US Department ofTransportation Federal Aviation Administration 1200 New JerseyAvenue SE West Building Ground Floor Room W12-140 Washington, DC 20590 Feb 19, 2016

Croman Corporation- FAA Authorization to use a restricted category S-61Aor SH-3H helicopters fortraining/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 conducttraining and checkflights 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 undera special Airworthiness certificate in the restricted category. Per 14 CFR 91.313 (b), the operator also is granted the abilityto perform training in these missions. These restricted category aircraft have an extensive history with millions ofSafe 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 operatorfor manyyears. 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:

CromanCorp 801 Avenue C •White City, OR97503 • (541) 826-4455 •FAX (541) 826-4730Section 91.313(a) prescribes, in pertinent part, that no person may operate a restricted category civil aircraftfor otherthan the special purpose forwhich it is certificated; or in an operation otherthan one necessaryto accomplish the work activity directly associated with that special purpose. Rationale forexemption: The aircraft, maneuvers and location ofthe requested training and checking are identical to those that have been accomplished by the operator in the past. Performing the same operations underthe oversight ofan FAA DPE/Inspector/PPE in accordance with all provisions of91.313, 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 propertyfor compensation or hire. Further, forthe purpose ofthis section, a special purpose operation involving the carriage of persons or material necessaryto accomplish that operation(s) forthe purpose of providing flight crewmembertraining in a special purpose operation, are not considered to be the carriage of persons or propertyfor compensation or hire. Rationale forexemption: Forthe purpose ofthis section, a special purpose operation involving the carriage ofpersons or material necessaryto accomplish that operation(s) forthe purpose of providing flight crewmembertraining in a special purpose operation, are not considered to be the carriage ofpersons or propertyfor compensation or hire. No additional maneuvers or operations otherthan those already performed by the operatorare to be performed in connection with the requested 61.31 or 61.58 training. Additionally, the location ofthe 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 conducttype rating training and checkflights 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 ofSikorsky Helicopters exemption from §91.313 (a,b) oftitle 14, code of federal regulations (14CFR) to the extent necessaryto allow Sikorskyto conduct part 61 training and checking in a restricted category aircraft.

CromanCo ROI Avenue C •White City, OR97503 • (541) 826-4455 •FAX(541) 826-4730For clarification about this request, please contactthe undersigned at (541) 826-4455, or email bhbeattie@croman.net.
Verytruly yours,



# ;t}~;JIJ~ Brian H. Beattie Groman Corporation

Croman Corp 801 AvenueC • White City, OR97503 • (541) 826-4455 •FAX (541) 826-4730