P.O. Box 1139 Patterson, Louisiana 70392 (319) 640

- 1935 ● adam@parkerbennecor p.com ● www.parkerbennecorp.com

January 1 5 , 201 5

Re: Petition for exemption of 14 CFR §91.313

To Whom it May Concern :

I am writing on beha lf of a c lient, Alaska Air Fuel , Inc. to request an exemption from 14

– CFR §91.313(a)(1) and §91.313(c).

Alaska Air Fuel, Inc. operates at least one r estricted c ategory fo r fuel transport

. Alaska Air Fuel is a
“cri tical business” transporting fuel around Alaska.

The extent of the exem ption to be t hat Alaska Air Fuel , Inc. be exempt from conforming to the regulation that only allows the aircraft to be operated for its in te nded purpose. Alaska Air Fuel , Inc. asks to be able to conduct training in restricted category aircraft outside of its intended purpose of fuel transportation

.

Furthermore we ask that the exemption includes that any pilot(s) who fly the aircraft in the capacity listed in this exemption not have any violations imposed on them for doing so.

We also ask that this exemption cover check rides and type ratings in the aircraft. And that the check airmen conducting the training/ check rides/ type ratings be exempt from violations for

conductin g the aforementioned training / check rides/ type ratings in accordance with this exemption.

This exemption would benefit t he public as a whol e because, in many cases, the operations are

critical to the survival and operation of people and businesses around Alaska

. This training also helps the pilot ( s ) to maintain proficiency and competency in the specific aircraft which is ultimately
better for t he public as a whole.

This exemption would not adversely affect safety because it would allow for us to complete training in the aircraft which there are no simulators for. Training has been proven as an effective way of reducing accidents and incidents i n aviatio n. Furthermore , Alaska Air Fuel , Inc. has a n impeccable safety record and systems in

- place to reduce the possibility of an accident or incident in our
aircraft.P.O. Box 1139 Patterson, Louisiana 70392 (319) 640

- 1935 ● adam@parkerbennecor p.com ● www.parkerbennecorp.com

Summary:

We are requesting an exemption of the parts of 14CFR §91.313 that would not allow us to be able to conduct the training that has proven to be effective in our operations. This training helps reduce the risk of an emergency which could potentially harm persons or property if it were not done ; by Training the crewmembers who operate these aircraft to a level of competency so that they are aware of situations which require operator input, an d by operating the aircraft as to exercise them to find any issues they may have so we can correct them immediately and not when the aircraft is working a mission.

Companies and private owners of Restricted Category aircraft have been diligent with keepin g their aircraft in compliance with Federal Regulations. As a whole these operators are making an effort to fly safely, there are several articles published that explain the benefits of training and why it is important for the operations of restricted cate gory aircraft.

This is a time

- critical request for exemption and would be prudent if this was granted as soon as possible.

Best Regards, 

# Adam L. Tjelmeland

Adam L. Tjelmeland

President & CEO Parker Bennecorp (319) 640

- 1935 adam@parkerbennecorp.com