Room W12-140 

Washington, DC 20590 

Sikorsky Aircraft Corporation - Request an amendment to Exemption No. 11030 to allow for 

demonstration flights, customer crew training flights, and customer acceptance flights in both the S-70i 

and S-92 

Reference: FAA Exemption No. 11030 

Background: 

Sikorsky Aircraft requested an exemption from FAR Part 61.3(a)(1) regarding single pilot operations in a 

S70i aircraft on 14 Jan 2014. The exemption, if approved, would authorize demonstration flights, 

customer crew training flights, and customer acceptance flights with customers who do not possess U.S. 

pilot certification. 

Exemption 10076A was issued 16 May 2012 (an extension of Exemption 10076) allowing single pilot 

demonstration flights with non-US licensed copilots in the S92. That extension for the S92 was due to expire 31 Jun 2014. 

The FAA thought it worthwhile to combine the S92 exemption extension and the S70i exemption request 

into a single exemption letter. Sikorsky agreed with the understanding that demonstration flights, 

customer crew training flights, and customer acceptance flights would be included for both aircraft. 

A supplemental letter dated 26 Jun 2014 was submitted at the request of the FAA in support of 

combining the two aircraft into one exemption letter. SAC requests an amendment to FAA Exemption No. 11030 to allow for demonstration flights, customer 

crew training flights, and customer acceptance flights in both the S-70i and S-92. 

Discussion: 

1) SAC is requesting this exemption amendment to allow for demonstration flights, customer 

acceptance flights. and training flights in both the S-70i and S-92. 

2) Remove the restriction for operations entirely between official sunrise and sunset: The SAC 

training syllabi contain task, condition, and standards for both night and NVG. It is part of the 

comprehensive training we are to provide to our customers. SAC internal procedures/training 

contracts require that all students be night and NVG qualified prior to the commencement of the 

training event. SAC does not initially qualify students in any flight mode or regime. SAC currently 

employs eight FAA certified NVG CFis, two of which are Authorized Individuals with the authority 

to sign off additional NVG CFis. All SAC NVG CFis are former military NVG pilots/instructors with 

experience in tactical, combat, and shipboard operations. 

3) Allow for the inclusion of crew chiefs and flight engineers in the back when necessary/required: 

SAC requests that the requirement allowing only the PIC, SIC and an addition SAC pilot be 

amended to allow for necessary personnel. 
this requirement. Neither aircraft is designed to allow for in flight crew change in the event of an 

emergency should the PIC/SIC become incapacitated in flight. In-flight incapacitation of the 

PIC/SIC will be part of the briefed emergency procedures with instruction to land as soon as 

possible/practicable. The SIC is required by SAC procedure to be a fully qualified helicopter pilot 

who is capable of landing the aircraft if this emergency should occur. All flights are conducted 

VMC, in a tightly controlled environment. 

The requirement to have an additional SAC pilot on board greatly increases the cost of the 

training event. The pilot requirement has doubled. This will result in increased cost to the 

customer with no tangible benefit. It will not increase the quality of training, the speed at which 

the training will take place, or increase the safety of the training in any way. 

No FAR reference could be found that could be used as a parallel for this requirement. No other 

training/evaluation event in the FARs could be found requiring an additional pilot on board. 

SAC will require a qualified crewmember on board for all demonstration flights, customer 

acceptance flights, and training flights. 

5) Foreign country: SAC fully understands that this exemption is only valid in the U.S. Para 5, pg 3 

states, "If SAC wishes to conduct operations outside the U.S., it must petition the FAA for such 

relief, including the reason for the request". Given the length of time of this exemption, it may 

not be feasible to wait this long in the future given the nature of potential customer 

request/demands. Request the requ irement be changed to: 

Conclussion: 

For operations in foreign countries, the Conditions and Limitations of this exemption will 

be adhered to, including any policies and regulations of the host country. SAC will notify 

the FAA of any operations covered by this exemption that fall outside U.S. airspace. 

In light of the above information, Sikorsky Aircraft request that Conditions and Limitations section be 

amended, in its entirety as follows: 

1. All flight operations using the privileges of this exemption are limited to operations conducted in 

day, night, NVG, visual meteorological conditions (VMC) entirely that do not involve maintenance, 

engineering or manufacturing flight testing and are limited to the following purposes: 

a. Flights for sales demonstration purposes; 

b. Customer crew training; 

c. Customer acceptance purposes; 

2. UTC must be in full operational control of any aircraft operated using the privileges of this 

exemption. 

3. All flights must be approved by properly designated personnel at Sikorsky Aircraft Corporation; 

4. The Pilot In Command {PIC) of all flights operated under this exemption must: 

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f . Have logged ot least 50 hours as PIC of on S-70i/S92. 

5. The person acting os second in command {SIC) of any flights operated using the privileges of this 

exemption must: 

o. Be able to competently speak and understand the English language; 

b. Be an authorized representative of the U.S. or foreign military service, or be an 

authorized representative of a legitimate purchaser or legitimate potential purchaser of 

an S-70i/S-92 aircraft from UTC; 

c. Hold a valid U.S. commercial pilot certificate or airline transport pilot certificate with a 

rotorcraft/helicopter rating; or, a pilot certificate with privileges issued by an /CADmember state; or, 

d. Hold military orders or other acceptable documentation identifying the person as being 

rated as a helicopter pilot and a current member of a branch of the U.S. or foreign 

military service. 

e. May manipulate the controls for the purposes of sales demonstration, customer pilot 

training, or customer acceptance purposes when accompanied by a PIC who meets the 

requirements of Condition No. 4; 

6. The PIC must provide each demonstration, customer training, or customer acceptance pilot a 

preflight briefing to include: 

g. a review of the conditions and limitations of this exemption; 

h. a review of the intended flight including all maneuvers to be performed; and, 

i. a review of all pertinent emergency procedures for the S-70i/S-92. 

7. Only persons or property necessary for the conduct of sales demonstration, customer training, or 

customer acceptance flights are permitted on board the aircraft when conducting any flights 

using the privileges of this exemption. The PIC is responsible for determining whether persons or 

property to be carried are necessary for the flight. A flight manifest will be retained for the 

duration of the flight. 

For clarification about this request, please contact the undersigned at 203-386-6777, or email 

jbrennan@sikorsky.com. 

Very truly yours, 

I ll 1 •- I~ ,..., ~ ."'--\v -

Joseph P. Brennan 

Sikorsky Aircraft 

Chief Program Pilot, 

Standardization and Safety 

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