P.O. Box 1139

Patterson, Louisiana 70392

(319) 640-1935 ● adam@parkerbennecorp.com ● www.parkerbennecorp.com

January 15, 2015

Re: Petition for exemption of 14 CFR §91.313

To Whom it May Concern:

I am writing on behalf of a client, 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 restricted category for fuel transport. Alaska Air Fuel is a 

“critical business” transporting fuel around Alaska. 

The extent of the exemption to be that Alaska Air Fuel, Inc. be exempt from conforming to the 

regulation that only allows the aircraft to be operated for its intended 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 

conducting the aforementioned training/ check rides/ type ratings in accordance with this 

exemption. 

This exemption would benefit the public as a whole 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 the 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 in aviation. Furthermore, Alaska Air Fuel, Inc. has an 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@parkerbennecorp.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, and 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 keeping 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 category 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