Description of Requested Relief

This is a petition to the Federal Aviation Administration (FAA) pursuant to 14 CFR Section 11.61 for an exemption from
14 CFR Section 135.611(b), as that section has been recently interpreted by the FAA’s Flight Standards Service in internal guidance to Principal Operations Inspectors. Air Methods is seeking immediate relief to the extent necessary to allow Air Methods to resume performing instrument flight rules (IFR) departures and approach procedures (IAP) at airports and or heliports that do not have an approved weather reporting source w ithout airborne radar or lightning strike detection equipment installed in its helicopter s with a passenger seating configuration of 9 seats or less (excluding any pilot seat). Consistent with Air Methods O perations S pecifications and its operational practice for several years before that interpretation, the requested exemption, if granted, wi ll be limited as follows:

A. The exemption would apply to operations of Air Methods helicopters with a passenger seating configuration of 9 seats or less (excluding any pilot seat), listed in our Operations Specifications when

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1. Current weather reports or forecasts indicate that there is no reasonable possibility of thunderstorms or other

severe weather expected to exist at the destination, alternate or along the route to be flown for the period of time planned for the flight ; and

2. Additional preflight planning is triggered by the Air Methods Preflight Risk Assessment Program that must be completed before the first leg of each Helicopter Air Ambulan c e Operation ( HAA O)
, conducted under Section
135.611

.

B. For a flight to be conducted under Section 135.611
, the additional weather briefing
, flight monitoring and related training actions described below must be taken . The se actions are described in the Air Methods General Operations Manual and Approved Training Programs

.

1. Additional Weather Briefing Requirements for Flight s Under Section 135.611

• The pilot will use information obtained from the National Weather Service to determine that there is no reasonable possibility of thunderstorms or other severe weather conditions expected to exist at the destination, alternate or along the route to be flown for the period of time planned for the flight ;

• The following aviation weather products must be reviewed in making that determination; AIRMET, SIGMET,
CONVEC TIVE SIGMET, METAR, REGIONAL NEXRAD, NOTAM, PIREP, and TAF ; and

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• No IFR operation under Section 135.611 will be released if c urrent weather reports or forecasts indicate the potential for thunderstorms or other severe weather to exist at the destination, alternate or along the route to be flown for the period of time planned for the flight. If such potential exists, t he pilot must refuse the flight.

2. Flight monitoring by the Operations Control Center

Once the flight becomes active
, the Air Methods Operations Control Center uses specialized software, Flight Management System (FMS)
, that automatically monitors the flight plan, current position and destination of all active flights. The FMS system automatically alerts the Operations C ontrol Specialist, by text and with visual alerts on the FMS display, when there are thunderstorms or severe weather within 30 NM of an aircraft or a point on the route of flight.The Air Methods Operations Control Center continuously monitor s all flights for thunderstorms and severe weather and provides that information to the pilot by :

• Relay through the Communications Center to the pilot ;

• Contact ing the pilot directly via satellite phone ; or

• Contact ing the pilot directly over our internet based voice communications system

.

- The Operations Control Center provides general advice such as, “there are thunderstorms to your west

-- recommend you divert to the east.”

3. Training for our pilots and operations co ntrol specialists will be completed on an annual basis and includes:

a. IFR Flight Planning (4.0 hours)

b. Use and interpretation of NWS weather charts (2.0 hours)

c. Interpretation of live radar feeds (2.0 hours)

d. SIGMETS and AIRMETS (2.0 hours)

e. METARS and TAFS’s ( 2.0 hours)

f. Interpretation and appropriate use of available cockpit weather displays (2.0 hours)

g. The applicability and use of this exemption (1.0 hours)

Granting the Requested Exemption would Enhance Safety and is in the Public Interest

Air Methods maintai ns that it is in the public interest to utilize the IFR infrastructure to the fullest extent possible thereby avoiding the potential for controlled flight into terrain ( CFIT ) accidents caused by pilots trying to remain VFR when the weather is marginal. The public interest also will be served by increasing the opportunity for additional access to critical care patient flights.

Air Methods believes that, by granting this petition, the FAA will permit an alternate means of compliance that is an equivalent level of safety as provided by Section 135.611(b) to be maintained and will be acting in a manner consistent with the aviation safety goal of Section 135.611. Air Methods believes that the true mitigation of the risk of operations in areas of severe weather lies in effective and consistent preflight planning and training for its pilots and operational control oversight by the certificate holder. If this exemption is not granted it would negatively affect the public interest by reducing the number of available HAA flights. A fully trained crew, following proper IFR procedures, in a properly equipped aircraft, can only enhance safety.

The underly ing purpose of Section 135.611 is to facilitate IFR operations by helicopter air ambulance operators and result in more aircraft operating in a positively controlled environment, thereby increasing safety. T he recent interpretation of the rule instead has the unintended consequence of encouraging HAA operators to fly in marginalweather conditions under VFR because the interpretation requires Airborne Weather Radar or Lightning Detection Equipment.

Air Methods is committed to the safe and successful completion of its air medical flights and believes that it is safer to file an IFR flight plan and to operate under IFR than to conduct flight operations under VFR in marginal visual meteorological conditions (VMC). Air Methods believes that operating in marginal VMC weather conditions has been the single most frequent ca usal factor in EMS aircraft accidents.

Air Methods further believes that the proposed exemption is in keeping with the safety purpose of the rule by permitting HAA operators the ability to operate in accordance with IFR more often. This would minimize the need for marginal VFR flight operations.

Granting the proposed exemption in regard to Section 135.611(b), as interpreted, would not promote flights into severe weather, because Air Methods does not conduct IFR operations in severe weather conditions.

Further Justifying Information

Air Methods is the largest HAA operator in the country and has over 35 years of HAA experience. Air Methods corporate headquarters are located in Englewood, CO. Air Methods has more than 300 bases of operations that serve 4 8 states providing air medical transport and critical patient services. We operate both fixed and rotor wing aircraft. In 1980 our founder Roy Morgan operated one of the first Hospital Based Programs (traditional model) in Grand Junction Colorado
conduct ing IFR operations in a single engine Bell 206 helicopter.

For the last eight years Air Methods has safely conducted IFR approaches into and out of airports and heliports using FAA approved non

- part 97 IAP’s at locations that do not have weather reporting. Since 2009 these procedures were approved under an authorization in Operations Specifications A021 and did not require severe weather detection equipment. During the rewrite of part 135, the authorization in A021 was correctly removed from the Operation s Specifications and placed in what became Section 135.611 in the final HAA rule. In Section 135.611 (b) there is a requirement for “severe weather detection equipment” with no specific definition of what that term means.

Air Methods conducted 7,946 IFR flights and transported 4,744 critical patients in the years 2011 through 2014.

The success rate for these operations rests upon two very important items

– (1) the thorough and effective training of pilots on preflight planning and IFR procedures and (2) the complete avoidance of flying in reported or forecast severe
weather. 

### Year AcType Total Hours IFR IFR Flight Count IFR Patients Flown
2011 Rotor Wing 1,129 1,413 949
2012 Rotor Wing 1,316 1,889 1,383
2013 Rotor Wing 1,775 2,185 1,295
2014 Rotor Wing 2,196 2,459 1,117 6,416 7,946 4,744 Rotor Wing TotalSummary.

In summary, immediate granting of the requested relief will enhance aviation safety and be in the public interest. Each day that passes without relief from the recent interpretation of Section 135.611(b) prevents safe IFR operations and unnecessarily restricts public access to air medical transportation. We appreciate your positive and expeditious consideration of our request for this relief.

Respectfully submitted,

D ennis McCall Director of Operations Air Methods Corporation 7211 South Peoria St. Englewood, CO 80112 dmccall@airmethods.com 303

- 495

- 4836

Summary of Petition for Publication

Air Methods seeks an exemption from Section 135.611(b) of Title 14 of the Code of Federal Regulations, as that section has been recently interpreted by the FAA’s Flight Standards Service in internal guidance to Principal Operations Inspectors. Air Methods is seeking relief to the extent necessary to allow Air Methods to resume performing instrument flight rules (IFR) departures and to perform IFR instrument approach procedures (IAP) at airports and or heliports that do not have an approved weather reporting source without airborne radar or lightning strike detection equipment installed in its helicopters with a passenger seating configuration of 9 seats or less (excluding any pilot seat), with limitations consistent with the company’s past operating practices.