20 February 2015

US Department of Transportation

Federal Aviation Administration

1200 New Jersey Avenue

SE West 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 137 Certificate WMWG078J, requests an exemption from

S91.313 (a,b) to conduct pilot check flights as required by $61.31 and 61,58 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 in the United States, aircrew training and

check flights as required by Part 61 are not possible to obtain in aircraft outside the Restricted category.

Aero-Flite supports the United States Forest Service (USFS) for wildfire 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 is vital that our pilots meet certification and currency requirements

in order 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 wildlife conservation. Per

91.313 (b), the operator is also granted the ability to perform training in these missions. The ainrorthiness

certificate inherently grants Aero-Flite the ability to train for and perform check rides to maintain Type

Ratings and Pilot in Command checks in these 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 of the 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 a Waiver of Authorization of 91.313 (e) (1,2,3), which allows for us to operate

Resticted category aircraft in congested areas, airways, and airports.

Type Rating training and PIC checks per 14 CFR 61.31 and 61.58 are conducted by Aero-Flite with our CL415 and RJ-85 aircraft. Aero-Flite holds that such training is safe and in accordance with all applicable

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

PPE observation check rides for our pilots. Such training and testing presents no additional risk to the public

and is in the public's interest so that 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 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

identicalto those that have been accomplished by the operator in the past. Performing the same operations

under the oversight of an FM DPE/lnspector/PPE in accordance with all provisions of 91.313, presents no

additional risk to the public.
Section 91.313(b) prescribes, in pertinent part that 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 by the

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 rides therefore do not present additional risk to the public

and are in the public interest.

Your attention to this matter is appreciated 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 at 661-361-3043, or email mlynn@aerofliteinc.com.

Mike Lynn

Director of Operations

Aero-Flite, lnc.