### Flight Trails Helicopters, Inc. **4805 E. Falcon Drive Mesa, Az. 85215**  Mr. Les Smith, 07
- 01
- 14 Manager, AFS 200 A ir T ran s portation D ivision This letter is requesting a L etter 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. Specificall y, we are requesting authorization to us US FAA issued airman certificates to train US rated and certified pilots and TSA appr oved Foreign students. We also request to operate MD500E, Registration N272MK serial number 0256E, owned b y the KRG
- MOI , LL C Company
. In addition , we will support the Kurdistan traffic police operations by assisting with the set up and implementation of th eir aviation program . All operations conducted are exclusively

for and approved by

the Kurdistan Regional Government, Minister of Interiors T raffic P olice O peration. In 2014, the Kurdistan Regional G overnment, T raffic P olice D ivision acquired 12 MD 530f f and 2 MD902 aircraft from the MD Helicopters, Inc. in a deal approved b y the US government. In addition they

acquired an MD500E to use as a training aircraft. The Kurdistan Regional G overnment, Minister of Interior's office (KRG

– MOI) has asked Flight T rails 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 t yp e policies and procedures to be followed along with I CAO rules. Iraqi C ivil A viation rules do not apply to foreign operators assistin g local police operations. All R otorcraft operated under this L OA are directl y owned or exclusively leased directl y to the KRG
- MOI traffic police. A review of ICAO article 3 rules clearly state that ICAO regulations appl y only to civil aircraft, not police operations. The KRG
- MOI traffic police operation is clearl y 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 specificall y for CFR
- 91.1605
. 1. Operation of N registered rotorcraft in E rbil , I raq's tower controlled airspace. 2. Allowance of accepting airman certificate usage for training other pilots. 3. Weather briefing and airport information wi ll be attained locall y for the E rbil T ower prior to operations. 4. Security

threat information will be received from the traffic police and direct communi cation will be maintained with E rbil air traffic control tower.

### Flight Trails Helicopters, Inc. **4805 E. Falcon Drive Mesa, Az. 85215**  Listed bel ow are our answers to operational concerns as listed as a requirement for an y 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 directl y

from the E rbil C ontrol T ower prior to taking off. In addition securit y threat information will be received from the KRG
- MOI traffic police prior to flights.

 **Use specific airways to enter Iraqi airspace.** Answer
- Does not appl y, only operations will be conducted in Erbil Air Traffic C ontrol A irspace.

 **Operate in accordance with the Iraq Aeronautical Information Publication (AIP).** Answer
- Iraq AIP will be followed and a current cop y will be retained in the KRG
-

MOI traffic police aviation programs chief pilots office

 **Minimize time below FL200 within the amend ed airspace.**  Answer
- Not applicable, no commercial operations are conducted and only flights will be inside E rbil Air Traffic Control A irspace.

 **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 at**  **202 -**  **267 -**  **3333 or email**  **a eo**  **- citewatch@faa.gov**  **.** Answer
- will comply

and in addition work closel y 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 re gistered aircraft.

 A ll pilots will be approved by the KRG
- Minister of Interior office and allowed to fl y in E rbil airspace as approved directly by the M inister of Interior prior to commencement of any flights.

### Flight Trails Helicopters, Inc. **4805 E. Falcon Drive Mesa, Az. 85215** 

 **How is indiv idual Aircraft Security Controlled?**  Answer

– Aircraft are located on the Erbil Airport where there is very tight securit y 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 Interio rs 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 appr oval/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 wit h Erbil Air Traffic Control and contact Tower for the Traffic Police recovery unit to come secure/recover the Aircraft by police personnel. I n 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 individ uals 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 qualit y 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 qualit y and the safest operations. The ability to use US trained pilots is the only

way this can be achieve d. Flight Trails Helicopters, I nc believes that the above procedures will ensure the best possible safet y protocols and procedures to provide a professional training environment that will meet or exceed an y US operation. Best Regards, 

## Terry J. Tyner Terr y J . Ty

ner Vice President, Flight Trails Helicopters, I nc. 602
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