Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801

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## Request for Exemption 14 CFR 135.611(b) FAA Air Carrier No. I7LA073P September 8, 2015

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 recently interpreted by the FAA’s Flight Standards Service in internal guidance to Pr incipal Operations Inspectors. Intermountain Life Flight is seeking immediate relief to the extent necessary to allow Intermountain Life Flight to perform Instrument Flight R ules (IFR) departures and approach procedures (IAP) 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 Intermou ntain Life Flight’s Operations Specifications, the requested exemption, if granted, will be limited as follows:

A. The exemption would apply to operations of Intermountain Life Flight with a passenger seating configuration of 9 seats or less (excluding any pi lot seat), listed in our Operations Specifications
when

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a. 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 b e flown for the period of time planned for the flight; and

b. Additional preflight planning is triggered by the Intermountain Life 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 Intermountain Life Flight’s General Operations Manual and Approved Training Programs.

1. Additional Weather Bri efing Requirements for Flights u nder 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 makin g that determination; AIRMET, SIGMET, CONVECTIVE SIGMET, METAR, REGIONAL NEXRAD, NOTAM, PIREP, and TAF; and

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 No IFR operation under Section 135.611 will be released if current weather reports or forecasts indicate the potential for thunderstorms or other s evere 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.Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801

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2. Flight monitoring by the Operations Control Specialist within th e Communication Center
Once the flight becomes active, the Operations Control Specialist utilizes a satellite tracking system

to monitor the flight plan, current position
, destination and enroute weather conditions for all active flights. The Intermountai n Life Flight Operations Control Specialist continuously monitors all flights for thunderstorms and severe weather and provides that information to the pilot * by:

 Contacting the pilot directly using existing radio infrastructure ; or

 Contacting the pilot d irectly via satellite phone.

* The Operations Control Specialist provides general advice such as, “ there are thunderstorms to your west

-- recommend you divert to the east. ”

3. Training for the 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

Intermountain Life Flight maintains that it is in the public i nterest 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 b e served by increasing the opportunity for additional access to critical care patient flights.
Intermountain Life 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. Intermountain Life 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 c ertificate 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 s afety.
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.Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801

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Intermountain Life Flight is committed to the safe and successful completion of its air medical flights and believes that it is safer to operate under IFR than to conduct flight operations under VFR in marginal visual meteorological conditions (VMC). O perating in marginal VMC weat her conditions has been the single most frequent causal factor in EMS aircraft accidents.

T he 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 wo uld 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 Intermountain Life Flight will not conduct IFR operations in severe weather conditions.

Further Justifying Information

Partly stemming from the recommendations from both the NTSB and FAA, Intermountain Life Flight began developing a low level IFR infrastructure centralized in the Salt Lake Valley several years ago . This effort included the design of six helipad approaches to key bases. These bases are located in areas that can be especially susceptible to inversion related fog, especially during winter months. These low visibility conditions, which are never acc ompanied by thunderstorm activity, can persist for weeks at a
time. It is expected that the first six approaches will be FAA approved by November of 2015. Utilization of these approaches, along with the low level structure, is expected to occur shortly t hereafter.
Intermountain Life Flight looks forward to navigating the Salt Lake Valley, and surrounding areas, taking advantage of the safety and protection of an IFR system. Currently operating three King Air aircraft, it is well acquainted with the re quirements and limitations of IFR, including the avoidance of severe
weather. The aircraft targeted for rotor wing IFR operations, five Agusta AW109SPs, are equipped for single pilot IFR operations, including cockpit based XM weather.

In summary, Interm ountain Life Flight is prepared to avoid severe weather because of the following:

1. Dedicated operational control specialists, with a current ratio of one full

- time controller to five rotor wing pilots, are trained to monitor and to provide hazardous weather information to pilots;
2. XM weather, which provides nearly real time access to severe weather, is available to all IFR rotor wing pilots;
3. Pilots will conduct a thorough preflight weather analysis prior to IFR flight;
4. The majority of IFR flights are expected to be conducted in inversion related weather.Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801

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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,



### William Butts, Director of Aviation Operations Intermountain Life Flight
250 North 2370 West Salt Lake City, UT 84116 bill.butts@imail.org
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Summary of Petition for Publication

Intermountain Life Flight seeks an exemption from Section 135.611(b) of Title 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. Intermountain Life Flig ht is seeking relief to the extent necessary to allow instrument flight rules (IFR) departures and to perform IFR instrument approach procedures (IAP) at airports and or heliports that do not have an approved weather reporting
source without airborne weath er radar or lightning strike detection equipment installed in its helicopters with a passenger seating configuration of 9 seats or less (excluding any pilot seat), with limitations consistent with the company’s past operating practices.