US Department of Transportation 

Federal Aviation Administration 

1200 New Jersey Avenue 

SE West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Feb 19, 2016 

Croman Corporation- FAA Authorization to use a restricted category S-61A or 

SH-3H helicopters for training/checking for initial types/61.58 checks. 

Reference (a) 14 CFR 91.313 (a,c) 

(b) 14 CFR 61.31 and 61.58 

Croman Corporation requests an exemption from §91.313(a,c) to conduct training and 

check flights as required by §61.31 and 61.58 in a restricted category aircraft. 

Croman Corporation is supporting the United States government in fire suppression 

operations and Emergency Services Responses which require training and check flights 

for our pilots. 

Justification 

Our aircraft are operated under a special Airworthiness certificate in the restricted 

category. Per 14 CFR 91.313 (b), the operator also is granted the ability to perform 

training in these missions. These restricted category aircraft have an extensive history 

with millions of Safe flight hours conducting training and check rides. 

Only recently, the restrictions on the airworthiness certificate and those found in 14 CFR 

91.313 have been interpreted to restrict the aircraft use for type rating training and PIC 

checks. 

Type rating training and PIC checks per 14 CFR 61.31 and 61.58 have been conducted 

by the operator for many years. Croman Corporation holds that such training and 

checking is safe and in accordance with all applicable regulations. Croman Corporation 

requests an exemption to perform type rating training, type rating checks and currency 

checks for pilots. Such training presents no additional risk to the public and is in the 

public interest. 

Croman Corporation requests exemption from the following regulations: 

Croman Corp 

801 Avenue C • White City, OR 97503 • (541) 826-4455 • FAX (541) 826-4730 
Section 91.313(a) prescribes, in pertinent part, that no person may operate a restricted 

category civil aircraft for other than the special purpose for which it is certificated; or in 

an operation other than one necessary to accomplish the work activity directly 

associated with that special purpose. 

Rationale for exemption: The aircraft, maneuvers and location of the requested 

training and checking are identical to those that have been accomplished by the 

operator in the past. Performing the same operations under the oversight of an FAA 

DPE/Inspector/PPE in accordance with all provisions of 91.313, presents no additional 

risk to the public. 

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 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 or property for compensation or hire. 

Rationale for exemption: For the 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 or property for compensation or hire. 

No additional maneuvers or operations other than those already performed by the 

operator are to be performed in connection with the requested 61.31 or 61.58 training. 

Additionally, the location of the requested training is identical to that used by the 

operator. The requested training therefore does not present additional risk to the public 

and is in the public interest. 

Groman Corporation requests an exemption from §91.313(a,c) to conduct type rating 

training and check flights per §61.31 and 61.58 in restricted category aircraft, Sikorsky 

S-61A models N1048Y and N1043T and Groman SH3-H model helicopters N611CK, 

N612CK, and N613CK. These flights pose no additional risk to the public and are in the 

public interest. 

Please see exemption number 10863, regulatory docket number FAA-2013-0476. This 

is an example of Sikorsky Helicopters exemption from §91.313 (a,b) of title 14, code of 

federal regulations (14CFR) to the extent necessary to allow Sikorsky to conduct part 

61 training and checking in a restricted category aircraft. 

Croman Co 

ROI Avenue C • White City, OR 97503 • (541) 826-4455 • FAX (541) 826-4730 
For clarification about this request, please contact the undersigned at (541) 826-4455, 

or email bhbeattie@croman.net. 

Very truly yours, 

;t}~;JIJ~ 

Brian H. Beattie 

Groman Corporation 

Croman Corp 

801 Avenue C • White City, OR 97503 • (541) 826-4455 • FAX (541) 826-4730