AFS-10-394-E 

Dec 20 2010 

 

 Exemption No. 7118G 

 Regulatory Docket No. FAA-2002-11655 

 

Mr. William Edgar Butts 

IHC Health Services, Inc. d.b.a. IHC Life Flight 

250 North 2370 West 

Salt Lake City, UT 84116 

Dear Mr. Butts: 

This letter is to inform you that we have amended Exemption No. 7118, as amended. It 

transmits our decision, explains its basis, and gives you the revised conditions and limitations 

of the exemption, including the date it ends. 

The Basis for Our Decision 

On August 31, 2010, IHC Health Services, Inc. d.b.a. Intermountain Life Flight wrote the 

Federal Aviation Administration (FAA) requesting clarification of Condition Nos. 4 and 7. 

With regard to Condition No. 4, the petitioner agrees that 25 hours as pilot in command (PIC) 

provide sufficient level of familiarization and experience in the aircraft. However, 

Intermountain Life Flight believes that the challenges and rigor of the hoist operations are 

mitigated more through hoist operations than by 25 hours of flight time conducting actual 

Class D external load operations. The petitioner contends that during hoist training it is 

possible to accomplish multiple hoist operations within an hour of flight time. 

 

The FAA agrees that the number of hoist operations conducted would be a better measure of 

effective training than actual hours flown. Additionally, the FAA recognizes that recording of 

time where an actual Class D external load operation was under way would be difficult. 

Tracking hoist operations is, therefore, a better measure of pilot experience. We have 

amended Condition No. 4 as follows: 
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 The PIC for such rescue operations must have a minimum of 25 hours of flight time as 

PIC in the Agusta A109K2. Additionally, each PIC must have successfully conducted 

 20 separate rescue hoist operations in the A109K2, either simulated or actual. Each of 

these hoist operations shall be conducted at an altitude which requires the aircraft to hover 

out of ground effect. Each hoist operation shall encompass the following elements: 

approach to the pickup site, establishment of a hover out of ground effect, a hoist lift with 

full recovery of the rescue target into the aircraft, and departure from the site. 

With regard to Condition No. 7, Intermountain Life Flight requests that the required risk 

assessment be maintained electronically. The FAA did not specify the method by which the 

exemption holder must maintain these records. It would, therefore, be acceptable for the 

operator to maintain them in an electronic format. 

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 7118, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA 

Administrator has delegated to me, I grant your petition, subject to the following revised 

conditions and limitations. 

 

 Conditions and Limitations 

1. Intermountain Life Flight will conduct training for pilots and crewmembers in 

accordance with a Class D external load training program accepted by the 

Administrator before commencing the conduct of Class D rotorcraft load combination 

operations. The training program will include initial and recurrent training for pilots 

and other crewmembers, in accordance with § 133.37. 

2. Intermountain Life Flight must submit a request to the certificate-holding district 

office (CHDO) for an amendment to its Class D authorization and training program to 

allow the conduct of Class D external load rescue operations with these additional 

limitations. 

3. The rotorcraft used in such rescue operations will be equipped with Arriel 1K1 turbine 

engines. 

4. The PIC for such rescue operations must have a minimum of 25 hours of flight time as 

PIC in the Agusta A109K2. Additionally, each PIC must have successfully conducted 

20 separate rescue hoist operations in the A109K2, either simulated or actual. Each of 

these hoist operations shall be conducted at an altitude that requires the aircraft to 

hover out of ground effect. Each hoist operation shall encompass the following 

elements: approach to the pickup site, establishment of a hover out of ground effect, a 
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hoist lift with full recovery of the rescue target into the aircraft, and departure from the 

site. 

5. This exemption is not valid for operations conducted below 2,500 feet mean sea level. 

6. This exemption is valid only for rescue operations undertaken to reduce or eliminate a 

significant imminent threat to human health or life and when no other civil aircraft is 

reasonably available that meets the requirements of § 133.45(e): 

a. In evaluating whether a threat is “significant and imminent,” Intermountain 

Life Flight, in consultation with appropriate and qualified rescue or medical 

personnel, must reasonably determine that a threat of serious injury or death is 

present; and 

b. In evaluating whether any other civil aircraft is “reasonably available,” 

Intermountain Life Flight must determine that at the time of the rescue 

operation, no other civil aircraft meeting the requirements of § 133.45(e) is 

available and capable of responding to the threat in a timely manner. 

7. Prior to any flight conducted under this exemption, Intermountain Life Flight must 

conduct and document a risk assessment to determine that the operation can be safely 

conducted. A copy of each completed risk assessment must be retained for 2 years 

and made available on request to the CHDO. 

8. Intermountain Life Flight, in consultation with the appropriate rescue or medical 

personnel, must reasonably determine that an external load hoist operation is 

necessary to respond to the threat in that the rotorcraft external load hoist operation 

offers the best opportunity to reduce or eliminate the threat to human health or life. 

9. Transport of passengers rescued under this exemption must be conducted in 

accordance with the requirements of Intermountain Life Flight’s part 135 operating 

certificate (Certificate No. I7LA073J) and operations specification paragraph A021. 

10. Intermountain Life Flight must provide the FAA with current information on the status 

of its helicopter replacement project. This information must include an expected 

timeline for fleet replacement. This information must be provided to the CHDO on a 

yearly basis, beginning August 30, 2011. 

The termination date remains August 31, 2012, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

Raymond Towles 

Acting Director, Flight Standards 

 Service