20 February 2015 

US Department of Transportation 

Federal Aviation Administration 

1200 New Jersey Avenue 

SE West Building Ground Floor 

Room W12-140 

Washington, 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 in a 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 in the 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 to our FAA mandated check rides, we are also required to perform annual 

pilot check flights to satisfy the USFS. It is vital that our pilots meet certification and currency requirements 

in order to meet USFS pilot inspection flights beginning March 121

h, 2015. 

Justification 

Our CL-415 and RJ85 aircraft are operated under a Special Airworthiness certificate in the Restricted 

category. Per 14 CFR 21.25(b), the aircraft are authorized to fly: (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 of the 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 for us to 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 and in 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 risk to the public 

and is in the 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 it is certificated, or in an operation other than one necessary to 

accomplish the work activity directly associated with that special purpose. 

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

identical to those that have been accomplished by the operator in the past. Performing the same operations 

under the oversight of an FAA DPE/Inspector/PPE in accordance with all provisions of 91.313, presents no 

additional risk to the public. 
... 

/ Section 91.313(b) prescribes, in pertinent part that operating a restricted category civil aircraft to provide 

flight crewmember training in a special purpose operation for which the aircraft is certificated is considered to 

be an operation for that special purpose. 

Rationale for exemption: No additional maneuvers or operations other than those already performed by the 

operator are to be performed in connection with the requested 61 .31 or 61.58 training. The requested Type 

Rating check rides and PPE observation check rides therefore do not present additional risk to the public 

and are in the public interest. 

Your attention to this matter is appreciated and necessary for Aero-Fiite to meet contractual obligations to 

the USFS, and to be available for emergency wildfire suppression. For clarification about this request, 

please contact the undersigned at 661 -361-3043, or email mlynn@aerofliteinc.com. 

Regards, 

Mike Lynn 

Director of Flight Operations 

Aero-Fiite, Inc.