Metro Aviation, Inc. • 1214 Hawn Avenue • P.O. Box 7008 • Shreveport, LA 71137 • (318) 222

- 5529 • Fax (318) 222

- 0503

www.metroaviation.com July 21, 2015

U. S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue SE Washington, DC 20590

Dear Sirs

Enclosed is a petition to the Federal Aviation Administration (FAA) for an exemption from Section 135.611(b) of Title 14 of the Code of Federal Regulations.

Metro Aviation, Inc. is an Air Ambulance operator with over 3 3 years of experience

. This petition would authoriz e Metro Aviation, Inc. to perform Instrument Flight Rules (IFR) operations at locations that do not report weather and in aircraft not equipped with the severe weather detection equipment required in 14 CFR 135.611(b).

Thank you for your consideration. Sh ould you have any questions, please contact me at my office, 318

- 698

- 5827, or by email at jarthur@metroaviation.com

Respectfully

,

J ames Arthur Director of Operations

## Metro Aviation, Inc.

FAA Air Carrier Certificate Number: HDNA610E

1214 Hawn Ave Shreveport, LA 71107

Contact:

James Arthur Director of Operations

Phone: 318

- 698

- 5827

Fax: 318

- 222

- 0503
Email: jarthur@metroaviation.com

_____________________________________________________________________________________

This is a petition to the Federal Aviation Administration (FAA), pursuant to 14 CFR Section 11.61(b), for an exemption from 14 CFR Section 13 5.611(b), as that section has been recently interpreted by the FAA's Flight Standards Service in internal guidance to Principal Operations Inspectors. Metro Aviation, Inc. is seeking immediate relief from 14 CFR 135.611(b) to the extent necessary to allow Metro Aviation, Inc. to perform instrument flight rules (IFR) departures and IFR instrument approach procedures (I AP) at airports and/or heliports that do not have an approved weather reporting source, without airborne radar or thunderstorm detection equip ment installed on our aircraft.

Metro Aviation, Inc. is an Air Ambulance operator headquartered in Shreveport, LA with field operations in 18 States. Our Company operates a fleet of 111 helicopters and 10 fixed wing aircraft, all of which are
dedicated t o Air Ambulance operations. If granted, Metro Aviation, Inc

. , would implement this exemption with the following conditions:

1. The exemption is limited to the Metro Aviation, Inc. helicopters, which are configured for nine or less passengers , as identified in the appropriate paragraphs of Metro Aviation, Inc. Operations Specifications

. 2. The exemption will only apply when current weather reports indicate that thunderstorms or other potentially hazardous weather conditions are not reasonably expected to exist a t the destination and at the alternate at the estimated time of arrival (ETA).

3. The pilot will use all available weather products during preflight planning (i.e. , DUATS, ADDS, and any other NWS data) to determine that severe weather does not exist, nor is f orecast to exist, at
the destination and at the alternate at the ETA.

4. The Metro Aviation, Inc. Flight Risk Assessment Tool includes the consideration of hazardous
weather conditions. Constant monitoring and continued risk mitigation with the certificate ho lder or the Operational Control Center will be required prior to and during flight if that risk is identified. The flight will be declined or aborted if the risk cannot be mitigated.Serving the best interest of the public:

**•** Metro Aviation, Inc. maintains it is in the public's best interest to utilize the IFR infrastructure to the fullest extent possible by allowing access to all IAPs , regardless of their weather reporting capabilities in accordance with 14 CFR 135.611 (a), (c), and (d). This wil l serve the public's best interest by allowing the public greater access to HAA assets that can expedite the air transportation of the patient directly to a specialty care facility. This will avoid the delay of ground transportation by allowing flight in weather conditions that would benefit from an IFR flight plan, while still avoiding flight in severe weather conditions.

**•** Metro Aviation, Inc. operates in many geographic areas that are routinely challenged by visibility and ceiling ; but are void of convective or otherwise hazardous weather conditions. Denial of a patient's access to the specialty care they need, in the time frame they need it, by restricting IFR operations in weather conditions that known to be free of hazardous wea ther

– is contrary to the best interests of the public.

Maintaining and enhancing an equivalent level of safety:

**•** This exemption, if allowed, will help void the potential for Controlled Flight into Terrain (CFIT)
accidents caused by pilots trying to remain in visual meteorological conditions (VMC) when the weather is clearly instrument meteorological conditions {IMC). The underlying purpose of Section 135.611 is to facilitate IFR operat ions by HAA operators, resulting in more aircraft operating in a positively controlled environment, thereby enhancing safety. This is also consistent with recommendations made by the National Transportation Safety Board (NTSB) on February 18,

2010 in a fact sheet issued by the FAA that calls for the need to facilitate "...more IFR operations by permitting helicopter air ambulance operators to continue IFR approaches into hospitals and airports using weather reports from nearby stations rather than requ iring weather reports specifically from the destination location."

**•** In support of conditions 1 through 4 li sted above, Metro Aviation, Inc. will mitigate the risk of flight into severe weather by training its pilots and operation control specialists on th e following subjects. The following training will be completed and evaluated annually:

1. IFR Flight Planning

2. Use and interpretation of NWS weather charts

3. Interpretation of live radar feeds

4. SIGMETS and AIRMETS

5. MET AR and T AFs
6. Interpretation and appropriate use of available cockpit weather displays

7. The applicability and use of this exemption avoid the potential for Controlled Flight into Terrain**•** Metro Aviation, Inc. General Operations Manual (GOM) clearly restricts flight into "thunderstorms
or other potentially hazardous weather conditions" with aircraft that either do not have thunderstorm detection equipment or airborne weather radar installed , or if installed and that equipment becomes inoperable in flight

.

**•** Metro Aviation, Inc.’s GOM Section 301, Paragraph D. 13) states:

“ Pilots shall operate their aircraft clear of all thunderstorms. If in flight the pilot cannot circumnavigate the thunderstorms, he shall land at the nearest suitable airport or return to point of departure. No flight may begin under IFR con ditions when current weather reports indicate that thunderstorm or other potentially hazardous weather conditions that can be detected with airborne thunderstorm detection equipment may be reasonably expected along the route to be flown, unless the airborn e thunderstorm detection equipment is in satisfactory condition. If the airborne thunderstorm detection equipment becomes inoperative en route under IFR during hazardous or potentially hazardous conditions, the pilot will coordinate with ATC so as to
termi nate the flight in the safest manner. ”

In summary, Metro Aviation, Inc. will maintain an equivalent level of safety to 14 CFR 135.611( b) with consistent, thorough and effective preflight planning, weather interpretation training for its pilots, and
clear guidance paired with constant operational control oversight and monitoring by the certificate holder.

Thank you for your consideration of this request for exemption.