September 29, 2014 

Mr. Everette Rochon 

Acting Manager, Commercial Operations Branch (AFS-820) 

800 Independence Avenue, S.W. 

Washington, DC 20591 

202-385-9629 

Everette. Rochon@faa.gov 

Dear Sir: 

Exemption 10142 amended 

Ammendments Request of Conditions & 

Limitations 

FAA Docket No. FAA-2010-0134 

Thank you for granting our petition to amend Exemption No. 10142 to allow Al's Aerial 

Spraying to use a single-engine turbopropeller-powered Air Tractor aircraft to make 

turnarounds over congested areas in a loaded configuration, subject to listed conditions and 

limitations. This is an amendments request of the conditions and limitations. 

There has been no change in the conditions and reasons relative to public interest and safety 

that were the basis for granting the original exemption. 

This exemption is valid only for operations where the aircraft is dispensing benign substances 

such as pheromones or Bacillus thuringiensis (Bt). 

The requested changes are to conditions numbered 5 and 9 based upon aircraft 

manufacturer's data. To insure that this remains in the best interests of the public, we also 

request that number 6 be modified to require Al's Air Service pilots flying under this exemption 

to have more command and agricultural experience. The current conditions and limitations we 

propose to change are below. The text under consideration is underlined and bold. 

5. The approved CAP (Congested Area Plan) must identify applicable emergency 

landing areas in compliance with § 137.51 (b)(4)(iii). The identified emergency landing 

areas must be located away from congested areas, no more than 1 nautical mile away 

from the point at which turnaround over a congested area will begin. In each CAP, the 

operator must show that at any time during a turnaround over a congested area, the 

airplane could reach an emergency landing area that is not congested in the event of an 

engine failure. 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of§ 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 100 hours of PIC time in single-engine turbopropeller-powered airplanes; and 

500 hours of PIC time dispensing agricultural materials or chemicals. 

9. Each turnaround over a congested area must begin at an indicated airspeed of 140 

mph, at a minimum altitude of 200 feet AGL. 
Al's Aerial Spraying, LLC respectfully requests that Condition and Limitation #5 be changed to 

read as follows: 

5. The approved CAP (Congested Area Plan) must identify applicable emergency 

landing areas in compliance with §137.51(b)(4)(iii). The identified emergency landing 

areas must be located away from congested areas, no more than 1.5 nautical mile away 

from the point at which turnaround over a congested area will begin. In each CAP, the 

operator must show that at any time during a turnaround over a congested area, the 

airplane could reach an emergency landing area that is not congested in the event of an 

engine failure. 

The requested change is from the existing limitation of 1 nautical mile to 1.5 nautical miles. 

This additional half mile aligns this Exemption with the glide data provided by the aircraft 

manufacturer Air Tractor we have included with this request. 

As provided by part §137.51, the Administrator has always allowed single engine helicopters to 

make turnarounds over congested areas in a loaded configuration. 

Helicopters are used in congested areas by Emergency Medical Service (EMS). In the United 

States, between January 2002 and January 2005, there were 41 helicopter EMS accidents, 16 

of which were fatal. The average accident rate increased from 3.53 accidents per 100,000 

flight hours between 1992 and 2001 to 4.56 accidents per 100,000 flight hours between 1997 

and 2001. 

A single engine helicopter is not able to demonstrate positive climb performance capabilities in 

the event of an engine failure. A single engine helicopter flying at 200 feet in agricultural 

spraying operations that experiences an engine failure is going to land on/in whatever the 

helicopter is flying over at the time that the engine failure occurs. There would be no time to 

maneuver and hardly enough time to auto-rotate. 

By contrast, anAl's Aerial Spraying Air Tractor flying at its normal application speed of 140 

knots at 100 feet is going to be able to climb to in excess of 3000 feet agl, make a 90 degree 

turn, and glide 1.55 miles. The Air Tractor is going to land in its emergency landing area. 

Compared to a single engine helicopter allowed by§ 137.51, operation of an Air Tractor in this 

environment is an enormous increase in safety. 

As provided by part§ 137.51, the Administrator has always allowed multi-engine airplanes to 

make turnarounds over congested areas in a loaded configuration. 

In the event of an engine failure, a pilot turning a loaded multi-piston engine aircraft over a 

congested area must: 

Identify the failed engine 

Verify that he has correctly identified it 

Shut down the dead engine and feather the propeller 

Dump the load 

Most of these tasks require the pilot's eyes to be inside the cockpit while flying at a high rate of 

speed very low to the ground. The pilot must do all of these tasks without slowing below the 

single engine minimum control airspeed or descending into the ground. He must do all of this 

simultaneously while looking out the window to avoid colliding with towers or wires. Then this 

pilot, who the FAA requires to only have 100 hours of agricultural application experience and 
25 hours PIC in make & model must fly this heavily modified multi-engine aircraft back to an 

airport on one engine. 

In contrast, to achieve the demonstrated 1.5 nm glide distance anAl's Aerial Spraying, LLC Air 

Tractor pilot must feather the prop, climb while slowing to the best glide speed, and dump the 

load while heading toward the emergency landing area. In comparison to the multi-engine 

airplane, the threat of loss of control substantially smaller. Owing to the excellent Air Tractor 

cockpit design, he is able to keep his eyes outside the aircraft. For a pilot with 2,000 hours of 

agricultural experience and 1,000 hours of single engine turbo-prop time, these are very simple 

tasks. 

Al's Aerial Spraying, LLC respectfully requests that Condition and Limitation #9 be changed to 

read as follows: 

9. Each turnaround over a congested area must begin at an indicated airspeed of 140 

mph, at a minimum altitude of 100 feet AGL. 

The requested change is from 200 feet AGL to 100 feet AGL. The glide data provided by the 

aircraft manufacturer Air Tractor calculated the escape maneuver in the event of an engine 

failure beginning from an altitude of 100 feet above ground level. Again, this aligns this 

exemption with the Air Tractor manufacturer's data provided herein. 

Using 100 foot agl allows the pilot to begin the turn at the end of a pass instead of climbing 100 

feet and waiting for the speed to rebuild to 140 mph. The extra 100 feet altitude currently 

stipulated in #9 does provide additional glide distance. However, the extra 100 feet also 

increases the amount of time that the agricultural airplane spends flying over the congested 

area. 

We request the reduction from 200 to 100 feet agl based upon the information provided herein 

to increase the distance to the emergency landing area from 1 nm to 1.5 nm. Again, this was 

demonstrated by the aircraft manufacturer, Air Tractor. 

In order to insure that our airplanes are flown within the confines of this exemption and 

operated at speeds and altitudes specified by the manufacturer that insure the required 

performance, we propose that the FAA require that this Exemption be flown by pilots with 

much more experience than required in previous versions of this exemption and/or §137.51 . 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of§ 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 1000 hours of PIC time in single-engine turbopropeller-powered airplanes; and 

2000 hours of PIC time dispensing agricultural materials or chemicals. -

The requested change is from 100 hours of PIC time in single-engine turbopropeller-powered 

airplanes to be increased to 1000 hours and 500 hours of PIC time dispensing agricultural 

materials or chemicals to 2000 hours. 

The increase in experience level creating a higher level of safety is emphasized in the recent 

data the National Agricultural Aviation Association (NAAA) has assembled from their review of 

the 2006 - 201 0 accidents. The category "Hours in Type" is very close to the total hours most 
agricultural pilots have in actual dispensing operations. It is clear that at the 2,000 hour 

experience level, the accident rate is significantly less than the 100 hour experience level. 

Rather than foster an equivalent level of safety, this increases Al's Aerial Spraying, LLC's 

safety factor by more than six times. 

Hours in Type Accidents Accidents/1 000 hours 

10,000 - 38,859 21 0.54 

5,000-9,999 49 9.8 

2,500-4,999 49 19.6 

1,000-2,499 73 29.2 

750-999 19 76 

500-749 28 112 

250-499 40 160 

100-249 48 192 

50-99 15 300 

0-49 22 440 

While this matter is under consideration, Al's Aerial Spraying, LLC will continue to operate in 

full accordance with the conditions and limitations provided in Exemption 10142C. 

To summarize, Al's Aerial Spraying, LLC requests Exemption 10142C be amended by the 

modification of three Conditions and Limitations. 

5. The approved CAP must identify applicable emergency landing areas in compliance 

with § 137.51 (b)(4)(iii). The identified emergency landing areas must be located away 

from congested areas, no more than 1.5 nautical miles away from the point at which 

turnaround over a congested area will begin. In each CAP, the operator must show that 

at any time during a turnaround over a congested area, the airplane could reach an 

emergency landing area that is not congested in the event of an engine failure. 

6. Each pilot must hold a commercial pilot certificate and be employed directly by the 

operator. In addition to the requirements of§ 137.53, each pilot must have at least 50 

hours of pilot in command (PIC) time in the designated model Air Tractor airplane to be 

flown; 1000 hours of PIC time in single-engine turbopropeller-powered airplanes; and 

2000 hours of PIC time dispensing agricultural materials or chemicals. 

9. Each turnaround over a congested area must begin at an indicated airspeed of 140 

mph, at a minimum altitude of 100 feet AGL. 

Thank you for your assistance in this matter. 
Michael D. Schiffer 

Mark Kosco 

Acting Manager 

Federal Aviation Administration 

Flight Standards District Office 

PO Box 888879 

3196 Kraft A venue SE, Suite 103 

Grand Rapids, MI 49512 

Mr, Kosco 

AL'S 

AERIAL SPRAYING, LLC 

Spraying - Fertilizing - Seeding 

3473 N. Shepardsville Rd. 

Ovid, Ml 48866 

(989) 834-5067 

Fax (989) 834-5098 

August 29, 2014 

This letter is in response to your request concerning our Exemption to FAR Part 137.51(b)(4)(i) allowing 

turnarounds over a congested area in a single-engine aircraft. Thanks for taking the time to meet with me 

on August 6, 2014. Per our discussion, I was able to do two flight tests on August 27th concerning the 

glide distance of our AT -502B. The results were almost exactly per our discussion. If further information 

or discussion is needed, please contact us. 

Thanks again for your help. 

Sincerely, 

c L 

Michael D. Schiffer 

Michael D. Schiffer 

AL'S 

AERIAL SPRAYING, LLC 

Spraying - Fertilizing - Seeding 

34'73 N. Shepardsville Rd. 

Ovid, Ml 48866 

(989) 834-5067 

Fax (989) 834-5098 
Mark Kosco 

Acting Manager 

Federal Aviation Administration 

Flight Standards District Office 

PO Box 888879 

3196 Kraft A venue SE, Suite 103 

Grand Rapids, MI 49512 

Re: Air Tractor Flight Test Results 

On August 27 I was did two flight tests in our AT502B, N445MS. The two tests were in opposite 

directions to average any wind effects. At 3,000 feet at 140 mph I pulled the power to idle, marked my 

location with our SA TLOC DGPS, began a pull to 90 mph, and feathered the prop. When the Air Tractor 

passed 2,900 feet, a loss of 100 feet, the location was again marked with the SATLOC. Our SATLOC 

DGPS is set to record each second. The distance was measured from the SATOC record. 

Distance Traveled: 

Michael D. Schiffer 

1.416 miles 

1.575 miles 

1.496 miles average