AFS-13-150-E

May 29, 2013

 Exemption No. 9844B

 Regulatory Docket No. FAA-2004-17207

Mr. Gregory J. Moreland

Thrush Aircraft, Inc.

P.O. Box 3149

300 Old Pretoria Road

Albany, GA 31217

Dear Mr. Moreland:

This letter is to inform you that we have granted your petition to extend Exemption No. 9844. 

It explains the basis for our decision, describes its effect, and lists the conditions and 

limitations.

The Basis for Our Decision

By letter dated November 30, 2012, but posted to docket on January 7, 2013, you petitioned 

the Federal Aviation Administration (FAA) on behalf of Thrush Aircraft, Inc. (TAI), for an 

extension of Exemption No. 9844. That exemption from § 61.31(a)(1) of Title 14, Code of 

Federal Regulations allows TAI pilots to operate as pilot in command (PIC) without holding a 

type rating when operating Thrush Model S2R-T660 aircraft that have a maximum gross 

weight that exceeds 12,500 pounds.

 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

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

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to TAI.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 9844 

remains valid with respect to this exemption and is in the public interest. The FAA has also
2 made some amendments to the conditions and limitations of Exemption No. 9844 that clarify 

our original intent and to refine our requirements. Specifically:

1. Condition/Limitation No. 2 is amended to clarify the requirements for TAI’s training 

manual contents.

2. Condition/Limitation No. 4 is added to standardize this exemption with similar 

exemptions to allow a pilot to act as PIC of the S2R-T660 without completing the 

training requirements of Condition No. 3 if that pilot meets minimum experience

criteria. 

3. Condition/Limitation No. 6 (former Condition/Limitation No. 5) is amended by adding 

the minimum qualifications for a person to conduct TAI familiarization ground 

training for the S2R-T660 and to standardize this exemption with similar exemptions.

While the relief does not change substantially, all users of the exemption should thoroughly 

review the revised conditions and limitations. In addition, we advise the petitioner that a 

S2R-T660 training manual, required by condition/limitation No. 2, must be submitted for any 

future requests to extend Exemption No. 9844.

Under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I grant your petition, subject to the following conditions and limitations.

Conditions and Limitations

1. This exemption applies to pilots operating S2R-T660 aircraft that hold a restricted 

category airworthiness certificate for operations involving agricultural, forest 

protection, and narcotic crop eradication flight operations.

2. TAI must develop and maintain a training manual that includes aeronautical 

knowledge training on the S2R-T660 aircraft systems, performance, handling 

characteristics. This training manual must include characteristics that are unique to 

S2R-T660 aircraft that are operated above 12,500 pounds. 

3. Except as provided in condition/limitation No. 4, before a pilot can serve as PIC in the 

S2R-T660 that pilot must have successfully completed familiarization ground training 

for the S2R-T660 that includes a review of the approved aircraft flight manual and 

cockpit familiarization checkout. This checkout must include ground training on the 

aircraft’s systems, performance, and handling characteristic of the S2R-T660. 

4. Pilots who have logged at least 100 hours of flight time, with at least 10 hours in the 

preceding 12 months, in a TAI S2R-T660 need not complete the training requirements 

of Condition No. 3. A record of this flight time must be made available by the pilot 

upon request by the Administrator. 

5. TAI must—
3 a. Ensure each pilot logs the ground training in his or her logbook, or TAI must 

record such training in the pilot's training record; and

b. Make this record of training available for review to the local Flight Standards 

District Office upon request.

6. The person qualified to give training under this exemption must meet the following 

minimum qualifications:

a. Be authorized by TAI to give this instruction;

b. Hold at least a commercial pilot certificate; and

c. Meet the following experience requirements:

i. 500 hours of flight time in turbine-powered agricultural type airplanes; 

or

ii. 1000 hours of flight time in agricultural type airplanes which includes 

at least 100 hours of flight time in a S2R-T660. 

7. TAI must make a copy of this exemption available to each pilot who serves as PIC in 

the S2R-T660.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 9844 to November 30, 2013,

unless sooner superseded or rescinded. 

Sincerely,

/s/

John M. Allen

Director, Flight Standards Service