WIPLINE FLOATS • SKIS • MODIFICATIONS • AIRCRAFT SALES 

AVIONICS • INTERIOR • MAINTENANCE • PAINT REFINISHING 

1700 Henry Ave – Fleming Field (KSGS), South St. Paul, MN 55075 

Ph: 651.451.1205 Fax: 651.457.7858 

www.wipaire.com 

February 12, 2013 

U.S. Department of Transportation 

Docket Operations 

West Building, Ground Floor, Room W12-140 

1200 New Jersey Ave., SE. 

Washington, DC 20590 

On behalf of Wipaire, Inc. I hereby file this petition for exemption pursuant to Title 14, Code of 

Federal Regulations (14 CFR) Section (§)11.61(b). 

Our company name and mailing address is as follows: 

 Wipaire, Inc. 

 1700 Henry Ave. - Fleming Field 

 South St. Paul, MN 55075 

 Telephone: 651-451-1205 

 Contact: Mr. Richard S. Adler, Certification Engineer 

 E-mail: radler@wipaire.com

Wipaire is petitioning for exemption from §§ 23.3(a) and 135.113 of 14 CFR with respect to the 

limitation on seating configuration, less pilot seats, of nine or less. The exemption would permit 

an increase in the maximum number of passenger seats to ten, while maintaining the TC 

approved maximum seats, including crew, of eleven, for Wipaire modified Cessna Caravan and 

Grand Caravan aircraft. An additional exemption is requested to allow for supplemental type 

approval for operations in the 208B Grand Caravan with an eleven to thirteen passenger seating 

configuration (maximum fourteen seats, including crew). 

As required by §§11.81(d) and 11.81(e), it will be shown that the granting of this petition will 

not adversely affect safety, and is in the public interest. Additionally, per §11.81(h), Wipaire 

requests that the privileges of this exemption be extended outside of the United States, as 

operators of aircraft so equipped are located world-wide and these operators’ countries of origin 

often rely on the US approval basis as their own. 

We seek relief for all Cessna Aircraft Company Model 208 Caravan aircraft modified by the 

installation of Wipaire, Inc. STC SA1311GL for Model 8000 or 8750 Straight or Amphibious 

Seaplane Floats. Wipaire also requests that such exemption be applicable to Cessna Model 208B 

Grand Caravan aircraft at such time as they are amended to STC SA1311GL. Approval 

activities are currently underway for the 208B under FAA Project Number SA7716CH-A. 
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Regulatory Background 

On July 7, 1970, the FAA issued Notice No. 70-25 (35 FR 10911) proposing to upgrade the level 

of airworthiness of small airplanes intended for operations under Part 135. This action was based 

upon a stated trend toward an increase in the number and types of airplanes designed to carry 

relatively large numbers of passengers. As stated in the notice and final rule: 

“At the time that the 12,500 pounds weight limitation on small airplanes was established in

1953, civil airplanes were well below or well above that weight. In recent years, it has become

apparent that the significance of that weight limitation as a line of demarcation between Parts

23 and 25 has changed. Many small airplanes with weights of, or close to, 12,500 pounds have

been produced by manufacturers for private, executive, and air taxi use. Some of these

airplanes have turbine engines and must carry large fuel loads to achieve a practical range at

high speeds and altitudes. ... More important, however, is the sudden trend toward an increase

in the number and types of small airplanes designed to carry relatively large numbers of

passengers. The FAA considers that continued applicability of Part 23 to small airplanes designed

to carry 10 or more passengers is no longer in the interest of safety. Future generations of these

small airplanes should adhere to the level of safety afforded by the requirements of Part 25

irrespective of whether operations are conducted under Part 135 or Part 91. ” ([Federal

Register: February 11, 1971 (Volume 36, Number 29)]

[Page 2862 ], Docket No. 10405)   

Amendment 23-10 limiting the number of seats, excluding pilot seats, to nine or less became 

effective March 13, 1971. It is interesting to note that the FAA went on to make it clear that the 

limitation was specific to the number of seats, not necessarily passengers; 

 “In response to several comments, the title of proposed Sec. 23.1583(l) has been changed to

read "Maximum passenger seating configuration" in order to make it clear that the operating

limitation on passenger seats is intended to implement the change to the applicability provisions

of Sec. 23.1. In establishing the seating capacity as a limitation it was not intended to include the

pilot's seat and, in the case of airplanes having dual flight controls, the second pilot's seat.

Furthermore, it was not intended to prevent the present practice of two small children

"doubling up" on a seat or an adult holding an infant.”

Between the issuance of Notice 70-25 and Final Rule for 23-10, the FAA Flight Standards 

Service issued Notice 70-611, proposing to delete §135.53, “Passenger occupancy of pilot seat”. 

This change was specifically intended to allow the operation of small aircraft with ten seats 

occupied by passengers, with one of those seats being the right side pilot seat: 

[14 CFR Part 135]

(Docket No. 10748: Notice 70‐61)

PASSENGER OCCUPANCY PILOT SEAT

Notice of Proposed Rule Making
Page 3 

The Federal Aviation Administration is considering amending Part 135 of the Federal Aviation

Regulations to delete § 135.53 which prohibits a passenger from occupying a pilot seat in an

aircraft with a passenger seating configuration of more than eight. Interested persons are

invited to participate in the making of the proposed rule by submitting such written data, views,

or arguments as they may desire. Communications should identify the regulatory docket or

notice number and be submitted in duplicate to: Federal Aviation Administration, Office of the

General Counsel, Attention: Rules Docket. GrC‐24, 800 Independence Avenue SW., Washington,

DC 20590. All communications received on or before January 29, 1971, will be considered by the

Administrator before taking action on the proposed rule. The proposal contained in this notice

may be changed In the light of comments received. All comments submitted will be available,

both before and after the closing date for comments, in the Rules Docket for examination by

interested persons. The prohibition of § 135.53 that no passenger may occupy a pilot seat in an

aircraft with a passenger seating configuration of greater than eight was based primarily upon

the assumption that a passenger so situated could be a distraction, either intended or

accidental, to the pilot.  However, upon further consideration of this rule in the light of actual

operating experience by certificate holders it appears that it may be unduly restrictive.

Therefore, it is proposed that § 135.53 be deleted.  Deletion of the present rule would permit a

passenger to occupy a pilot seat in airplanes with a seating configuration, excluding any pilot

seat, of less than 10 and thereby allow a maximum of 10 passengers to be carried with but one

pilot.  

PROPOSED RULEMAKING

In consideration of the foregoing, it is proposed to amend Part 135 of the Federal Aviation

Regulations by deleting and reserving § 135.53 "Passenger occupancy of pilot seat."

This amendment is proposed under the authority of sections 313(a) and 601 of the Federal

Aviation Act of 1958 (49 U.S.C. 1354 and 1421) and section 6(c) FEDERAL REGISTER, VOL. 35, NO.

252—WEDNESDAY, DECEMBER 30, 1970 19797 of the Department of Transportation Act (49

U.S.C. 1655(c)).

Issued in Washington, D.C., on December 23, 1970.

Edward C. Hodson,

Acting Director,

Flight Standards Service.

The final rule for amendment of §135.53, released in October, 1971, after the final rule for 

Amendment 23-10, contains revised wording making the carriage of 10 passengers, with one 

passenger occupying the right hand pilot seat, prohibited in aircraft type certificated after 

October 15, 1971: 

PART 135—AIR TAXI OPERATORS

AND COMMERCIAL OPERATORS OF

SMALL AIRCRAFT

Passenger Occupancy of Pilot Seat
Page 4 

The purpose of this amendment to § 135.53 of the Federal Aviation Regulations is to permit a

passenger to occupy a pilot seat in an aircraft type certificated prior to the effective date of the

amendment with a passenger seating configuration greater than eight. This amendment is

based on a notice of proposed rulemaking (Notice 70‐51) published in the Federal Register on

December 20, 1970 (35 F R, 19796). Twenty‐six comments were received in response to the

notice. It is the position of the FAA that with respect to aircraft currently used in Part 135

operations a prohibition against passengers occupying a pilot seat is unduly restrictive inasmuch

as the rationale therefor, namely, that a passenger could intentionally or inadvertently interfere

with the pilot, does not appear to be supported by actual operating experience. The comments

indicated that the position taken by the FAA in this regard is correct. However, based on the

comments received and further FAA study, we believe that the prohibition against passenger

occupancy of a pilot seat in the subject aircraft should be retained with respect to aircraft type

certificated after the effective date of the amendment.  In the absence of operating experience

to indicate otherwise, we believe that occupancy of a pilot seat by a passenger may be unsafe

with respect to newer and more sophisticated aircraft. In light of the above, the amendment

adopted herein differs from the proposals in the notice to the extent that the prohibition

against passenger occupancy of a pilot seat in an aircraft with a passenger seating configuration

greater than eight is continued in force with respect to aircraft type certificated after the

effective date of the amendment, but is made inapplicable to those type certificated before that

date. It should be noted that § 135.53 applies only to an 11 ‐seat configuration (including the

pilot seats); aircraft with fewer seats have always been permitted to carry passengers in the

pilot seat and have done so safely. For aircraft with a greater number of seats. § 135.52 requires

them to be operated with two pilots thus making the pilot seat unavailable to passengers.

Interested persons have been afforded an opportunity to participate in the making of this

amendment, and due consideration has been given to all relevant matter presented. Since this

amendment is relaxatory, I find that good cause exists for making it effective on less than 30

days' notice. In consideration of the foregoing, §135.53 of the Federal Aviation Regulations is

amended, effective October 15, 1971, to read as follows:

§ 135.53 Passenger occupancy of pilot seat.   

No certificate holder may operate an aircraft type certificated after October 15, 1971, that has a

passenger seating configuration, excluding any pilot seat, for more than eight passengers if any

person other than the pilot in command, a second in command pilot, a company check airman,

or an authorized representative of the Administrator, the National Transportation Safety Board,

or the Post Office Department occupies a pilot seat.

§§ 313(a), 601, Federal Aviation Act of 1958 49 U.S.C. 1354( a), 1421; sec. 6(c), Department of

Transportation Act, 49 U.S.C. 1655(c).

Issued In Washington, DC., on October 5,1971.

J. H.Shaffer, Administrator.
Page 5 

The reason given for the change, “In the absence of operating experience to indicate otherwise, we

believe that occupancy of a pilot seat by a passenger may be unsafe with respect to newer and more

sophisticated aircraft.”, seems somewhat contrived, as it would appear more likely that the 

originally proposed operating rule change would now have been in conflict with Amendment 23-

10. 

Subsequent to Amendment 23-10, the FAA attempted to prohibit the use of small aircraft with 

ten or more passenger seats in Part 135 operations:

On August 29, 1977, the FAA issued Notice No. 77‐17, (42 FR 43490) Part 135 Regulatory Review

Program, proposing, in part, to prohibit the operation, after certain dates, of reciprocating

engine or turbopropeller‐powered small airplanes not certificated in the transport category and

having a passenger seating configuration of ten or more seats. Before the closing date for

comments on November 28, 1977, the FAA withdrew this part of the proposal in Notice No. 77‐

17. The more significant reasons given for the withdrawal are (1) Comments on this proposal

showed its effect would virtually destroy the commuter airline industry and deprive the general

public of needed transportation; (2) the proposal had already disastrously effected the industry;

(3) airplane sales had been canceled and operators had serious difficulty with financing; and (4)

the cost of complying with the proposal would exceed 300 million dollars for an industry whose

total profits did not exceed 50 million dollars a year.

The withdrawal of this proposal showed recognition on the part of the FAA of the need, in the 

public interest, for means to provide certain types of air transportation using aircraft not 

certificated in the transport category. It also exposed the error of earlier thinking that “In any

event, the recent rapid increase in the number of small airplanes carrying 10 or more passengers

emphasizes the need for a single level of airworthiness for airplanes carrying 10 or more passengers.”.  

As a result, through SFAR 41, and later with the addition of the commuter category, the FAA 

adopted airworthiness standards for aircraft up to 19 passenger seats under FAR 23 at 

Amendment 34. Unfortunately, single engine aircraft were intentionally excluded from 

certification in the commuter category, as stated in the final rule and disposition of comments:

Another commenter recommends that Sec. 23.3(d) be changed to add single‐engine,

turbopropeller‐powered airplanes to the commuter category. The FAA does not agree with the

inclusion of single‐engine, turbopropeller‐powered airplanes within the commuter category.

While the commenter contends that turbopropeller engines have a record of increased

reliability over reciprocating engines, the prospect of a single‐engine failure does not provide

the level of safety expected from the airworthiness standards for commuter category airplanes

which must have the ability for continued safe flight and landing after probable failures,

including the failure of an engine.  [Federal Register: January 15, 1987 (Volume 52, Number

10)][Page ‐ 1806]

As such, a single engine, turbopropeller aircraft cannot be type certificated in the commuter 

category, it cannot be type certificated in the transport category, nor can it be type certificated in 

the normal category with allowance for a passenger seating configuration greater than nine. 

There is, however, precedent for allowing the operation of aircraft type certificated prior to FAR 
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23 Amendment 10 with more than nine passengers, specifically the DHC-3 Otter, which was 

type certificated under CAR 3 for up to 16 occupants, including crew. From the final rule 

addressing ‘Commuter Operations and General Certification and Operations Requirements’: 

Alaskan Comments:

A part of the proposal that would have affected several Alaskan certificate holders is the

proposal that single engine airplanes with 10 passenger seats now operating scheduled

flights under part 135 would in effect have to remove a seat in order to continue

operating in

scheduled service under part 135.  Single‐engine airplanes are ineligible for operation

under part 121. The only 10‐ seat single‐engine airplane model involved is the single‐

engine deHaviland DHC–3 Otter (not to be confused with the twin‐engine de Haviland

DHC–6 Twin Otter mentioned 65840 Federal Register / Vol. 60, No. 244 / Wednesday,

December 20, 1995 / Rules and Regulations elsewhere in this notice). According to

AACA and other commenters, there is no possible safety benefit in taking a seat out of

an airplane, but the cost to certificate holders who want to continue to use these

airplanes in scheduled operations will be significant. NATA comments that no accident

involving the Otter would have been prevented by limiting the seating to 9 passengers.

Furthermore, according to the commenter, the FAA cost on this issue is another

example of gross underestimation; actual costs will be 15 times higher (almost $22,000

per aircraft). The City and Bureau of Juneau opposes the proposal to remove a seat from

the 10‐seat airplanes so that they can operate under part 135. This commenter notes

that there will be additional flights, additional noise, and additional congestion on the

water and in the air. It notes that it is incomprehensible how the reduction of one seat

from the Otter will provide an additional level of safety. Wings of Alaska comments that

the most cost efficient floatplane used in southeast Alaska is the single‐engine DHC–3

Otter. Because there is no cost‐effective replacement aircraft available for float

operations that offers the same capacity as the Otter, replacing them is not an option.

Wings states that it operates the Otter about 6 months a year. Four communities that

do not have runways receive daily service. Wings purchased five 10‐seat Otters in ’92–

93 to improve service to a wilderness sports facility, substantially reducing noise by

reducing the number of flights by 50%. Wings estimates that the removal of one seat

would have cost them $85,000 in 1994. Wings asks that the Cessna Caravan and the

Cessna Grand Caravan also be allowed to operate with 10 seats. (emphasis added)

AACA comments that Ketchikan Air Service, Taquan Air Service, and Wings of Alaska

together operate 12 Otters in southeastern Alaska.

............

In response to the single‐engine airplane issue, the FAA has decided to allow an

exception to continue. Currently, several part 135 certificate holders conduct scheduled

passenger carrying operations in single‐engine airplanes type certificated with two pilot

seats in the ‘‘cockpit’’ and 9 passenger seats in the ‘‘cabin.’’ Some certificate holders are

authorized to conduct scheduled operations in that airplane, the DHC–3 Otter, under

daytime VFR, and carry a tenth passenger in the right‐hand pilot seat. In Notice 95–5,

the FAA proposed to limit all scheduled operations of single engine airplanes to the

carriage of nine passengers, under all conditions. (60 FR 16235, 16273) The FAA has

decided to allow the current practice to continue for operators who currently conduct

single‐engine operations under daytime VFR with a tenth passenger.  
Page 7 

...........

5. Part 119

Single‐Engine Airplanes. Several commenters state that the NPRM cost estimates for not

allowing a passenger to sit in the co‐pilot seat on a single‐engine Otter are understated.

One commenter states that the data the FAA used was based on national averages while

all of the airplanes in question are located in Alaska. The commenters also state that the

load factors and operating costs in Alaska are much higher than the rest of the country.

FAA Response: The FAA agrees with the commenters and will not prohibit qualified (as

prescribed by § 135.113) single‐engine airplanes, namely single engine Otters, from carrying a

revenue passenger in the copilot seat.

(65832 Federal Register / Vol. 60, No. 244 / Wednesday, December 20, 1995)

These statements support the FAA’s concurrence that operations of single engine aircraft with 

accommodations for more than nine passenger seats are economically necessary, in the public 

interest, and provide an acceptable level of safety. When §135.113 (previously 135.53 and 

135.101) was created, the stated purpose was increased safety, and yet only aircraft certified

to earlier airworthiness rules are allowed to operate with a tenth passenger seat,

thus encouraging the continued operation of high time aircraft in lieu of newer, low

time aircraft certified to modern rules. The current rule effectively already provides a 

§135.113 exemption identical to Wipaire’s petition with the exception that it only provides this 

exemption to older aircraft certified to earlier rules. 

Exemption is in the Public Interest 

Granting this exemption would benefit the public in a number of ways: 

 Increased utility - Because of the utility nature of the aircraft, it has served international 

relief and humanitarian efforts throughout the world. With the Wipaire seaplane or 

amphibian float installation the utility of the aircraft is greatly expanded, serving many 

communities otherwise inaccessible by air transportation. The Wipaire amphibian 

configured aircraft provides additional remote access in support of humanitarian relief, 

water rescue, and emergency medical evacuation. Allowance for additional passenger 

seats further enhances this utility, encourages operators to upgrade to newer equipment, 

and in some cases provides for economic viability of remote routes that would otherwise 

not receive service. 

 Positive Environmental Impact – As stated by commenters ( including The City and 

Bureau of Juneau) responding to Notice 95-5, additional passengers amounts to an 

increase in capacity and associated potential reduction in number of flights, resulting in 

less noise and less fuel consumed. Also, as compared to the Turbine DHC-3 Otter, the 

Caravan and Grand Caravan provide approximately 35% greater cruise speeds on similar 

fuel flow, further reducing fuel consumption and noise footprint. 

 Increased safety – Operators upgrading from the DHC-3 or adding the Caravan/Grand 

Caravan to existing DHC-3 fleets will be operating an aircraft that is not only newer and 
Page 8 

lower time, but certified to safer, more modern regulations. Rule changes specific to 

passenger safety include shoulder harnesses, flame resistant materials, and larger exit 

door requirements, as well as increased seat crashworthiness. 

 Positive Economic Impact – While difficult to substantiate in specific numbers, 

comments submitted to the referenced rulemaking actions indicate that existing operators 

have specific interest in operating Wipaire modified Caravans in addition to, or in lieu of, 

DHC-3 aircraft. As Wipaire, a ‘Made in USA’ manufacturer, is the exclusive worldwide 

manufacturer of float modifications for the Caravan/Grand Caravan, any sales would 

have a positive impact on the United States economy and international sales would have 

an additional positive impact on balance of trade. Additionally, any associated sales of 

Cessna Caravan series aircraft would have a similar positive economic impact. 

Appendix A provides a letter from a current 208 Caravan floatplane operator in support of this 

petition and the benefits to the public as stated above. 

No Adverse Effect on Safety 

 

Safety is not adversely affected because the aircraft is already approved, on the Type Certificate 

Data Sheet (TCDS), for the specific seating configuration being requested in this petition. 

Additionally, the 10th passenger seat, described as the right front seat in the FAA Approved 

Airplane Flight Manual (AFM), is already approved for passenger use. The passenger seating 

configuration required by §§23.1524 and 23.1583(j) for the 11-place/10 passenger seat 

configuration is already included in the AFM, as is the loading information required by 

§23.1589(b). The only alteration necessary to the approved data is relief from the limitation on 

occupation of only eight seats aft when the right front seat is occupied by a passenger. Copies of 

the TCDS and applicable pages from the AFM, along with a copy of Wipaire STC SA1311GL, 

are attached as Appendix B of this petition. 

For the 11 to 14 seat (including crew) additional configuration, applicable to the Cessna 208B 

models, an optional seating configuration is already available from Cessna and is currently 

approved for use in New Zealand, Australia, South Africa, Norway, Sweden, Kenya, Israel, 

Columbia, and is approved on the EASA issued Caravan TCDS for use by the 31 EASA 

Member States for up to 14 seats. As above, an approved AFM supplement, providing 

compliance with the passenger seating configuration required by §§23.1524 and 23.1583(j), and 

the loading information required by §23.1589(b), is available for the requested configuration as 

Cessna P/N 108BPHBUS-S16-02. Similar to the above, the only alterations necessary to the 

approved data are relief from the limitation on occupation of only eight seats aft when the right 

front seat is occupied by a passenger, and FAA approval of the S16 AFM supplement for up to 

14 seats (including pilot). Additionally, the 208B meets the commuter category emergency exit 

requirements of 23.807, and Wipaire is willing to provide an evacuation demonstration in 

compliance with the commuter category requirements of 23.803(a). Copies of EASA TCDS 

IM.A.226, Issue 5, and International AFMS Cessna P/N 108BPHBUS-S16-02 for fourteen place 

seating, along with applicable pages from the Cessna Grand Caravan optional equipment 

selection guide, are attached as Appendix C of this petition. 
Page 9 

Summary 

The current part 23 rules provide for increased levels of certitude based on weight and passenger 

seat limits. Early part 23 rulemaking implies that these limits were expected to be in close 

proximity to one another, i.e. an aircraft that could carry 10 or more passengers would likely be 

multiengine and in excess of 12,500 lbs. and therefore subject to transport category rules. The 

FAA has subsequently acknowledged that technology has altered these assumptions, and also 

acknowledged that some of these current generation aircraft need not be subject to the full level 

of certitude offered by the transport category in order to provide acceptable levels of safety, most 

notably with the advent of the commuter category. 

The Wipaire modified Cessna Caravan has fallen into a void in the current certification and 

operations rules, being single engine, significantly less than 12,500 lbs., and capable of ten place 

(or more) passenger seating configurations. Past rulemaking has discussed safety of turbine 

powered aircraft in relation to ‘high and fast’ performance, and this same performance and 

complexity model is the basis for current part 23 rulemaking efforts. The Wipaire modified 

Cessna Caravan is not a complex, ‘high and fast’ aircraft, it is a utility aircraft capable of 

providing humanitarian service and service to remote areas that would not otherwise be served. 

The aircraft is already FAA TC Approved for a seating configuration supporting ten passenger 

seats, and TC approved by EASA and other international airworthiness authorities for a seating 

configuration supporting eleven (or more) passenger seats. 

There is significant benefit to the United States and no detriment to safety by the granting of this 

petition. 

Federal Register Summary 

To comply with FAR 11.81(f) the following information provides a summary for Federal 

Register publication. 

Petitioner: Wipaire, Inc. 

Sections of 14 CFR Affected: 14 CFR 23.3(a), 135.113. 

Description of Relief Sought: Wipaire is petitioning for exemption from §§ 23.3(a) and 

135.113 of 14 CFR with respect to the limitation on seating configuration, less pilot seats, of 

nine or less. The exemption would permit an increase in the maximum number of passenger 

seats to ten, while maintaining the TC approved maximum seats, including crew, of eleven, for 

Wipaire modified Cessna Caravan and Grand Caravan aircraft. For Grand Caravan aircraft, an 

additional approved configuration would permit an increase in the number of passenger seats to 

eleven or more (up to thirteen) based on current international approvals. The exemption is in the 

public interest because it expands the utility capabilities of the aircraft, which include 

international humanitarian relief efforts, water rescue, emergency medical evacuation, 

transportation services to remote areas not otherwise accessible, and Government operated public 

service missions. Safety is not adversely affected because the aircraft is already approved, on the 

Type Certificate Data Sheet (TCDS), for the specific ten passenger seating configuration being 
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requested, and TC approved by EASA and others for a seating configuration supporting eleven 

(or more) passenger seats. 

Sincerely,

Richard S. Adler 

Wipaire, Inc. 

Certification Engineer 

DER Flight Analyst/Acoustics 

Cc: Mr. Greg Michalik, FAA Chicago ACO.
Page 11 

Appendix A – Seair Seaplanes Supporting Letter 
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Appendix B – Cessna Caravan TCDS and AFM Information 
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Appendix C – Cessna Caravan EASA TCDS, International AFMS, and Optional 

Equipment Information 
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