 

a. Practical tests necessary to issue type ratings required by § 61.31(a) to pilots 

employed by Airborne, 

b. Flight training for pilots employed by Airborne seeking to take a practical test 

for a type rating designation necessary to operate an aircraft covered under this 

exemption; and, 

c. Observation flights performed for the purpose of designating or observing a 

Designated Pilot Examiner (DPE). 

5. An aircraft configuration analysis including, but not limited to, flight deck, flight 

manual, operating limitations, required placards, and procedures must be 

completed and provided to the Flight Standards District Office (FSDO) with 

geographic responsibility for the airport or area where the aircraft is based. This 

analysis must reflect the capability of the aircraft to perform all required 

procedures and maneuvers necessary to meet the applicable requirements of the 

aircraft type rating Practical Test Standards (for airplanes, FAA-S-8081-5F, as 

amended). 

6. A copy of this exemption must be provided to the FSDO in the geographic region 

where the aircraft is based, must be provided to any representative of the 

Administrator upon request, and must be carried aboard the aircraft at all times. 

7. Failure to meet any of the conditions of this exemption immediately cancels the 

authority authorized by this exemption. 
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8. This exemption is not valid for operating outside the United States. 

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

Michael J. Zenkovich 

Deputy Director, Flight Standards Service 

Enclosure 

Exemption No. 11245