20 February 2015 US Department of Transportation Federal Aviation Administration 1200 New Jersey Avenue

SE West Building Ground Floor Room W12-140Washington, DC 20590 Aero-Fiite Inc.- FAA Authorization to use Restricted category CL-415 and RJ-85 for Type Rating and PPE Observation 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-415, 1998 Aero-Fiite Incorporated, holder of Part 137 Certificate WMWG078J, requests an exemption from

§91.313 (a,b)to conduct pilot check flights as required by §61.31 and 61.58 ina 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 §61.31 and 61.58.

With the limited number of CL-415 and RJ85 aircraft operating inthe United States, aircrew training and check flights as required by Part 61 are not possible to obtain in aircraft outside the Restricted category. Aero-Fiite supports the United States Forest Service (USFS) for wildfire suppression throughout the lower 48 states and Alaska. In addition toour FAA mandated check rides, we are also required to perform annual

pilot check flights to satisfy the USFS. Itis vital that our pilots meet certification and currency requirements in order to meet USFS pilot inspection flights beginning March 121h, 2015. JustificationOur CL-415 and RJ85 aircraft are operated under a Special Airworthiness certificate inthe Restricted category. Per 14 CFR 21.25(b), the aircraft are authorized tofly: (2) Forest and wildlife conservation. Per

91.313 (b), the operator is also granted the ability to perform training in these missions. The airworthiness certificate inherently grants Aero-Fiite 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 "FAA training, checking, and currency requirements" for crews ofthe CL-415. The FSB report gives guidance on requirements, and special emphasis items for Pilot Inspectors when conducting Type Ratings and Pilot Proficiency Exams. Aero-Fiite has also been granted a Waiver of Authorization of 91.313 (e) (1,2,3), which allows forusto operate Restricted 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-Fiite with our CL415 and RJ-85 aircraft. Aero-Fiite holds that such training is safe andin accordance with all applicable regulations. Aero-Fiite requests an exemption to use our aircraft to conduct Type Rating check rides and PPE observation check rides for our pilots. Such training and testing presents no additional risktothe public andisinthe public's interest so that we may be available for wildfire suppression operations for the USFS. Aero-Fiite Inc. requests exemption from the following regulations:

Section 91.313(a) prescribes, in pertinent part, that no person may operate a restricted category civil aircraft for other than the special purpose for which itis certificated, orinan operation other than one necessary to accomplish the work activity directly associated with that special purpose.

Rationale for exemption: The aircraft, maneuvers and location ofthe requested training and checking are

identical to those that have been accomplished bythe operator inthe past. Performing the same operations under the oversight ofan FAA DPE/Inspector/PPE in accordance with all provisions of 91.313, presents no additional risktothe public.... / Section 91.313(b) prescribes ,in pertinent part that operating a restricted category civil aircraft to provide flight crewmember trainingina special purpose operation for which the aircraft is certificated is considered to bean operation for that special purpose . Rationale for exemption: No additional maneuvers or operations other than those already performed by the

operator are tobe performed in connection with the requested 61.31or 61.58 training .Ther equested Type

Rating check rides and PPE observation check rides therefore do not present addi tional risk tothe public and areinthe public interest. Your attention to this matter is appreciated and necessary for Aero-Fiite to meet contractual obligations to the USFS, and tobe available for emergency wildfire suppression .For clarificat ion about this request , please contact the undersigned at661- 361-3043 ,or email mlynn@aerof liteinc.com. Regards , Mike LynnDirector of Flight Operations Aero-Fiite, Inc.