6309 Jellison Road

Billings, MT 59101

406-252-6937

Website: billingsflyingservice.com

To whom it may concern:

This letter supersedes request letter dated 8-11-2016 and adds additional justification to our amendment 

extension. This letter also incorporates additional information to justify the same level of safety and is in the 

best of the public.

BFS has been issued Exemption No. 11180, that exemption expires on February, 28 2017. In the process of 

extending this exemption I would like to remove the limitation of only allowing training in specific “N”

numbers and adding UH-60 Black hawk as an approved type.

Justification for removal of specific “N” number aircraft.

BFS operates multiple restricted category aircraft. We have USFS contracts that many of the aircraft 

are committed to. Also, these aircraft required extensive maintenance throughout the calendar year

which renders them non-flyable. Removing this limitation will allow more flexibility to our operation. 

Equivalent level of safety:

 BFS will remain in full operational control of the aircraft

 Limit it to the aircraft listed on our 133 or 137 operating specifications if “N” 

number is required.

 The FAA determined a sufficient level of safety was met with the current

exemption limitations and removing the “N” numbers will not detract from the 

current level of safety as all aircraft go through the same process of becoming 

airworthy.

Best interest of the public:

BFS aircraft are used for fire suppression. This will allow us the flexibility to train our pilots in any of 

our aircraft.

 Uninterrupted service to our fire suppression contracts that benefit the public.

 Allow us to have aircraft for training when others are down for maintenance.

Justification for addition of UH-60:

BFS now owns type certificate number R00021LA. BFS has the same training requirements for this 

aircraft as we require for the CH-47D.

Equivalent level of safety:

 BFS will use the same process of obtaining airworthiness for the UH-60 as we have 

on the CH-47D. 

 BFS will remain in full operational control of the aircraft.

 BFS will use training pilots that hold a type rating appropriate for the aircraft. 

 BFS will use the same training process we used for the CH-47D.
Best interest of the public:

 The FAA believes that the fire suppression operations conducted by Billings Flying 

Service are a benefit to the public. Since these operations cannot be conducted 

without appropriately trained and certificated pilots, the FAA finds that Billings 

Flying Service request for exemption would also be in the public interest. The FAA 

also believes that safety is enhanced by enabling the conduct of a practical test to 

add a type rating, as well as the training in preparation for that practical test, in the 

aircraft or aircraft type that will be operated by the pilot during the special purpose 

operation

Billings Flying Service, Inc. Purposed conditions and limitation:

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

a. UH-60

b. CH-47D

2. Billings Flying Service 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. 5.

4. All routes and locations used during any operation conducted under this exemption must be 

accepted by the CHDO in the geographic region where the aircraft is to be operated.

5. Billings Flying Service 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)

b. Proficiency training for pilots 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 with an Aviation Safety Inspector onboard 

for the purpose of designating or observing a Designated Pilot Examiner 

(DPE).

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

operating limitations, and procedures must be completed and provided to the CHDO 

reflecting the capability of the aircraft to perform all required procedures and maneuvers 

necessary to meet the training, practical tests, and proficiency check requirements in part 61.

7. No person may operate an aircraft under the relief of this exemption at a weight greater than 

the weight that, with the critical engine inoperative, would permit a rate of climb of at least 

50 feet per minute at an altitude of at least 1,000 feet above the elevation of the highest 

ground or obstruction within the area to be operated or at an altitude of 5,000 feet, 

whichever is higher.

8. The UH-60 aircraft listed in Condition/Limitation No. 1 (a) must be serviced and 

maintained in accordance with the approved Type Certificate Data Sheet.

9. The CH-47D aircraft listed in Condition/Limitation No. 1 (b) must be serviced and 

maintained in accordance with the approved Type Certificate Data Sheet.

10. A copy of this exemption must be provided to the CHDO in the geographic region where 

the aircraft is based and must be carried aboard the aircraft at all times.

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

authorized by this exemption.

Please feel free to contact me with any questions or comments.

Regards,

Jeff Cook