120 

Patient 

Adams 

AirLift 

Boulevard 

Services A't\L5 

Farmingdale, New York 11735 

631-694-PALS (7257)(p) 

631-755-2184(£) 

\V\vw.palservices.org 

Zui5 :".P;~-; .=> J: OO 

I PATIENT AIRLIFT SERVICES! 

Changing lives, one flight at a time ... 

Board of Directors 

ALAN SHEINESS 

CHAIRMAN 

JOE HOWLEY 

PRE:SIDE:NT VICE:· 

CHAIRMAN 

DONNA COLLINS 

TRE:ASURE:R 

MICHAEL CROWLEY 

SECRETARY 

MARK HANSON 

BRIAN LISOSKI 

JAMES MCCLOUD 

RHODA KUPFERBERG 

JAMES O'ROURKE 

SCOTT PAIGE 

JAMES PLATZ 

JOHN ROCHELLE 

RUTHANNE RUZIKA 

STUART WALDRUM 

KEITH WARD 

WILLIAM WEAVER 

Board Member Emeritus 

PETER RYAN 

HAROLD LEVY 

March 30, 2015 

by United States Postal Service- Express Mail 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor 

Room W12-140 

I200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Re: Exemption No. 10294 

Regulatory Docket No. FAA-2011-0324 

-- Request For Extension 

Dear Mr. Duncan: 

On June 22, 20II, the Administration's Flight Standards Service issued the 

attached letter advising Patient AirLift Services, Inc. ("PALS") that your office had 

granted PALS' Petition For An Exemption from Section 61.113( c) of Title 14, Code of 

Federal Regulations (14 CFR) to allow the reimbursement of its volunteer pilots for fuel 

costs incurred in conducting charitable flights. Subsequently, we filed for and received an 

extension to that exemption that letter stated that "exemption terminates on June 30, 20 I5 

unless sooner superseded or rescinded." 

We are writing to you at this time to request at least an additional two (2) year 

extension of Exemption No. I 0294. Not all pilots can afford to make charitable flights 

that sometimes can require hundreds of dollars of aviation fuel for a single flight. As a 

result of Exemption No. I 0294, PALS has been able to encourage pilots to volunteer their 

time and aircraft for flights transporting children and adults for access to healthcare and 

for other humanitarian purposes. The program has been highly successful. 

PALS would not have been able to carry out all of its humanitarian flights without 

the fuel reimbursement exemption. The benefits from this type of charity flying were 

recognized by Congress in Section 821 of Public Law 112-95, and acknowledged in the 

FAA's Policy Clarification on Charitable Medical Flights, published in the Federal 

Register on February 2, 2013. 

Patimt AirLiftS ervices is a 501 (c)(3) ta.x-exen!pf public charity 
PALS has carefully implemented the terms of its Exemption No. 10294, and PALS has 

continued to stress pilot education and safety with all of its volunteer pilots. 

Pilots wishing to qualify for in the PALS fuel reimbursement program must pass 

through a series of steps. Pilots must first supply all documentation proving they meet 

PALS standards to serve as Command Pilots, and provide a copy of their Class II 

Medical Certificate. 

In compliance with the terms ofF AA Exemption No. 10294, PALS has engaged 

Mid Island Air Services (MIAS), operators of an FAA approved flying school based at 

Islip, New York, to develop andr administer an initial and recurrent training program 

tailored to cover the specific items required under Exemption No. 10294. Pilots receive a 

Log Book endorsement from MIAS, and PALS receives a certification of the same from 

MIAS. 

Prior to each flight, PALS obtains the required pilot documentation, including a 

pilot affirmation that all Exemption requirements are adhered to. This includes the 

specific "Pilot Go/No Go Checklist" defined in Exemption No. 10294. Upon completion 

of the flight, pilots fill out reimbursement requests, which are verified and recorded. 

The program under the Exemption has been very important to the mission of 

PALS. The first training class was completed in February of2012. Since that time, 69 

pilots have completed training. 

PALS volunteer pilots have flown 254 flights transporting, for example, burn 

victims, wounded warriors, children receiving major medical treatments, and many 

others. 

Accordingly, PALS requests that your office extend Exemption No. 10294. An extension 

would allow PALS to continue to use fuel reimbursement to encourage pilots, who could 

not otherwise afford to participate in our program, to continue to volunteer their time and 

aircraft in support ofPALS' humanitarian services. 

We sincerely appreciate the FAA's support ofthe fuel reimbursement program. 

Should you have any questions, please do not hesitate to contact the undersigned. 

cc: John Rochelle 

Eileen Minogue 

Very truly yours, 

Alan heiness 

Chairman of the Board of Directors 

Patient AirLift Services, Inc. 

Alan. Sheiness@palservices.org 

(949) 289-3672 
Enhanced Affirm!'ltion for Fuel Reimbursement Fli~!'lts - 6_.2S.20~4 _ .

Pilot; . Mission No: Date: 

1 promise not to act as a-Command Pilotfpr any Patient Airlift Services flight referred to me unless at the tim·e of 

each such flight: 

1. I hold a Valid and current pilot certificate for th.e. aircraft category, class and type (if a type rating· is .required) 

In whic;h 1 will be acting as piloHii-cofnrriiu1d. 

2. 1 hold at_ least a va·lid and cu·rreht Cl~ss_ ilmedicalceitificate _ 

3. I ani IFR rate_cf, current and qualified in the aircraft ·category, class and type (if a type rating is required) to be 

flown. . . . 

4. La'min co_r:npliance_-with all Fed_eral A_yiati<?_n Regulati()ns, ircludin~tbo~e reg4lations rel~ti_l')g to c~:~r:rency for 

.carrying passengers, flight reviews, night flying, fuel·reserves and instrument flight. 

5_. - i .a·min compliance Witb all Fe_deraiAviation Regulations reJating to the use of. alcohol and.dri.Jgs,:including 

reporting requirements specifie_d ln the-regu(aticms. 

6. Whether flying rented or owned aircraft, I have in force liability insurance applicable to the flight providing 

minimum coverage of$1,000;000 per occurren~e and $100,000 per seat. 

7. I am flying an airplane with-a valid standard airworthiness certificate (normal, ut_ility, acrobatic,· commu-ter or 

.transport cate·gory). 

8. If! ·am rentil']g an aircraft for the mission; I attest that I have_ S(!tisfied the requirements and condjtions_of the 

re_nting agency~ 

9. I have flown at least SO hours as pilot~i_n~command in the last 12 calendar months: 

10. i have flown a minimum of i2 h9urs ~s PIC duringth_e 90 days i111mediately prec~ding the mission, or in the 

alternative, I have comple_t~d 2 ho~rs ofdu_al training with a certif!ed flight.instructor wit.hin th~·p·r~ceding 3 

calel)dar months prior tq the m·o.nth C?'f.{light. (This 12 hours is inci\Jded i_n t~e tota! of SO, and i_s not 

additional) 

1-1. I am under 78 years of age_. Otherwise, I ·have obtained a waiver from·th~ P-ilot Safety committee. 

12. I am in compliance with the.Pati~nt Airlift Services Manual, including,:but not lim.ited to: · 

a. For the operation of any single engine piston aircraft; the pilot shall have ·a minimum total time of 

sao· hours, with not less than 400 hours as pilot-in-command (PIC), SO hours of such PIC time having 

been in the_ same ma_ke and l_llodel aircraft. 

b. For the operation of any multi-engine or turbin·e powered aircr.aft the. pilot shall have a minimum 

total time a_s pilot-in-command (PIC) on;ooo h-ours, with a minimum of 100 hours in the specific 

make and model for a twin engine aircraft and 100 hours in type for a single ·engine turbine aircraft 

b!Jt not less than so hours'in make and rnodel, (Jnless disp_ensation shall have been pre~iousiy 

granted to· said pilot by the Safety Committee, but in no event shall such dispensation· be for less 

than the qualifications as set forth in paragraph (a) above. 

Pilot Name (print)-------------- Membership Number: __ ;....__--"-

Signature:----'---..,.----,,...-------~--- Date:-----------

1 understand that it is l)ly respon-sibility anp obligation to decline. to serve as pilot-in-command on any flight re'ferreq 

tb nie by -Patient Airlift SerVices unless ALL of the above.-statements are· true at the time. of the flig~~. 

This document is to be signed and s_ubmitted to PAI,.S along with all .;.,_aivers and W&B before each fuel reimbursement f/jght. 

Additionally-for Fuel Reimbursement Flights Only: 

./ lfthis is a Fuel Reimbutsementflight, check at left and complete the Enhanced Affirmatio·n and 

ttie·Pre~Fiight Risk Assessment Tool on the. following pages. 

Patient Airlift Services; 120 Adams Blv_d, Farmingdale, NY 11735 PALSMail@palservices.org -Fax: 631-755-2184 
Enhanced Affirmation for Fuel. Reimbursement Flights~ 6.25.2014. 

2 

Pilot: Mission No: Date: 

·.; 

Certificates, qualifications,.and aeronautical experience 

I hereby certify that I. meet the following certificates, qualifications, and ·aeronautical experience requirements (please 

.check all that.apply): 

0 

0 

0 

0 

0 

0 

[j 

0 

0 

0 

An instrument rating or privilege that is appropriate to the aircraft being flown; 

For the operation of any single-engine piston aircraft; a minimum total time Of SOO hou~s, with. no less than 400 

hours·as pilot in command (PIC), and a minimum of SO hours in the specific make and model of single-engine 

aircraft b'¢ing flown; · · · · · · · · 

For the opera'ting any multiengine.aircraft, a minimum total time of 1,000 hours as PIC in any aircraft;.a minimum 

of 2SO hdur~ in inulti-engil'!e aircraft, and a. min_imum of so hours ir:"~:the make and hio.del of multfe"~gine 'aircraft 

being flown; 

For the operation ofany single- or multieng.ine tur~ine-powered aircraft, a minimum total time ofl,OOO hours as 

PIC, a minimum of 100 hours in turbinecpowered aircraft, and a minimum of-SO hours in the make and model of 

turbine-powered aircraft.being flown; 

A minimum of SO hours as PI( sl:lall.have been logged within the precedingl2 calendar months-immediately. 

preceding the month of the flig~t; . 

A minimum of 12 hours flown and logged,.or 2 hours of dual flight trainingwith a certifi,cated. flight instructor, 

within the prece~ing.~ calendar mon,t~s prior. to the mqntl:l of ~he fl!ght_;. 

A 2nd class medical certificate (per§§ 61.23( d)(2)(i) and 61.2); 

Within the preceding 12 cal~ndar months, an instrument proficiency ched<(IPC) meeting the requirements of 

§61.S7( d), or a flight review meeting the requirements found in§ 6~.SG(a). The IPC or flight review must consist of 

at least 1 hour of flighttraining and 1 hour of ground training. This requirement can substituted by a FAA practical 

test for any pilot certificate or rating; · 

A currentflightre~iew (per§ 61.S6(a)) in the same aircraft category, c·iass, and type (if a type rating is required) 

being flown; Instrument c.urrent·(per§ 6LS7(c) or (d), as appropriate) in the same aircraft category, class, and type 

(if a type rating is required)·being.flown; ahd 

For all operations under this•exemption, the pilot must be current .for night operations (per §6l.S7 (b)) In an 

aircraftofthe same.category, class, and type(ifa type rating is required) . 

. Flight duty, rest, and fiight time limitations 

l'h.ereby certify that prior to (and at the conclusion of)Jhis mission I am (and will be) in compliance with the foflowing:flight 

duty, re~i,_and.flighttime limitations (pl~ase'check all that apply): . . . . 

0 No pilot may fly more than 8 hours of fllght tiin~ (per§ 61 .1) within any24-co.nsecutive-hour duty day period; 

. 0 No pilot may perform a ~luty day in excess of 12 conseiutjve h~urs. (A duty d~y st.~rts when the pil~t arrives.at the 

·airport and begins preparation for the·ftight and ten'ninates upon com'pletion of the post flight of the aircraft); and 

0 Once tlie·pilot has performed 12 co'n~ec·utj:ve n·our!(of duty, the pilot·must re·st.:a period of at'lea·sn2 hours before 

conducting another flight,6. · · · ' 

Fiight requirements . 

I hereb.v certifY to conduct this flight in compliance with the following'flight requirements (piease check all that apply): 

0 

0 

0 

_All flights opera_t~d under this exemption must acthrc_~te an IFR flight p_lan. 

The earliest the flight plan may be canceled..is upon acceptance of a visual approach clearance from air traffic 

control; 

For flights in instrument meteor.ological conditions (IM,C), each pilot may _only_ use.airports ~hat have·a functioning!· 

published, precision approach procedure; 

0 Pilot must add 100 feet to all instrument approach minimums; 

0 Ail 'circling approaches ati1ight are prohibited; 

O Pilots must add SO percent to· pilot operating handbook (POH) runway length performance for obstacle clearance 

on takeoff and landing under ambient conditions; · 

0 For IMC takeoff minimums, the pilot.must (lpply SO percent above the approach landing minimums (example: 

Baltimore-Washington International Airport minimum~ 200/1/2, then theta~eqff minimu~ms will b~.;:~t.le!lst 300 

feet and 3/4-statute-mile visibility); · · 

Patient Airlift Services,120 Adams~~~~~ F.;umingdale, 1\JY 11735 .. PALSMail@palservices.o·rg Fax:.6.31-755-tl84. 
Enhanced Affirm~tion for Fuel Reimbursement-Flights- 6:?5.2014 

Pilo.t: Missiorj No: Qate: 

Aircraft·engine,.propeller; and all components 

I hereby certify the following as to aircraft engine, propeller, and all components (please check): 

0 The aircraft engine, propeller, and all components.have not reached the airframe, engine, or propeller 

manufacturer's recommended time between overhaul: 

Passenger and medical crew briefing 

I here_by certify to provide the folloy./ing reqyifea passeng~r and medical crew briefing: 

./ The flight is being peril)lt~ed uhd~r a grant of e~em~ti_o[l to)?ALS .. P.A.LS is not a certificated commercial operator; 

./ When, where, and under what conditions smoking·is allowed; 

./ Use ofsafety belts, shoulder harnesses, an·d child restraint systems: 

./ When, where, ,and under whatconditions·it is necessary to have safety belts and, if installed1 shoulder harnesses, 

fastened; 

./ The placement of seat backs in c;~n upright position· b~fore takeoff and landing; 

./ Location and ml;!ans for".n6rmal<!ndemergency egress; 

./ :;location· of survival equipment; 

./ Use of normal and emergency oxygen, if installed; and -

./ Location and operation of fire extinguishers.-

In addition ll}_ere_by c;ertjfy-!ci e!'lsut_e th.e .f911b~t~lrig: -· 

3 

./ Pri~>r to t;!ach -ta~eoff, the.PIC~l,!St erisur~ that th~_p_cit!ent,who may need ttl~ assistance-of a·nother person to exit 

the aircra~ if an emergen_cy occurs, has receive~~ briefing~-~ to the procedures to be followe~ if an evacuation 

occurs. This paragraph does not !Jpply to a pers.on who has ti~en,given a briefing before a previous leg of a flight il'l 

'the same aircraft. ._.. • - ·· 

./ Tti'e pilot must ensure.that all passengers are restrained by FAA-approved seatbelts or FAA-apprqveg c-hil~ safety 

seat at ali times during the flight; Tlie only·exception shall be change ofseat'"pqsitions; qui_cblccess·t:o·lugga€fe, 

care and/or feeding of child, or use oflavatory; · · · 

./ Pilots will utilize and brief passengers on sterile cockpit procedures as defined· under§ 135.100. · 

Domestic ·operations 

I unders~a_nd this ~xemptiori for yuel reimbursem.~~~ appliesto-fligh~.s fOrid_uc~e~ Within-domestic United s~.ates ~irspe~ce. 

1 understand ·that the conditions ·and· limitations i~cluded .witli. the PALS ex~rnpti(>n, for 'fuel 

reimbursemenL are not based on specific regulations, but ·.are. the FAA's means of en·suring ·an 

_eqt,~ivaJent l.ev.~l of safety: !hi~ nec~ssitates limita!ion~ that go :bey~nd· the established_ r~~ulat.ions due 

to the 'fact that the propbs~d~ OP..er~~ibn is .PY its need:for ~-n·_exemption,_ outside _the: normal regl!latory 

structure.: I have. read an <;I unc:J~rs~Qod th_e .PALS·FAA exeinption~aild' I am in full. complia~ce· with all the 

conditions_ arid limitations.applicableeto,me.as,PIC.of.this flight.~· 

Pilot signature .. Airman Certificate· No -Mission. No Date 

Patient Airli~ Services, 12Q Ada !Tis Blvd~ Fai'IJ'liilgdale, NV 11735 ·. PALSMail@palservices.org Fax: 631-755-2-184 
Enhanced Affirm.ation:for Fuel Reimbur.semenHiights- 6.25_.2014 

4 

Pilot: Mission No: Date: 

Pre:-flight Risk Assessment Tool_ . - -- - . ,. . . - ---~ 

This Risk Assessment Tool cannot· guarantee a safe flight- safety is ultimately the re~po~sibility ofthe pilot. 

This ·risk. number should be used·to con.trol risk before a flight takes place. Ose/completion of.this tool 

replaces the Pilot Go/No-Go Checklist_. Utilization/completion of this tool'is mandatory. 

t!· 

0 

c; 

... 

~ 

c 

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... 

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Operating Environment 

1 No published approaches_ - -- -

. - .. -

2 Circling approac~ (best avai_labl~ approach) - - - -3 VOR/GPS/LOC/ ADF (Best approach availablew/o vertical guidance) 

4 No weather reporting at destination 

" 5 - Alternate airport not selected 

. 6 Uncontrolled airport . . 

.7 Control tower not6peratiorial'at ETA or ETD 

&. Mountainous airport 

;-1 Night operation _,. .. . -

2 Twilight operat!on' ' 

3 Winter operatiC?n .. 

4 Pop up trip (Less'than 4 hours crew notice) 

1 Stopping distance gr~ater than 80% of available runway 

2 Runway braking action less than good 

3 .Contaminated runway 

4 Wet runway ., 

- 1 Severe turbulence 

2 Icing (moderate-severe) 

3' Thuri~erstorms at departure and/or destination 

·4 Crosswinds greater than 15 knots 

5 Surface winds greater than 30 kl)ots 

6· l;leavy rain. at departure·~nd/or- destination -

7 Frozen precipitation at dep-ar:ture and/or qestination .. 

8 Ceiling & visibility at destin-ation less than 500ft. I 2 sm 

T9tal Factor Score-

* Cumulative risk factor score of :23 or above Command Pilot is 

required to consult with _Safety Committee member 

prior to Go/No Go decision. Contact: John Rochelle, Safety Committee Chair 

cell: 973-219-0100. 

--

COMPLETED TOOL MUST BE SENT TO PALS PRIOR TO DEPARTURE. 

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This docum_ent is to be signed and submitted to PALS aiong with all affirmations, waiver:s and W&B before each_ fuel reimbursem_entflight. 

Patient Airlift Services, 120Adams Blvd, Farmingdale, NY 11735_ PALSMail@palservices.org Fax: 631-755-2184 
---.:~~~7 ·MID·ISlAIID-,AI-J)··qs_~RVICE~-~ite::·:_; .: .·-l~-:~r.::).:, ?. -~· - F SE!HH~-G ;..u. YOl!R C£1QHi.M. AVMHO!f't:t,lr{}S:~~~l~C!;' l'ii.G ·. :.: :. [fi'iiili!iMil@f®~W ; ' . . . . ·< .· . . ~ ... ,. . . ·.- .. I ~ . . ---~.. "----~ --..:--.,..__,·,.,.--~~•rr•-:-=......--·.-:.~--r-..:--...-_·~~ 

PALS -lnitiai.'Pilot Training ·Course· Outline 

:For Parficipation in Fuel Reimbursement Program 

This program is designed to meeUexceed the requirements of FAA Exemption No. 

1 0294A, paragraphs 8 and 16, containing the applicable requirements of 14 CFR 

135.345. 

Fuel Reimbursement Training 

Introduction to the FAA waiver 

Aviation Safety Statistics & Analysis 

Accident Trends for General Aviation 

Risk and Hazard Identification 

Risk Mitig~tiol1 

Warning Against Complacency arid TechnologyDependemce 

Flight Planning 

Aerqnautical Decisic;m Making (ADM) 

Proper Fueling and Fuel Contamination 

Fuel Planning and Fuel Reserves 

Flight Planning Considerations for IFR Flight 

Navigqtion, Nqvigational aids 

Principles and Methods for Determjning 

Weight and Balance 

Takeoff and Landing Performance 

Runway Limitations 

Weather 

Fronts 

Pressure systems 

Clouds/Fog 

Precipitation 

Wind· 

Wind shear 

Turbulence 

Thunderstorms 

Icing 

Air Traffic Control System 

Procedure 

Phraseology 

VFR Into IMC 

Instrument Flying Technique 

Deficient IFH Technique 

Unusual Attitude Recovery 

Partial Panel 

Instrument Malfunction 

Mountainous Terrain 

Instrument Approaches 

Hazards on Approach 

. Most recent revision: June 2!?, ?014 
-.· 

Distraction 

Decent below DHIOA/MDA 

· Visual cues required 

Approach Disci~line 

Go Arounds and Missed Approaches . 

Landing and Landing Hazards 

Emergency Procedures.· 

Factors Affecting Flight Safety 

Single pilot IFR 

Night operations 

Mission mentality 

Distractions 

Missed approaches/go around 

Incomplete or stale weather briefings 

Communications 

Air Traffic Control 

·workload and time management 

Effects of fatigue 

Effects of stress 

ADM and judgement 

Mission Mentality/Pressure 

PALS .Exemption Requirements 

Pilot Rest 

Passenger Briefing 

Recurrent Training 

Aircraft Maintenance 

United States Airspace 

Flight Plan Requirement (Flight Locating) 

Airport Selection 

Approach Minimums 

Night Operations 

Takeoff/Landing. Performance 

IMC Takeoff Minimums 

Safety Belt Briefing 

Sterile Cockpit 

Go/No-'Go Checklist, Preflight Risk Assessment 

Most recent revision: June 25, 2014 
PALS Recurrent Pilot Training Course Outline 

For Participation in Fuel Reimbursement Program 

This program is designed to meet/exceed the requirements of FAA Exemption No. 

1 0294A, paragraphs 8 and 16, containing the applicable requirements of 14 CFR135.345, 

Initial Pilot training Review 

Accident Statistics and Analysis 

Accident Trends for General Aviation 

Risk .and Hazard Identification 

Risk. Mitigation 

Warning Against Complacency and Technology Dependence 

Preflight Preparation 

Flight Planning 

Principles and Methods for Determining 

W~ight and Balanc~ 

Takeo.ff and Landing Performance 

Runway Limitatfons 

Weather and Weather Hazards 

Thunderstorms 

Icing 

Wind 

Wind shear 

Turbulence 

Safe Operating Procedures Review 

Taxi 

Takeoff 

Climp 

Cruise 

Maneuvering Flight 

Instrument Flying Technique 

Deficient IFR Technique 

Unusual Attitude Recovery 

Partial Panel 

Instrument Malfunction 

Decent 

Instrument Approaches 

Hazard$ on Approaches 

Dis.traction 

Decent Below DHIDA/MDA 

Visual cues required 

Go Arounds and Missed Apprqaches 

Landings and Landing Hazards 

Emergency Procedures 

Most recent revision: .June 25, 2014 
Factors Affecting Flight Safety 

Single pilot IFR 

Night operations 

M_ission mentality 

Distractions 

Missed approaches/go around 

Incomplete or stale weather briefings 

Communications 

Air Traffic Control 

Workload and time management 

Effects of fatigue 

Effects of stress 

ADM and judgement 

Mission Mentality/Pressure 

PALS Exemption Requirements 

Pilot Rest 

Passenger Briefing 

Recurrent Trai_ning 

Aircraft M~intenance 

United States Airspace 

Flight Plan Requirement (Flight Locating) 

Airport Selection 

Approach Minimums 

Night Operations 

Takeoff/Landing Performance 

IMC Takeoff Minimums 

Safety Belt Briefing 

Sterile Cockpit 

Go/No-Go Checklist, Prefli_ght Risk Assessr:nent 

Mostrecent revision: Jun-e 25, 2014 

·'· 
U.S. Deportment 

of Transportation 

Federal Aviation 

Administration' 

June 19,2013 

Mr. Joseph Howley 

Chairman of the Board of Directors 

Patient AirLift Services, Inc. 

120 Adams Boulevard 

Farmingdale, NY 11735 

Dear Mr. Howley: 

Exemption No. 1 0294A 

800 Independence Ave .. S.W. 

Washinglon. D.C. 20591 

Regulatory Docket No. FAA-2011-0324 

This letter is to inform you that we have extended and amended Exemption No. 10294. ·It 

explains the basis for our decision, describes its effect, and lists the revised conditions and 

limitations. 

The Basis for. Our Decision 

By letter dated February 28, 2013, you petitioned the Federal Avi(!.tion Administration (FAA) 

on behalf of Patient AirLift Services, Inc. (PALS), for an exemption from § 61.113( c) of 

Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow for 

reimbursement of its volunteer pilots for fu~l costs incurred in conducting charitable flights. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that"were the basis for granting the original exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to PALS. 

AFS-13-297-E 
Our Decision 

The FAA hasmodified and/or added to the conditions and limitations of Exemption 

No.1 0294 to address several issues raised by another exemption holder. These changes were 

in order to cla,rify original content, and further define the intent and provide consistency of 

safety-related aspects of the conditions and limitations. 

Please note that the conditions and limitations included with an exemption are not based on 

specific regulations, but are the FAA's means ot;ensuring an equivalent level of safety. This . 1-

may necessitate limitations that go beyond thei'established regulations due to the fact that the 

proposed operation is by its need for an exerhption, outside the normal regulatory structure. 

Previous Condition/Limitation Nos. 1-4 and 6-14 have been edited for clarity or for 

standardization with other similar grants of exemption. 

Condition/Limitation 1 was added to re-enforce that this exemption is solely for charitable 

medical (Patient AirLift) flights. 

Condition/Limitation 2 was added to clarify PALS tax exemption requirements as noted in 

Public Law 112-95 Section 821. 

Condition/Limitation 3 was updated to ensure that PALS pilots meet qualification, training, 

and recurrency requirements along with ensuring that the operator is maintaining 

documentation. 

Condition/Limitation 4(h) was updated to require an instrument proficiency check or flight 

review within the previous 12 calendar months. This condition/limitation gives the FAA 

assurance that annual proficiency checking and testing (required in Condition/Limitation 9) 

will include a review of the basic requirements in§§ 61.56 or 61.57. · 

Condition/Limitation 8 (topics for the required initial pilot training program) has been 

modified to remove some redundant topics that are already covered in private pilot practical 

test standards and on required§ 61.57 flight reviews. · 

2 

Condition/Limitation 15 requires a transition to a preflight risk assessment tool, replacing the 

Pilot Go/No-Go Checklist. We made this change because we feel the preflight risk assessment 

tool offers a more effective evaluation of the pilots' readiness for flight. We are providing 

12 months to complete this transition. 

Condition/Limitation 16 requires a transition to an initial and recurrent ground training 

program based on the requirements of§ 135.345 .. We made this change because we feel these 

ground training themes (for air-taxi operations) are more comparable to your operation. We 

are providing 12 months to complete this transition. 
3 

Condition/Limitation 1 7 was added to ensure that the FAA General Aviation & Commercial· 

Division has the latest version of the preflight risk assessment tool and initiaVrecurrent ground 

training program. · 

Under the authority contained in 49 U.S.C. §§ 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Patient Airlift. Services Inc., an exemption 

from 14 CFR § 61.113( c) to the extent necessary to allow for reimbursement of its volunteer 

pilots for fuel costs incurred in conducting charitable flights, subject to the following revised 

conditions and limitations. 

Conditions and Limitations 

1. This exemption may be exercised only for charitable medical flights. Operations 

where PALS clients are not onboard for the purpose of obtaining medical care may not 

·be conducted under the terms of this exemption. 

2. PALS:must: 

a. meet the requirements described in section 501(c)(3) ofthe Internal Revenue 

Code of 1986 and be exempt from taxation undersection 501(a) of such Code; 

and, 

b. be organized for the primary purpose of providing, arranging, or otherwise 

fostering charitable medical transportation. 

3. PALS must ensure the following items are available to any representative ofthe FAA 

Administrator, upon request: 

a. A detailed description of PALS's process for verification of pilot qualification 

and training. This process must include a means to verify pilots' qualifications 

to act as pilot-in-command (PIC) prior to each flight; 

b. Documentation showing all PALS pilots' flight experience, airman certificate 

information, and currency ofF AA medical certificate; 

c. Documentation from each pilot showing that at the time he/she accepts a flight 

under this exemption, he/she meets all minimum standards and appropriate 

currency requirements established by PALS, part 61, and all conditions and 

limitations of this exemption; and 

d. Documentation of each flight and reimbursement containing the following 

information, at a minimum: 

1. Name and certificate number of the PIC; 

u. Name and identifier of the departure and arrival airports; 

u1. Name of all occupants of the airplane excluding the PIC; 

tv. Date and time of departure and arrival; and 

v. Amount·offuel reimbursement. 
e. All the documentation require9 under Condition No.3 must be maintained by 

PALS for a minimum of24 calendar months. 

4. All operating under the terms of this exemption must possess the following 

certificates, qualifications, and aeronautical experience -

a. An instrument rating or privilege (instrument privilege relates to the airline 

transport pilot certificate) that is appropriate to the aircraft being flown; 

4 

b. For the operation of any single-engine piston aircraft, a minimum total time of 

500 hours, with no less than 400 hours as pilot in command (PIC), and a 

minimum of 50 hours in the specific make and model of single-engine aircraft 

being flown; 

c. For the operating any multiengine aircraft, a minimum total time of 

· I ,000 hours as PIC in any aircraft, a minimum of 250 hours in multiengine 

aircraft, and a minimum of 50 hours in the make and model of multi engine 

aircraft being flown; . 

d. For the operation of any single- or multi engine turbine-powered aircraft, a 

minimum total time of 1,000 hours as PIC, a minimum of 100 hours in 

turbine-powered aircraft, and a minimum of 50 hours in the make and model of 

turbine-powered aircraft being flown; 

e. A minimum of 50 hours as PIC shall have been logged within the preceding 

12 calendar months immediately preceding the month of the flight; 

f. A minimum of 12 hours flown and logged, or 2 hours of dual flight training 

with a certificated flight instructor, within the preceding 3 calendar months 

prior to the month of the flight; 

g. ·A 2nd class medical certificate (per§§ 61.23(d)(2)(i) and 61.2); 

h. Within the preceding 12 calendar months, an instrument proficiency check 

(IPC) meeting the requirements of§ 61.57(d), or a flight review meeting the 

requirements found in§ 61.56(a). The IPC or flight review must consist of at 

least 1 hour of flight training and 1 hour of ground training. This requirement 

can substituted by a FAA practical test for any pilot certificate or rating; 

1. A current flight review (per§ 61.56(a)) in the same aircraft category, class, 

and type (if a type rating is required) being flown; 

J. Instrument current (per§ 61.57(c) or (d), as appropriate) in the same aircraft 

category, class, ari.d type (if a type rating is required) being flown; and 

k. For all operations under this exemption, the pilot must be current for night 

operations (per§ 61.57 (b)) in an aircraft ofthe same category, class, and type 

(if a type rating is required). 

5. All operations under this exemption must be in compliance with the following flight 

duty, rest, and flight time limitations: 

a. No pilot may fly more than 8 hours of flight time (per § 61.1) within any 

24-consecutive-hour duty day period; 
b. No pilot may perform a· duty day in excess of 12 consecutive hours. (A duty 

day starts when the pilot arrives at the airport and begins preparation for the 

flight and terminates upon completion of the post flight of the aircraft); and 

c. Once the pilot has performed 12 consecutive hours of duty, the pilot must rest 

a period of at least 12 hours before conducting another flight. 

6. Passenger and medical crew briefing requirements. Prior to each takeoff, the PIC 

must ensure that all passengers have been orally briefed on the followinga. The flight is being permitted under this grant of exemption and'that the 

operator is not a certificated commercial operator; 

b. When, where, and under what conditions smoking is allowed; 

c. Use of safety belts, shoulder harnesses, and child restraint systems: When, 

where, and under what conditions it is necessary to have his or her safety belt 

and, if installed, his or her shoulder harness fastened about him or her; 

5 

d. The placement of seat backs in an upright position before takeoff and landing; 

e. Location and means for normal and emergency egress; 

f. Location of survival equipment; 

g. Use of normal and emergency oxygen, if installed; and 

h. Location and operation of fire extinguishers. 

7. Prior to each takeoff, the PIC must ensure that the patient, who may need the 

assistance of another person to exit the aircraft if an emergency occurs, has received a 

briefing as to the procedures to be followed if an evacuation occurs. This paragraph 

does not apply to a person who has been given a briefing before a previous leg of a 

flight in the same aircraft. 

8. PALS must establish an initial pilot training program tha~ includes the following 

elements. All pilots must complete this training program: prior to conducting flights 

under this grant of exemptiona. Risk, hazard identification; 

b. Accident trends for general aviation aircraft. 

c. Flight planning and aeronautical decision-making: 

1. Improper pre-flight planning. 

n. Insufficient fuel reserves. 

111. Aircraft systems. 

1v. Improper operation of fuel system. 

v. Fuel contamination. 
Vl. Improper fueling. 

vn. Weather and continued visual flight rules into instrument 

meteorological conditions. 

vnt. Descending below minimum descent altitude on approach. 

tx. Mountainous terrain. 

x. Icing. 

d. Other factors: 

t. Single pilot IFR; 

n. Night operations at unfamiliar airports; 

111. MissiOI1 mentality; 

tv. Pressure to complete flight operations; 

v. Distractions; 

vt. Missed approach/go around; 

vn. Incomplete/stale weather briefings; 

vm. Communications processes; decisions, and coordination, to include 

communication with air traffic control and passengers; 

tx. Workload and time management; 

x. Situational awareness; 

xt. Effects of fatigue on performance, avoidance strategies and 

countermeasures; 

xn. Effects of stress and stress reduction strategies; and 

xnt. Aeronautical decision-making and j udgmerit. 

9. Recurrent training is required for all pil~ts operating under the terms of this 

exemption. The annual recurrent training program must include: 

6 

a. Verification that each pilot is adequately trained, current, and proficient on all 

of the elements in the PALS initial pilot training program; and 

b. Testing to determine each pilot's aeronautical knowledge, proficiency with the 

aircraft, and the limitations.ofthis exemption. 

10. Each aircraft operated under this exemption must have a standard airworthiness 

certificate. 

11. All maintenance except when complying with the provisions of 14 CFR § 43.7(f) and 

Appendix A, preventive maintenance items conducted on aircraft operated under this 

exemption must be performed by an FAA-certificated mechanic, repairman, or repair 
7 

station. The aircraft engine, propeller, and all components must be overhauled prior to 

reaching the airframe, engine, or propeller manufacturer's recommended time between 

overhaul. 

12. This exemption applies to flights conducted within domestic United States airspace. 

PALS may exercise this relief for overflights within the territory and airspace of a 

foreign country only with the specific permission of the foreign civil aviation 

authority. 

13. All pilots operating under this exemption must comply with the following 

requirements: 

a. All flights operated under this exemption must activate an IFR flight plan. The 

earliest the flight plan may be canceled is upon acceptance of a visual approach 

cleararice from air traffic control; 

b. For flights in instrument meteorological conditions (IMC), each pilot may only 

use airports that have a functioning, published, precision approach procedure; 

c. Pilot must add 100 feet to all instrument approach minimums; 

d. All circling approaches at night are prohibited; 

e. Pilots must add 50 percent to pilot operating handbook (POH) runway length 

performance for obstacle clearance on takeoff and landing under ambient 

conditions; 

f. For IMC takeoff minimums, the pilot must apply 50 percent above the 

approach landing minimums (example: Baltimore-Washington International 

Airport minimums 200/1/2, then the takeoff minimums will be at least 300 feet 

and 3/4-statute-mile visibility); . 

g. The pilot must ensure that all passengers are restrained by FAA-approved seat 

. belts or FAA-approved child s~fety seat at all times during the flight. The only 

exception shall be change of seat positions, quick access to luggage, care 

and/or feeding of child, or use of lavatory; and 

h. Pilots will utilize and brief passengers on sterile cockpit procedures as defined 

under§ 135.100. 

14. Pilots must use the PALS Go/No-Go checklist, patient, passenger, pilot release forms, 

and post-flight report. The completed checklist must be transmitted to PALS prior to 

conducting a flight under this exemption. The completed checklist must be retained 

. by PALS for a minimum of three days. The Go/No-Go checklist will consist of at 

least the following information: 
8 

Pilot Go/No-Go Checklist 

EXCELLENT OK MARGINAL PooR 

Pilot 

Physical health 0 0 0 0 

Mental health 0 0 0 0 

Prepared/Confident 0 0 0 ·o 

Well rested 0 0 0 0 

Aircraft 

Maintenance 0 0 0 0 

Fuel reserve 0 0 0 0 

Pre-flight 0 0 0 0 

Equipment sufficient for the 0 0 0 0 

flight conditions 

Weight and balance Takeoff weight/CO 

Landing weight/CO 

EXCELLENT OK MARGINAL POOR 

Weather 

Current & WX Forecast 0 0 0 0 

Conditions 

Departure 0 0 0 0 

Destination 0 0 0 0 

Return 0 0 0 0 
9 

Explain if Marginal or Poor: 

YES No 

Child safety seat 

Passengers briefed 

Pre-departure·weather briefing 

Verify departing on correct runway 

Release forms signed 

Flight# 

Pilot Signature 

Date 

The checklist must be provided to the exemption holder or left with a responsible person, such 

as a fixed-base operator, prior to conducting a flight under this exemption. The completed 

checklist must be retained for 3 days. 
-. 

10 

15. PALS must develop and implement a preflight risk assessment tool to supplement or 

replace the Go/No-Go checklist within 12 calendar months of the date of issue of this 

exemption. Once implemented, use 9f the preflight risk assessment tool will 

supersede the requirements of Condition No. 14. The tool must be completed by the 

PIC before each flight and must be transmitted to PALS prior to takeoff for any flight 

operated under this exemption. The completed tool must be retained by PALS for a 

minimum of three days. A sample risk assessment tool is available at FAA 

Information for Operators (InFO) 07015: 

http://www.faa.gov/other _visit/aviation _industry/airline_ operators/airline_ safety/info/ 

all_infos/media/2007 /inF0070 15.pdf. 

16. Within 12 calendar months of the date of issue of this exemption. PALS must develop 

and implement an initial and recurrent ground training program that contains the 

requirements of§ 135.345 that are applicable to the PALS operations. This program 

will supplement or replace the requirements of Condition No. 8. Once implemented, 

use of the new initial and recurrent training program will supersede the requirements 

of Condition No. 8. 

17. PALS must ensure that the latest version of its preflight risk assessment tool 

(Condition No. 15) and the initial/recurrent ground training program (Condition No. 8 

and 16 are sent to the FAA Airman Certification and Training Branch, 800 

Independence Ave SW, Washington DC 20591 or via e-mail to 9-AFS-800-

Correspondence/ AW AIF AA. These two documents must be clearly labeled to identify 

the most current version. 

This exemption terminates on June 30, 2015, unless sooner superseded or rescinded. 

Sincerely, 

~~. 

{) John M .. Allen 

Director, Flight Standards Service 
' '1. ,, ~ 

US. Department 

of Transportotion 

Federal Aviation 

Administration 

June 22, 2011 

Mr. Joseph Howley 

Chairman of the Board of Directors 

Patient AirLift Services~ Inc. 

120 Adams Boulevard 

Farmingdale, NY 11735 

Dear Mr. Howley: 

Exemption No. l 0294 

800 Independence Ave .. S.W. 

Washington. D.C. 20591 

Regulatory Docket No. FAA-2011-0324 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated March 24,2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Patient AirLift Services, Inc. (PALS), for an exemption from § 61.113( c) of Title 14, 

Code of Federal Regulations (14 CFR) to the extent necessary to allow for reimbursement of 

its volunteer pilots for fuel costs incurred in conducting charitable flights. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to PALS. 

· The FAA has issued grants of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption Nos. 10009 and 10019 (copies 

enclosed), the FAA found that the humanitarian efforts of these pilots who volunteer their 

time and piloting services are commendable, and the FAA wants to encourage this kind of 

volunteerism and public service for the common good of our citizens. The FAA recognizes 

the fact of rising costs for fuel and aircraft operating expenses; however, when money is 

exchanged for transportation, the public expects, and the FAA has a duty to demand, a higher 

level of safety for the flying public. The FAA believes by requiring the petitioners and their 

AFS-11-314-E 
·" 

pilots to comply with the conditions and limitations set forth in this grant of exemption, the 

FAA can ensure that a higher level of aviation safety for the flying public will be maintained. 

Having reviewed your reasons for requesting an exemption, I find that2 

• they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption Nos. 10009 and 100 19; 

• the reasons stated by the FAA for granting the enclosed Grant of Exemption Nos. 10009 

and 10019 also apply to the situation you present; and 

• a grant of exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Patient AirLift Services, Inc., an exemption from 

14 CFR § 61.113( c) to the extent necessary to allow for reimbursement of its volunteer pilots 

for fuel costs incurred in conducting charitable flights, subject to the conditions and 

limitations described below. 

Conditions and Limitations 

1. The exemption holder must have in place the following: 

a. A' structured and documented pilot registration process that has an annual 

renewal requirement and ensures that only qualified pilots who are registered 

and trained conduct charitable flights. This process must include a means to 

verify registration prior to flight; 

b. On-file documentation authenticating registered pilots' experience, ratings, 

FAA physical, and any other information pertinent to the pilots' qualifications; 

c. A system that registers the pilot's assertion, at the time he/she accepts a flight 

to accomplish, that he/she meets all minimum standards and appropriate 

currency requirements established by the FAA and all conditions and 

limitations set forth in this exemption and will conduct the flight in accordance 

with all applicable Federal regulations; and 

d. A file of all flight and reimbursement records that must be made available to 

the FAA for viewing at a designated office site location. Records shall be kept 

a minimum of 2 years. 

2. The FAA may, at any time or place, conduct inspections of the pilot(s) and aircraft 

being flown in accordance with this exemption. 

3. All pilots must possess the following qualifications and aeronautical experience, as 

appropriate: 
3 

a. Must hold an instrument rating or privilege (i.e., instrument privilege relates to 

the airline transport pilot certificate) that is appropriate to the aircraft being 

flown; 

b. For the operation of any single-engine piston aircraft, the pilot shall have a 

minimum total time of 500 hours, with no less than 400 hours as pilot in 

command (PIC), and a minimum of 50 hours in the speci:(tc make and model of 

single-engine aircraft being flown; 

c. For the operation of any multiengine aircraft, a minimum total time of 1,000 

hours as PIC, a minimum of 250 hours in multi engine aircraft, and a minimum 

of 50 hours in the specific make and model of multi engine aircraft being flown; 

d. For the operation of any turbine-powered aircraft, a minimum total time of 

1,000 hours as PIC, a minimum of 100 hours in turbine-powered ·aircraft, and a 

minimum of 50 hours in the specific make and model of turbine-powered 

aircraft being flown; 

e. A minimum of 50 hours as PIC shall have been flown and logged within the 

preceding 12 calendar months immediately preceding the month of the flight; 

f. Minimum of 12 hours flown and logged, or 2 hours of dual flight training with 

a certificated flight instructor, within the preceding 3 calendar months prior to 

the month of the flight; 

g. Must hold a 2nd class medical certificate (per§§ 61.23(d)(2)(i) and 61.2); 

h. Must have a current flight review (per§ 61.56(a)) in the same aircraft category, 

class, and type (if a type rating is required) being flown; 

1. Shall be instrument-current (per§ 61.57(c) or (d), as appropriate) in the same 

aircraft category, class, and type (if a type rating is required) being flown; 

J. Within the preceding 3 calendar months prior to the flight, the pilot(s) must 

have logged at least three takeoffs and three landings to a full stop in the same 

aircraft category, class, and type (if a type rating is required) being flown. 

However, this condition may be accomplished by logging at least three takeoffs 

and three landings to a full stop at night within the preceding 3 calendar 

months in the same aircraft category, class, and type (if a type rating is 

required) being flown; and 

k. For all operations under this exemption, the pilot must be current for night 

operations (per§ 61.57 (b)) in an aircraft of the same category, class, and type 

(if a type rating is required). · 
4. Flight duty, rest, and flight time limitations: 

a. No pilot may fly more than 8 hours of flight time (per § 61.1) within any 24-

consecutive-hour duty day period; 

4 

b. No pilot may perform a duty day in excess of 12 consecutive hours (a duty day 

starts when the pilot arrives at the airport and begins preparation for the flight 

and terminates upon completion of the post flight of the aircraft); and 

c. Once the pilot has performed 12 consecutive hours of duty, the pilot must rest a 

period of at least 12 hours before conducting another flight. 

5. Passenger and medical crew briefing requirements: Prior to each takeoff, the PIC must 

ensure that all passengers have been orally briefed on the following: 

a. The flight is being permitted under this grant of exemption and that the 

operator is not a certificated commercial operator; 

b. Smoking: When, where, and under what conditions smoking is allowed; 

c. Use of safety belts, shoulder harnesses, and child restraint systems: When, 

where, and under what conditions it is necessary to have his or her safety belt 

and, if installed, his or her shoulder harness fastened about him or her; 

d. The placement of seat backs in an upright position before takeoff and landing; 

e. Location and means for opening the passenger entry door and emergency exits; 

f. Location of survival equipment; 

g. Use of normal and emergency oxygen installed; 

h. Location and operation of fire extinguishers; and 

1. Prior to each takeoff, the PIC must ensure that the patient, who may need the 

assistance of another person to exit the aircraft if an emergency occurs, has 

received a briefing as to the procedures to be followed if an evacuation occurs. 

6. Pilot training: The exemption holder must establish an initial pilot training program 

that includes the following elements. All pilots·must complete this training program 

prior to conducting flights under this grant of exemption: 

a. Risk, hazard identification; 

b. Accident trends and factors for general aviation fixed wing under 

12,500 pounds; 

c. Current edition of the Aircraft Owners and Pilots Association Air Safety 

Foundation Nail Report; 

d. High risk phases of flight--

i. Takeoff and climb; 
u. Takeoff stall/settling; 

u1. Loss of airspeed resu~ting in nonrecoverable stall or sink rate; 

1v. Loss of control; and 

v. Crosswinds/other conditions leading to loss of directional control; 

e. Maneuvering--

!. Stall qr los~ of control; and 

11. Loss of airspeed resulting in stall/spin; 

f. Descent/approach: Beginning of descent from cruise altitude to missed 

approach point or runway threshold; 

g. Stalls/spins; 

h. Loss of airspeed; 

1. Collisions with objects, terrain; 

J. Loss of engine power; 

k. Carburetor icing (if appropriate, for the aircraft the pilot is assigned to fly); 

l. Incorrect fuel mixture; 

m. Wind gusts or wake turbulence; 

n. Landing--

!. Loss of directional control; 

11. Crosswinds; 

111. Inadequate airspeed control; 

IV. Stalls, hard landing, short-long touchdown; 

v. Runway conditions; and 

v1. Runway contamination; 

o. Flight planning and decisionmaking--

1. Flight planning; 

11. Improper pre-flight planning; 

111. Insufficient fuel reserves; 

IV. Inadequate in-flight monitoring of ground speed; 

v. Systems operation; 

v1. Improper operation of fuel system; 

5 
vu. Fuel contamination; 

vm. Improper fueling; 

IX. Weather; 

6 

x. Continued visual flight rules into. instrument meteorological conditions; 

XL Deficient instrument flight rules (IFR) technique; 

xu. Failure to follow appropriate IFR procedures; 

XIII. Descending below minimum descent altitude on approach; 

x1v. Thunderstorm; 

xv. Flying too close or penetrating turbulence; 

xv1. High winds; 

xv11. Mountainous terrain; 

XVIII. Icing; 

XIX. Loss of lift and performance; and 

xx. Instrument malfunction; 

p. Other factors--

1. Single pilot IFR; 

11. Night operations at unfamiliar airports; 

111. Mission mentality; 

IV. Pressure to complete flight operations; 

v. Distractions; 

v1. Missed approach/go around; 

VII. Incomplete/stale weather briefings; 

vu1. Communications processes, decisions, and coordination, to include 

communication with air traffic control and passengers; 

IX. Workload and time management; 

x. Situational awareness; 

xi. Effects of fatigue on performance, avoidance strategies and 

countermeasures; 

xu. Effects of stress and stress reduction strategies; and 

XIII. Aeronautical decisionmaking and judgment. 
7. Recurrent training: An annual recurrent training program must ensure: 

a. The pilot remains adequately trained, current, and proficient regarding all of 

the elements contained in the exemption holder's training program; 

b. Recurrent training must include testing to determine the crewmember's . 

knowledge of the aircraft and the exemption holder's program; and 

c. Recurrent flight training sufficient to satisfactorily complete the recurrent 

proficiency flight check. 

8. Aircraft requirements: Each aircraft must have a standard airworthiness certificate. 

7 

9. Aircraft maintenance: All maintenance must be performed by a certificated mechanic, 

repairman, or repair station. Aircraft components must be overhauled prior to reaching 

manufacturer's recommended time between overhaul. 

10. Areas of operations: All flights must remain within domestic United States airspace. 

11. All pilots must adhere to the following best practices policies of the exemption holder 

which are: 

a. In instrument meteorological conditions (IMC) conditions, each pilot must plan 

to land at airport with a precision approach; 

b. Each pilot must add 100 feet to all instrument approach minimums; 

c. For night landings, the pilot shall use runways with functional vertical 

guidance (visual approach slope indicator, precision approach path indicator, 

instrument flight system); 

d. Pilot will not attempt circling approaches at night; 

e. Add 50 percent to pilot operating handbook runway length performance to 

clear the obstacle for takeoff and landing under ambient conditions; 

f. For IMC takeoff minimums, the pilot must apply 50 percent above the 

approach landing minimums (example: Baltimore-Washington International 

Airport minimums 20011/2, then the takeoff minimums will be at least 300 feet 

and 3/4-statute-mile visibility); 

g. If destination is unfamiliar, the pilot must obtain briefing from a pilot or fixedbase operator with experience with that airport prior to flight; 

h. Pilots are requested to use nonpunitive report process to communicate any and 

all situations when safety of flight was compromised; 

1. Pilots are requested to provide feedback on weather, airports, air traffic control, 

other pilots, etc., that could compromise safety for future flights; 

J. The pi lot must ensure that all passengers are restrained by FAA -approved 

seatbelts or FAA-approved child safety seat. The only exception shall be 
.· 

change of seat positions, quick access to luggage, care and/or feeding of child, 

or use of lavatory; 

k. Pilots will consult all available weather products, wind sock, etc., to verify 

departure will be from the correct runway relative to wind conditions; 

I. Pilots will utilize computer devices and reading material only as these are 

pertinent to safe operation of the flight and will refrain from any and all 

distractions that could compromise safety of flight; and 

m. Pilots will utilize and brief passengers that a sterile cockpit condition exists 

during taxi and takeoff until reaching cruise altitude and also during descent 

from cruise altitude, descent, approach, landing, and taxi to ramp. 

12. Pilots must complete and adhere to the Go/No-Go checklist, patient, passenger, copilot release forms, and post-flight report. The Go/No-Go checklist will consist of at 

least the following information: 

Pilot Go/No-Go Checklist 

EXCELLENT OK MARGINAL POOR 

Physical health 0 0 0 

Mental health 0 0 0 0 

Prepared/Confident 0 0 0 0 

Well rested 0 0 0 0 

Aircraft 

Maintenance 0 0 0 0 

Fuel reserve 0 0 0 0 

Pre-flight 0 0 0 0 

Equipment sufficient for the o 

flight conditions 

0 0 0 

Weight and balance Takeoffweight/CG ________ _ 

Landing weight/CO ________ _ 

8 
9 

EXCELLENT OK MARGINAL POOR 

Weather 

Current & WX Forecast 0 0 0 0 

Conditions 

Departure 0 0 0 0 

Destination 0 0 0 0 

Return 0 0 0 0 

Explain if Marginal or Poor: 

YES No 

Child safety seat 

Passengers briefed 

Pre-departure weather briefing 

Verify departing on correct runway 

Release forms signed 

Flight# 

Pilot Signature 

Date 
,, . . ,· 

10 

The checklist must be provided to the exemptiol! holder or left with a responsible person, such 

as a fixed-base operator, prior to conducting a flight under this exemption. The completed 

checklist must be retained for 3 days. 

13. Flight locating procedures required: The pilot must file and activate an IFR flight plan 

for each flight. The flight plan may be canceled up_on acceptance of a visual approach 

clearance from air traffic control. 

This exemption terminates on June 30, 2013, unless sooner superseded or rescinded. 

Sincerely, 

Melvin Cintron 

Acting Deputy Director, Flight Standards 

Service 

Enclosures