AFS-15-390-E 

April 24, 2015 

 Exemption No. 11383 

 Regulatory Docket No. FAA-2015-0127 

Mr. Matt Van Pelt 

CHI Aviation 

3679 Bowen Road 

Howell, Michigan 48855 

Dear Mr. Van Pelt: 

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 16, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Construction Helicopters, Inc. DBA CHI Aviation (CHI) for an exemption from 

§§ 91.313(a) and (b) of Title 14, Code of Federal Regulations (14 CFR) to the extent 

necessary to allow CHI to conduct operations needed to satisfy crewmember training, type 

rating requirements, and proficiency requirements found in part 61 in the CH-47D series 

restricted category aircraft. 

Although the petition requests relief from § 91.313(b), the FAA does not believe that an 

exemption from that provision is necessary. This provision allows an operator to consider 

training for the special purpose operation for which the aircraft is certificated to be an 

operation for that special purpose. Since CHI will not be conducting training directly related 

to the special purpose under this exemption, relief from § 91.313(b) is not required. 

Further, and although not specifically requested, the FAA believes that relief from § 91.313(c) 

will be necessary in order for the petitioner to conduct operations described in its request. 

Therefore, the FAA is construing the petition as a request for relief from § 91.313(c). 
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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 CHI. 

The FAA contacted CHI on March 20, 2015, to clarify who owns the aircraft that CHI would 

operate under the requested relief. CHI responded via email the same day and noted that the 

aircraft to be used under the exemption are owned by CHI. A record of conversation that 

captures this information was 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 Construction Helicopters, Inc., DBA CHI 

Aviation (CHI) an exemption from 14 CFR §§ 91.313(a) and (c) to the extent necessary to 

allow CHI to conduct operations needed to satisfy crewmember training, type rating 

requirements, and proficiency requirements found in part 61 in the CH-47D series restricted 

category 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. CH-47D: N947CH, N948CH and N949CH 

2. CHI 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. 
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4. CHI 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 CHI, 

b. Flight training for pilots employed by CHI 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 helicopters, FAA-S-8081-20 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 April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John Barbagallo 

Acting Deputy Director, Flight Standards Service 

Enclosure 

Exemption No. 11245