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Sikorsky

A Lockheed Martin Company

6900 Main Street Stratford, CT 06615-9129 

Mailstop S212A4

Telephone +1 203•386•4000 

US Department of Transportation 

Federal Aviation Administration 

1200 New Jersey Avenue

SE West Building Ground Floor 

Room W12-140

Washington, DC 20590

June 7, 2016

Sikorsky Aircraft Corporation — (1) Request extension of Exemption 11030A for the S-70i and S-92, (2) 

Amend Exemption 11030A to read S-70, (3) Amend Exemption 11030A to remove restrictions, thereby 

allowing flights under a special airworthiness certificate. 

Reference:

a) 14 CFR 61.3(a)(1)

b) 14 CFR 61.55(g)

c) Exemption 11030A, Regulatory Docket No. FAA-2014-0040

d) S-70 Operator's Manual

e) S-92 Rotorcraft Flight Manual

Based on the continuing requirement for Sikorsky, A Lockheed Martin Company, to conduct demonstration, customer 

pilot training, and customer acceptance flights with a variety of foreign customer pilots, Sikorsky requests an 

extension of the previously granted exemption from the requirements of section 14 CFR 61.3(a)(1). This section 

requires all pilots to hold a FAA pilot license in accordance with the requirements of the Operator's Manual which 

states, "the minimum crew required to fly the helicopter is two pilots". In addition, Sikorsky requests an amendment 

to the exemption allowing for operation of the S-70 and to allow flights under a special airworthiness certificate.

Discussion:

The S-70 and S-92 operator manuals require two pilot crewmembers. While airmen holding an appropriate FAA 

certificate can occupy the second in command seat to perform flight of the S-70 and S-92 in U.S. airspace per 14 CFR 

61.55(g), otherwise qualified individuals lacking FAA certificates may not. This precludes Sikorsky from allowing the 

pilots of many foreign customers to manipulate the controls during demonstration, pilot training, or acceptance 

flights in the aircraft. This requirement most directly and negatively affects Sikorsky's foreign military aircraft sales 

and training contracts, where the foreign military pilots typically do not hold civil airman certificates from their own 

country.

Pertinent regulations:

Section 61.3(a)(1) prescribes, in pertinent part:

(a) Pilot certificate. No person may serve as a required pilot flight crewmember of a civil aircraft of 

the United States, unless that person--

(1) Has a pilot certificate or special purpose pilot authorization issued under this part in 

that person's physical possession or readily accessible in the aircraft when exercising the privileges 

of that pilot certificate or authorization.
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Rationale for extension/amendment:

(1) Request extension of Exemption 11030A for the S-70i and S-92. Sikorsky requests to continue to 

operate in accordance with limitation established by exemption 11030A where all customer pilots are 

required to have in their possession a valid U.S. commercial pilot certificate or airline transport pilot 

certificate with a rotorcraft/helicopter rating or, a pilot certificate with rotorcraft/helicopter privileges issued 

by an ICAO-member state, or 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. 

All Sikorsky pilots will possess a valid U.S. commercial pilot certificate or airline transport pilot certificate, S70 or S-92 type rating with a current 61.58, and a FAA certified flight instructor certification. 

(2) Request Amendment to Exemption 11030A to read S-70. Amend exemption 11030A to read S-70

instead of S-70i in order to extend the exemption privileges to all S-70 models identified on figure 5-88 

(Pilot Certificate Aircraft Type Designations-Helicopter) of FAA Order 8900.1. Sikorsky Aircraft currently 

manufactures, operates, and trains in all the aircraft listed on figure 5-88 which are also operated by a 

number of foreign military services and foreign commercial operators. The extension of privileges in this

exemption to all S-70 type designation aircraft will allow customer pilots to participate in demonstration, 

pilot training, and customer acceptance flights. Only Sikorsky instructor pilots that are designated instructors 

in the S-70 models per figure 5-88 will exercise duties as Pilot-In-Command. 

(3) Request Amendment to Exemption 11030A to remove restriction on page 4, para 1(e)(iii);

“Flights under a special airworthiness in the experimental category other than for purpose of 

sales demonstration”. Thereby allowing flights under a special airworthiness certificate. The 

current conditions and limitations of exemption 11030A does not allow customer to participate in training

flights or customer acceptance on aircraft that are operated under a special airworthiness certificate in the 

experimental category. This limitation places a requirement on foreign customer pilots to obtain a U.S. 

commercial pilot certificate in order to receive training or accept aircraft acquired from our company. In 

many cases foreign military pilots are not required to hold a commercial pilot license or have the means to 

obtain a commercial license and will do not meet the requirements to apply for a temporary FAA Private 

pilot certificate on the basis of a foreign pilot license, in accordance with 14CFR Part 61.75. Therefore, 

customers will not be able to satisfy the Second-In-Command requirements of 14 CFR 61.55(g). 

Additionally, S-70 aircraft currently being manufactured by Sikorsky for foreign sales do not hold a type 

certificate. Consequently, it requires the aircraft to be operated under a special airworthiness certificate 

which prevents customer pilots from participating in aircraft acceptance and pilot training. 

If granted the extension/amendment, Sikorsky will continue to impose the following conditions and follow the 

limitations listed in exemption 11030A:

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

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

a. Hold a valid U.S. commercial pilot certificate or airline transport pilot certificate with a S-70 or 

S-92 type rating and current 61.58;
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b. Hold a valid U.S. first or second class medical certificate;

c. Be directly employed by Sikorsky, or contracted to conduct demonstration, customer pilot 

training, or customer acceptance flights on behalf of Sikorsky; and,

d. Must be an FAA certified flight instructors (CFI) and be designated by Sikorsky as an instructor 

pilot in the different S-70/S-92 models; and,

e. Must remain the PIC for the duration of the flight.

5. Persons acting as Second-In-Command (SIC) of any flights operated using the privileges of this 

exemption must:

a. 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-70 or S-92 

aircraft from Sikorsky;

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

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

an ICAO-member 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:

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

b. A review of the intended flight including all maneuvers to be performed; and,

c. A review of all pertinent emergency procedures for the S-70 or 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.

For clarification about this request, please contact the undersigned at 203-383-6400, or email at 

joe.g.nieves@lmco.com

Sincerely,

José G. Nieves

Chief Pilot, Standardization and Training 

Sikorsky Aircraft Corporation

6900 Main St. Stratford CT 06615