20 February 2015

US 

### Department of

### Transportation Federal

### Aviation Administration 1200 New Jersey Avenue SEWest Building Ground Floor Room W12-140 Washington, DC 20590



### Aero-Flite lnc.

## - FAA

### Authori?fltion 

### to use 

### Restricted catesorv CL-415 

### and 

### RJ45 for Tvpe Rating 

## ind PPE,Obsprvation .check 

### rides 

## Reference (a) 14 CFR 91.313 (a, b)



### (b) 14 CFR 61.31 and 61.58 (c) 14 CFR 21.25 Flight Standards Board (FSB) Reports CL-a15, 1998

Aero-Flite lncorporated, holder of Part 137Certificate WMWG078J, requests an exemption from S91.313 (a,b)to conduct pilot check flights as required by $61.31 and61,58 in a Restricted category aircraft. Specifically, 

### we request authorization to use our Bombardier CL-415, and BAe RJ85 aircraft to complete Type Rating check rides and Pilot Proficiency Examiner (PPE) annual observation check rides required by 561.31 and 61.58.

With the limited number of CL-415 and RJ85 aircraft operating inthe United States, aircrew training and check flights as required by Part 61 are not possible to obtain inaircraft outside the Restricted category. Aero-Flite supports the United States Forest Service (USFS) forwildfire suppression throughout the lower 48 states and

### Alaska. ln addition to our 

## FM mandated check rides, we are 

### also required 

### to perform annual pilot check flights to

### satisff the 

### USFS. lt isvital that our pilots meet certification and currency requirements inorder to meet USFS pilot inspection flights beginning 

### March 12b,20'15.


### Justification

Our CL-415 and RJ85 aircraft are operated under a 

### SpecialAinrorthiness certificate in

### the Restricted 

### category. Per 14 CFR 21.25(b), the aircraft are authorized to

### fly: (2) Forest and

### wildlifeconservation. Per 91.313 (b), the operator isalso granted the ability

### to perform training inthese 

### missions. The 

### ainrorthiness certificate inherently grants Aero-Flite the ability totrain for and perform check rides

### to maintain Type Ratings and Pilot in Command checks inthese type of aircraft (per 14 CFR 61.31 and 

### 61.58).The 1998 Flight Standards Board Report for the CL-415 specifically addresses 

## 'FM training, checking, and 

### cunency requirements" for crews ofthe 

### CL-415. The FSB report gives guidance on requirements, and special emphasis items

### for Pilot lnspectors when conducting Type Ratings and Pilot Proliciency 

### Exams. Aero-Flite has also been granted aWaiver ofAuthorization of 91.313 (e) (1,2,3), which allows 

### for usto operate 

### Resticted category aircraft in congested areas, airways, and airports.
Type Rating training and PICchecks 

### per 14 CFR 61.31 and 61.58 areconducted byAero-Flite with our CL415 and RJ-85 

### aircraft. Aero-Flite holds that such training issafe and inaccordance with allapplicable 

### regulations. Aero-Flite requests an exemption to use our aircrafi to conduct Type Rating check rides and PPEobservation check rides for our 

### pilots. Such training and testing presents no additional risktothe public and is in

### the public's interest sothat

### we may be available for wildfire suppression operations for

### the USFS.

Aero-Flite 

### lnc. requests exemption trom the following regulations:



### Section 91.3f 3(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 inan 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 

### identicalto those that have been accomplished bythe operator inthe past. Performing the same operations under the oversight ofan 

## FM DPE/lnspector/PPE inaccordance with all provisions of 91.313, presents no additional risktothe public.

### Section 91.313(b) prescribes, in pertinent partthat operating a restricted category civil aircraft to provide

flight crewmember training in a special purpose operation for which the aircraft is certificated is considered to be an operation for that special purpose.



### Rationale 

### for exemption: No additional maneuvers or operations other than 

### those already performed bythe operator are

### to be performed in connection with the requested 61.31 or 61.58

### training. The requested Type Rating check rides and PPE observation check ridestherefore do not present additional riskto

### the public and are inthe public interest.

Your attention tothis matter isappreciated and necessary for Aero-Flite 

### to meet contractual obligations to 

### the USFS, and

### to be available for emergency wildfire 

### suppression. For clarification about this request, please contact the undersigned at661-361-3043, or email mlynn@aerofliteinc.com.

Mike Lynn Director of Operations Aero-Flite, lnc.