Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801-321-3333 Page 1

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 Principal Operations Inspectors. Intermountain Life 

Flight is seeking immediate relief to the extent necessary to allow Intermountain Life Flight to perform

Instrument Flight Rules (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 Intermountain 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 pilot seat), listed in our Operations Specifications 

when -

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 be flown for the period of time planned for the flight; andb. 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 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.
Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801-321-3333 Page 2

2. Flight monitoring by the Operations Control Specialist within the 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 Intermountain 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 directly 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 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.

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 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. 
Intermountain Life Flight 250 North 2370 West, Salt Lake City, UT 84116 801-321-3333 Page 3

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). Operating in marginal VMC weather conditions has been the 

single most frequent causal factor in EMS aircraft accidents.

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 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 accompanied 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 thereafter. 

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 requirements 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, Intermountain 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 801-321-3333 Page 4

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

801-321-3385

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 Flight 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 weather 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.