To:John Linsenmeyer

FAA Flight Standards Service, AFS-810

From: Matt Weisman

Alameda County Sheriff’s Air Squadron

Subject: Response to your questions

In re Petition for Exemption Docket Number FAA-2013-0167

Date: March 26, 2013

In response to your request for specific description of the prospective transport flights 

that would be within the Petition Exemption, we are providing the following:

 The context of the scope of activities of the Alameda County Sheriff’s Office

 Examples of flights that may be authorized.

 Examples of flights that would not be authorized. 

 Associated reimbursable and non reimbursable expenses for authorized flights.

 Additional information on the tax status of the Alameda County Sheriff’s Air 

Squadron.

We will be pleased to provide further clarifications as needed by the FAA. If you would 

like to speak to me, my telephone number is 415-377-9123.

Thank you for your timely attention to and review of our Petition.

Request: More information describing an ACSAS-sanctioned mission, beyond 

the description included in your petition. What would be most helpful is an list of 

the types of missions authorized and those that would not be authorized. Please 

make your response as specific as possible. 

Context:

The activities of the Alameda County Sheriff’s Office (ACSO) that will generate a 

need for air transportation requests to the Alameda County Sheriff’s Air Squadron 

(ACSAS) are as follows. 

The ACSO is a law enforcement agency established under the California 

Constitution. The Sheriff is an elected official of the County of Alameda, California. 

The ACSO has approximately 1600 personnel. The ACSO is a member of several 

associations that govern law enforcement accreditations. The ACSO is among the 

top accredited law enforcement agencies in the U.S. and holds the following 6 

accreditations.

• Commission on Accreditation for Law Enforcement Agencies (CALEA) 

Accreditation against 459 benchmarks. In 1996, the Sheriff’s Office was the first 

California agency to be CALEA accredited and has been reaccredited every 

three years since.
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• CALEA Award for Excellence In July of 2011, the ACSO was the first California 

law enforcement agency and one of only seventeen throughout the U.S., to 

receive this award.

• American Correctional Association

• National Commission on Correctional Health Care

• American Society of Crime Laboratory Directors

• Explosive Ordnance Disposal

• National Sheriff’s Association Triple Crown Award 

The ACSO is the Region II Mutual Aid Coordinator for the State of California. Region 

II is the most active Mutual Aid Region within the State of California. The Sheriff 

routinely responds to requests for assistance in the form of Search & rescue 

personnel, Search or Cadaver dogs, E.O.D Technicians or SWAT personnel. Mutual 

Aid requests are generally short notice requests for aid that require rapid response

that may require travel to locations not served by nearby commercial airlines or not 

with frequent flights or with direct flights.

ACSO personnel participate in recurrency and specialized training programs that 

may require advance notice travel to locations not served by nearby commercial 

airlines or not with frequent flights or direct flights. ACSO management attend 

conferences held by accreditation associations and specialized law enforcement 

related conferences that may require travel to locations not served by nearby 

commercial airlines or not with frequent flights or direct flights.

Flight Authorization Process: 

1. For a transportation request to become a sanctioned mission an individual within 

the Sheriff’s Office command structure would either initiate the request for 

transportation or approve and transmit the request for transportation. 

2. The authorizing ACSO manager would normally send the request for transport by 

the Alameda County Sheriff’s Air Squadron (ACSAS) to the Alameda County 

Sheriff’s Office of Homeland Security and Emergency Services (OHSES) to the 

on duty supervisor. 

3. The on duty supervisor, following the OHSES Policy and Procedures, would

transmit the transportation request to the Air Squadron’s Liaison Officer (ASLO), 

who is a paid employee of the Sheriff’s Office, and to the Air Squadron 

Commander, who is a volunteer member of the Squadron. The Squadron 

Commander is elected by the Squadron membership. The Squadron’s flight 

authorization process is carried out in accordance with the Squadron’s published 

Policies and Procedures that are incorporated in the Squadron’s Petition for 

Exemption. 
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Squadron Membership: 

1. Applicants for membership in the Air Squadron must meet a set of requirements 

for membership specified in the Squadron’s By-Laws. In addition, applicants 

receive background checks conducted by the Sheriff’s office. 

2. After the completion of the background check and with no disqualifying findings, 

the volunteer is sworn in as a Disaster Service Worker for the Office of the 

Emergency Services of the State of California and swears to defend the Federal 

and California State Constitutions. 

3. Air squadron volunteers perform as emergency services volunteers for the

OHSES. 

4. There is a one-year probation period before a permanent identity card is issued 

as a Sheriff’s Emergency Services worker.

5. There are ACSAS meeting and training attendance requirements. 

6. Members pay annual dues and special assessments.

7. Members are not paid for their services.

8. Members are required to have uniforms and receive a uniform allowance from 

the County of Alameda.

Examples of Transport Flights to be flown and not flown.

The following examples of transport flights are based upon the actual activities of the 

Sheriff’s Office. The flights are, however, prospective examples of how the Air Squadron 

would provide air transport to the ACSO. All flights will be conducted in compliance with 

the ACSAS Policy and Procedures.

Example 1. Pursuant to an ACSO investigation, the Captain of the Eden 

Township sub-station which is the Sheriff's Office Criminal Division headquarters,

might on a Monday request to OHSES the transport on Thursday of two 

investigators to the nearest suitable airport to the State Prison at Tehachapi, CA. 

The investigators are to conduct an interview of an in-custody prisoner regarding 

an on-going investigation or active case. Many of California State Prisons are not 

located with easy access of an airport with frequent Commercial Air Carrier 

service and driving time each way to the prison may consume several hours. 

The investigators would depart at 08:00 am on a Squadron flight from (OAK) to 

Tehachapi, CA (TSP). By car, this is 4hr 30min each way trip. Depending upon 

the aircraft used, this is an approximate 2 hr flight. The aircraft arrives at TSP at 

10:00am where a car from the prison is waiting for the investigators. ACSAS 

aircraft and crew waits at TSP for 2hrs 30min while the investigators go to the 

prison, conduct the interview, have a quick lunch, and return to TSP. The 

ACSAS aircraft departs TSP at 1:00 pm and returns with the investigators to 

OAK at 3:00pm. 
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Example 2. Pursuant to a mutual aid agreement, an urgent request is made to 

the Sheriff, Under Sheriff, an Assistant Sheriff, or a Division Commander to 

provide a bomb sniffing dog and a handler to San Luis Obispo, California. The 

request is approved by the ACSO, then the dog handling unit and the Office of 

Homeland Security and Emergency Services (OHSES) would be notified. In turn 

the Air Squadron would be notified by the on duty supervisor at the OHSES.

Subject to compliance with the Squadron’s policy and procedures, an available 

qualified crew would be assigned to the flight by the Squadron Commander. The 

flight would depart with a bomb sniffing dog and handler from the airport nearest 

to the OHSES which airport is Livermore, LVK . The aircraft crew upon arriving 

at LVK would brief the trip, prepare and file the flight plan, pre-flight check the 

aircraft, and wait for the dog and handler to arrive. Following the ACSAS 

Procedures, the dog would be secured in the aircraft and the handler briefed. 

The destination airport would be SBP. Depending upon the expected duration of 

the canine team activities at San Luis Obispo, the aircraft and crew might remain 

overnight at SBP or subject to the Squadron’s Policy and Procedures the aircraft 

and crew might return that same day to LVK.

Please note that the Policy and Procedures submitted as part of the Petition for 

Exemption, identify the requirements and procedures for the safe transportation 

of the dog and trainer

Example 3. The Transport of Sheriff's Office personnel to Law Enforcement 

Conferences or training events. The Sheriff's Office is an accredited Law 

Enforcement agency by the Commission on Accreditation of Law Enforcement 

Agencies, or CALEA. CALEA requires annual training as well as attendance at

law enforcement related conferences often hosted by a Sheriff’s Office in another 

State.

Example 4. The Sheriff's Office is in possession of various types of specialized 

equipment. The specialized equipment is critical to the accomplishment of the 

mandated services provided by the Sheriff's Office, and may be requested by a 

Mutual Aid agency. Transport by the Air Squadron may be appropriate when the 

equipment is needed urgently. The Squadron can also facilitate the return of 

specialized equipment borrowed by the Sheriff's Office on a special event basis.

Examples of flights that would not be authorized are as follows:

Example A. Personal transportation for a non-County or non-Sheriff’s Office 

related purpose such as transport for the purpose of going on vacation to his/her 

vacation destination.

Example B. Carriage of hazardous materials for which the Squadron is not 

authorized to carry or the available aircraft is not properly equipped or the crew 

properly trained.
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Example C. Transportation for which there are frequent and direct commercial air 

carrier flights with seat availability for those travelling.

Request: As specific a list as possible of the expenses you seek reimbursement 

for under the privileges of your proposed exemption. 

In Example 1 above, landing/takeoff fees, parking/transient fees, aircraft fuel, 

aircraft oil, any other aircraft consumables or special supplies required by the trip, 

crew out of pocket expenses reimbursable by the ACSO or ACSAS such as meal 

expense while travelling.

In Example 2 above, in addition to the expenses listed in Example 1, reimbursed 

expenses may include ground transportation, lodging at the destination, and 

depending upon weather or security requirements overnight transient hangar fee.

The above expense examples are illustrative of the type of direct expenses 

associated with a flight and that are proposed to be reimbursed. However, the 

listed expenses are not an exhaustive list of all direct expenses that might be 

associated with a flight. 

Request: Information about ACSAS's federal tax status, if any.

The IRS determined that the Alameda County Sheriff’s Air Squadron is exempt from 

Federal Income Tax under Section 501 (c) 4 of the Internal Revenue Code. The 

effective date of the exemption was May 15, 2010. Our Employer Identification Number 

is 94-6107783.

The Franchise Tax Board of the State of California determined by letter dated October 

15, 1956 that the Alameda County Air Squadron was exempt from State Franchise tax 

under the provisions of Section 23701 g of the Revenue and Taxation Code of the State 

of California. Our State ID is 0328341.

The Air Squadron is in the process of applying for a change in our Federal Tax status to 

Section 501(c) 3 of the Internal Revenue Code.