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 relief to the extent necessary to allow 

HALO-Flight to perform instrument flight 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 of 9 seats or less (excluding any pilot seat). 

Consistent with HALO-Flight Operations Specifications the requested exemption, if granted, will be limited as follows: 

A. The exemption would apply to operations of HALO-Flight helicopters with a passenger seating configuration of 9 

seats or less (excluding any pilot seat}, listed in our Operations Specifications when -

1. Current weather reports or forecasts indicate that there is no reasonable possibility of thunderstorms or other 

severe weather expected to exist at the destination, alternate or along the route to be flown for the period of time 

planned for the flight; and2. Additional preflight planning is triggered by the HALO-Flight Preflight Risk Assessment Program that must be 

completed before the first leg of each Helicopter Air Ambulance Operation (HAAO}, conducted under Section 

135.611. 

B. For a flight 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 that there is no 

reasonable possibility of thunderstorms or other severe weather conditions expected to exist at the destination, 

alternate or along the route to be flown for the period of time planned for the 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 if current weather reports or forecasts indicate the 

potential for thunderstorms or other severe weather to exist at the destination, alternate or along the route to 

be flown for the period of time planned for the flight. If such 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 for thunderstorms 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 over VHF or UHF radio. 

The Operations Control Center provides general advice such as, "there are thunderstorms to your west-- recommend 

you divert to 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 radar feeds (2.0 hours) 

d. SIGMETS and AIRMETS (2.0 hours) 

e. METARS and TAFS's (2 .0 hours) 

f. Interpretation and appropriate use of available cockpit weather displays (2.0 hours) 

g. The applicability and use of this 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 of compliance that is an 

equivalent level of safety as provided by Section 135.611(b) to be maintained and will be acting in a manner consistent 

with the aviation safety goal of Section 135.611. HALO-Flight believes that the true mitigation of the risk of operations in 

areas of severe weather lies in effective and consistent preflight planning and training for its pilots and operational 

control oversight by the certificate holder. If this exemption is not granted it would negatively affect the public interest 

by reducing the number of available HAA flights. A fully trained crew, following proper IFR procedures, in a properly 

equipped aircraft, can only enhance safety. 

The underlying purpose of Section 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 of the rule instead has the unintended consequence of encouraging HAA operators to fly in marginal 

weather conditions under VFR 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 safer to 

file an IFR flight plan and to operate under IFR than to conduct flight operations under VFR 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 of the 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 of the requested relief will enhance aviation safety and be in the public interest. Each 

day that passes without relief from the recent interpretation of Section 135.611(b) prevents safe IFR operations and 

unnecessarily restricts public access to air medical transportation. We appreciate your positive and expeditious 

consideration of our request for this relief. 

Respectfully submitted, 

Thomas Klassen 

Director of Operations 

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 of the 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 relief to 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 of 9 seats or less (excluding any pilot seat).