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 interpreted by the FAA's Flight Standards Service in internal guidance to Principal Operations Inspectors. HALO-Flight is seeking immediate reliefto the extent necessary to allow HALO-Flight to perform instrumentflight rules (IFR} departures and approach procedures (lAP) 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 of9 seats or less (excluding any pilot seat) . Consistent with HALO-Flight Operations Specifications the requested exemption, ifgranted, will be limited as follows: A. The exemption would apply to operations of HALO-Flight helicopters with a passenger seating configuration of9 seats or less (excluding any pilot seat}, listed in ourOperations Specifications when - 1. Current weather reports orforecasts indicate thatthere is no reasonable possibility ofthunderstorms orother severe weather expected to exist at the destination, alternate or along the route to be flown forthe period oftime planned forthe flight; and2. Additional preflight planning is triggered by the HALO-Flight Preflight Risk Assessment Program that must be completed before the first leg ofeach HelicopterAir Ambulance Operation (HAAO}, conducted underSection 135.611. B. For aflight to be conducted under Section 135.611, the additional weather briefing, flight monitoring and related training actions described below must be taken. These actions are described in the HALO-Flight General Operations Manual and Approved Training Programs. 1. Additional Weather Briefing Requirements for Flights Under Section 135.611 • The pilot will use information obtained from the National Weather Service to determine thatthere is no reasonable possibility ofthunderstorms or other severe weather conditions expected to exist at the destination, alternate oralong the route to be flown forthe period oftime planned forthe flight;
• The following aviation weather products must be reviewed in making that determination; AIRMET, SIGMET, CONVECTIVE SIGMET, METAR, REGIONAL NEXRAD, NOTAM, PIREP, and TAF; and- • No IFR operation under Section 135.611 will be released ifcurrent weather reports orforecasts indicate the potential forthunderstorms or other severe weather to exist at the destination, alternate or along the route to be flown forthe period oftime planned forthe flight. Ifsuch potential exists, the pilot must refuse the flight. 2. Flight monitoring by the Operations Control Center The HALO-Flight Operations Control Center continuously monitors all flights forthunderstorms and severe weather and provides that information to the pilot by: 1843 FM 665 Corpus Christi, TX 78415 361-265-0509• Contacting the pilot directly via satellite phone; or • Contacting the pilot directly overVHF or UHF radio. The Operations Control Center provides general advice such as, "there are thunderstorms to your west-- recommend you divertto the east." 3. Training for our pilots and operations control 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 radarfeeds (2.0 hours) d. SIGMETS and AIRMETS (2.0 hours) e. METARS and TAFS's (2.0 hours) f. Interpretation and appropriate use ofavailable cockpit weather displays (2.0 hours) g. The applicability and use ofthis exemption (1.0 hours) Granting the Requested Exemption would Enhance Safety and is in the Public Interest HALO-Flight maintains 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. HALO-Flight believes that, by granting this petition, the FAA will permit an alternate means ofcompliance that is an equivalent level ofsafety as provided by Section 135.611(b) to be maintained and will be acting in a manner consistent with the aviation safety goal ofSection 135.611. HALO-Flight believes that the true mitigation ofthe risk ofoperations in areas ofsevere weather lies in effective and consistent preflight planning and training for its pilots and operational control oversight by the certificate holder. Ifthis exemption is not granted itwould negatively affect the public interest by reducing the number ofavailable HAA flights. Afully trained crew, following proper IFR procedures, in a properly equipped aircraft, can only enhance safety. The underlying purpose ofSection 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. The recent interpretation ofthe rule instead has the unintended consequence ofencouraging HAA operators to fly in marginal weather conditions underVFR because the interpretation requires Airborne Weather Radar or Lightning Detection Equipment. HALO-Flight is committed to the safe and successful completion of its air medical flights and believes that it is saferto file an IFR flight plan and to operate under IFR than to conduct flight operations underVFR in marginal visual meteorological conditions (VMC). HALO-Flight believes that operating in marginal VMC weather conditions has been the single most frequent causal factor in EMS aircraft accidents.HALO-Flight further believes that the proposed exemption is in keeping with the safety purpose ofthe 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 HALO-Flight does not conduct IFR operations in severe weather conditions. Summary. In summary, immediate granting ofthe requested relief will enhance aviation safety and be in the public interest. Each day that passes without relieffrom the recent interpretation ofSection 135.611(b) prevents safe IFR operations and unnecessarily restricts public access to air medical transportation. We appreciate your positive and expeditious consideration ofour request forthis relief. Respectfully submitted,

Thomas Klassen Director ofOperations HALO-Flight 1843 FM 665 Corpus Christi, TX 78415 tomk@haloflight.org 361 -265-0509

Summary of Petition for Publication HALO-Flight seeks an exemption from Section 135.611(b) ofTitle 14 ofthe 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. HALO-Flight is seeking reliefto the extent necessary to allow HALO-Flight to resume performing instrument flight rules (IFR) departures and to perform IFR instrument approach procedures (lAP) 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 of9 seats or less (excluding any pilot seat).