Flight Trails Helicopters, Inc.

4805 E. Falcon Drive

Mesa, Az. 85215

Mr. Les Smith, 07-01-14

Manager,

AFS 200 Air Transportation Division

This letter is requesting a Letter of Authorization in accordance with FAA notice 8900.264 dated 

6/5/14 SFAR 77 authorization, Appendix F, specifically to conduct rotorcraft operations in Erbil 

Iraq.

Specifically, we are requesting authorization to us US FAA issued airman certificates to train US 

rated and certified pilots and TSA approved Foreign students. We also request to operate 

MD500E, Registration N272MK serial number 0256E, owned by the KRG-MOI, LLC 

Company. In addition, we will support the Kurdistan traffic police operations by assisting with 

the set up and implementation of their aviation program. All operations conducted are 

exclusively for and approved by the Kurdistan Regional Government, Minister of Interiors 

Traffic Police Operation.

In 2014, the Kurdistan Regional Government, Traffic Police Division acquired 12 MD 530ff and 

2 MD902 aircraft from the MD Helicopters, Inc. in a deal approved by the US government. In 

addition they acquired an MD500E to use as a training aircraft.

The Kurdistan Regional Government, Minister of Interior's office (KRG–MOI) has asked Flight 

Trails Helicopters Inc. to assist them in setting up this program and getting them flying. The 

KRG-MOI has no experience in rotorcraft operations and request United States FAA type 

policies and procedures to be followed along with ICAO rules.

Iraqi Civil Aviation rules do not apply to foreign operators assisting local police operations. All 

Rotorcraft operated under this LOA are directly owned or exclusively leased directly to the 

KRG-MOI traffic police.

A review of ICAO article 3 rules clearly state that ICAO regulations apply only to civil aircraft, 

not police operations. The KRG-MOI traffic police operation is clearly for the local traffic police 

and will be operated as such, no commercial use or for hire work will be conducted under the 

requested LOA.

The current regulations state that an airman may not exercise his certificate, however a CFI 

certificate is needed and required to train and check out other US pilots or to conduct flight 

training. Therefore we are requesting this LOA.

The particular LOA/Exemption we are requesting is specifically for CFR-91.1605 .

1. Operation of N registered rotorcraft in Erbil, Iraq's tower controlled airspace.

2. Allowance of accepting airman certificate usage for training other pilots.

3. Weather briefing and airport information will be attained locally for the Erbil Tower prior to 

 operations.

4. Security threat information will be received from the traffic police and direct communication 

 will be maintained with Erbil air traffic control tower.
Flight Trails Helicopters, Inc.

4805 E. Falcon Drive

Mesa, Az. 85215

Listed below are our answers to operational concerns as listed as a requirement for any LOA per 

Appendix F of Notice 8900.264 and additional pertinent items;

 Have a method for obtaining current reports and information on airport conditions, 

navigation aids, weather, and any other factors that may affect the safety of flight 

including commercially available current threat information. This includes both 

preflight planning and enroute operations.

Answer - Flight Trails Helicopters trained pilots will obtain current reports directly 

 from the Erbil Control Tower prior to taking off. In addition security threat 

 information will be received from the KRG-MOI traffic police prior to 

 flights.

 Use specific airways to enter Iraqi airspace.

Answer- Does not apply, only operations will be conducted in Erbil Air Traffic 

 Control Airspace.

 Operate in accordance with the Iraq Aeronautical Information Publication (AIP).

 Answer - Iraq AIP will be followed and a current copy will be retained in the KRG-

 MOI traffic police aviation programs chief pilots office

 



 Minimize time below FL200 within the amended airspace.

 Answer- Not applicable, no commercial operations are conducted and only flights 

 will be inside Erbil Air Traffic Control Airspace.

 Not land at airports other than ORER and ORSU, except in an emergency.

 Answer- Will comply.

 Report any security incidents/events to the FAA Washington Operations Center 

(WOC) via phone at202-267-3333 or email aeo-citewatch@faa.gov.

 

 Answer - will comply and in addition work closely and follow all TSA rules.

 Comply with 14 CFR parts 91, 119, 125, 135 or 121.

 Answer- will comply with 14 CFR part 91 rules as applicable to US registered 

 aircraft.

 All pilots will be approved by the KRG-Minister of Interior office and allowed to fly in 

Erbil airspace as approved directly by the Minister of Interior prior to commencement of 

any flights.
Flight Trails Helicopters, Inc.

4805 E. Falcon Drive

Mesa, Az. 85215

 How is individual Aircraft Security Controlled?

 Answer – Aircraft are located on the Erbil Airport where there is very tight security 

 controlled by gate guards, check points and all personal must be escorted 

 or have airport ID access badges. In addition to this all aircraft are 

 located at the Traffic Police’s aviation hangar facility and will be secured 

 inside the hangar.

 How will aircraft maintenance and security be performed?

 Answer- Maintenance is performed by US certificated personal along with Minister 

 of Interiors hand picked and screened maintenance training candidates. The 

 hangar facilities are secured, first by entrance and approval into the airport, 

 then by locked hangar with entrance approval/badges required prior to 

 entering hangar. A maintenance program is being established using the

 original manufacturers recommendations and published manuals for all

 maintenance and following guidelines based on US FAR.

 How will aircraft accidents or incidents be handled if an aircraft goes down inside 

Kurdistan?

 Answer- All rotorcraft will maintain two way radio communications with Erbil Air 

 Traffic Control and contact Tower for the Traffic Police recovery unit to 

 come secure/recover the Aircraft by police personnel. In addition, a 

 company air to air frequency will be used to contact traffic police should 

 any assistance be required. 

The benefit of the letter of authorization will be that FAA qualified pilots will be allowed to train 

individuals utilizing their skill and expertise learned and obtained in the US under FAA 

guidelines. The KRG recognizes that the US has one the best structured programs in the world 

for pilot training and to receive such training brings the highest quality and capability to the this 

program. The KRG is committed to establishing a program mirrored to US FAA standards that 

are orientated toward the highest quality and the safest operations. The ability to use US trained 

pilots is the only way this can be achieved.

Flight Trails Helicopters, Inc believes that the above procedures will ensure the best possible 

safety protocols and procedures to provide a professional training environment that will meet or 

exceed any US operation.

Best Regards,

Terry J. Tyner

Terry J. Tyner

Vice President,

Flight Trails Helicopters, Inc.

602-617-6010