pOLICE 

PHILLIP L. SANCHEZ 

CHIEF OF POLICE 

207 N . GARFIELD AVENUE 

PASADENA, CA 91 101 

August 11, 2014 

PETITION FOR EXEMPTION FROM PROVISIONS OF 

14 CFR 61.51(j)(l) and (j)(4) 

14CFR11.81(a): NAME, MAILING ADDRESS, CONTACT INFORMATION: 

Michael Ingram, Lieutenant 

Pasadena Police Department 

Air Operations Unit 

207 N. Garfield A venue 

Pasadena, CA 911 01 

Telephone - (626) 744-4606 

Email - mingram@cityofpasadena.net 

(626) 744-4501 

§11.81(b): SPECIFIC SECTION OF 14CFR FROM WHICH EXEMPTION IS SOUGHT 

14CFR61.51 G) states: "Aircraft requirements for logging flight time. For a person to log flight 

time, the time must be acquired in an aircraft that is identified as an aircraft under §61.5(b), and 

IS ••• 

(1) An aircraft ofU.S. registry with either a standard or special airworthiness certificate 

... or ... 

( 4) A public aircraft under the direct operational control of a Federal, State, county, or 

municipal law enforcement agency, if the flight time was acquired by the pilot while engaged on 

an official law enforcement flight for a Federal, State, County, or Municipal law enforcement 

agency. [Our emphasis] 

§11.81(c): EXTENT OF RELIEF SOUGHT 

Pasadena Police Department Air Operations Section (AirOps) requests an exemption that will: 

1. Clearly apply subparagraph (4) versus subparagraph (1) of §61.51G) to our flight training 

operations, and 

2. Extend the definition of"officiallaw enforcement flight" in subparagraph (4) to specifically 

include flight time acquired by Pasadena Police officers undergoing flight training to be 

AirOps helicopter pilots or flight instructors, conducted by AirOps in our OH-58 helicopters, 

as eligible to be logged as satisfying experience requirements of 14CFR61 for their Pilot or 

Flight Instructor certificates with Rotorcraft Helicopter ratings. 

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@xceLLence • e}nnovation • e}ntetjritr; 
This exemption would apply only to training conducted by AirOps for sworn Pasadena Police 

Department officers undergoing training to be AirOps pilots or flight instructors in AirOps 

helicopters. 

A grant of the exemption would not compete with any civilian revenue flight activities, thus 

satisfying the intent of the §61.51 G) regulatory restriction against logging time in public aircraft 

other than on official law enforcement flights. 

§11.81(d): REASONS FOR SEEKING RELIEF 

AirOps currently utilizes several former military Bell OH-58 helicopters, operated as public 

aircraft. These helicopters are not eligible for civilian airworthiness certificates, and 

consequently do not meet the specific requirement of §61.51 G)(1) as regards logging of flight 

time- that the aircraft be" ... of U.S. registry with either a standard or special airworthiness 

certificate." Because it is not clear whether training flights in these aircraft satisfy the "official 

law enforcement flight for a ... municipal law enforcement agency" requirement of §61.510.)(4), 

AirOps does not believe that our police officers being trained as pilots can legally log flight 

experience in these helicopters. To avoid violating this rule, AirOps has been forced to send 

trainees to outside commercial flight schools, where they fly civilian helicopters that do have 

standard airworthiness certificates - but entirely different handling qualities and operational 

procedures, in an environment completely different from that of AirOps, and at significant 

additional cost. 

§11.81(d): GRANTING THIS PETITION WOULD BE IN THE PUBLIC INTEREST 

Through its Foothill Air Support Team (FAST), Pasadena Police Department AirOps provides 

support for the law enforcement agencies of the cities of Alhambra, Arcadia, Covina, Monrovia, 

Pasadena, San Marino, Sierra Madre, South Pasadena, and Pomona, California, as well as 

unincorporated areas between those cities, and -through mutual agreements, the cities of 

Glendale and Burbank- a geographic area spanning approximately 40 miles, with a population 

of nearly two million people. In these times when funding for municipal helicopter operations is 

stringent, for AirOps to meet its mission requirements it must be able to upgrade police officers 

from its cadre of helicopter observers into pilot positions with the maximum favorable balance 

between safety, training benefit, and cost. 

However, since we believe that §61.51 G)( 4) prohibits our trainees from logging pilot or 

instructor training in our own OH-58 helicopters, we must have newly-qualifying pilots trained 

at outside commercial flight schools whose helicopters have standard airworthiness certificates -

and then conduct additional training to qualify them in our equipment. This places an 

unwarranted economic burden upon the Pasadena Police Department, and indirectly upon the 

city's taxpayers and those ofFAST participant communities. Conversely, conducting their flight 

training in AirOps fleet helicopters provides the most economical and practicab~e means of 

achieving that goal. 

Although AirOps has one Bell 206B helicopter (for use on missions for which use of public 

aircraft is not allowed), that ship was purchased on the commercial market, and is maintained 

using commercial market components- in contrast to the OH-58s, which were purchased as 

government surplus and accompanied by a large supply of airworthy spares with supporting 

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records. Even considering AirOps' policy of refurbishing surplus components to "civilian" 

airworthiness standards before using them, the hourly combined operating cost of the OH-58s is 

far less than the 206B - or of training at an outside flight school. 

§11.81(e): WHY THIS PETITION PROVIDES AN EQUIVALENT LEVEL OF SAFETY 

This exemption, if granted, will actually provide an improved level of safety, for several reasons: 

• The pilot and instructor trainees will be gaining flight experience in the same make and 

model of aircraft they will be flying as AirOps helicopter pilots, rather using than civilian 

helicopters of a different make and model with significantly different engines, systems, 

performance, and handling qualities. This improves safety by eliminating the need to 

"unlearn" one helicopter and "learn" another one. 

• Training and practice in abnormal and emergency flight operations in the same make and 

model of aircraft they will fly in service provides a much more valid and inherently safer 

experience and knowledge base than training in a make and model of helicopter they will 

never fly on duty. 

• While complying with applicable Practical Test Standards, training our pilots and flight 

instructors in our own aircraft, providing an opportunity to become facile with the extensive 

suite of special equipment installed in our OH-58s (see the supplement accompanying this 

petition), with our own instructors, allows us to integrate AirOps policies and procedures 

from the beginning, thus providing a smoother, safer transition to line pilot duties. 

• For the reasons stated above, the trainees will not be required to learn limitations, 

performance, systems, and equipment of a new helicopter type when they return to AirOps 

after obtaining their Commercial Pilot certificates with Rotorcraft Helicopter ratings from an 

outside commercial flight school in a different type of helicopter. 

• Since their flying will be from the Pasadena Police Heliport and will transit areas served by 

AirOps flights, their flight training will occur in the same operating and procedural 

environment as their service after obtaining their Commercial Pilot certificates and 

Rotorcraft Helicopter (or Instructor) ratings. This provides a safer, more direct transfer of 

learning to their duties as police helicopter pilots than operations from a distant commercial 

flight school. 

• From the beginning of their training, police pilots can be taught not only the requirements in 

the Practical Test Standards, but undergo that training in a policing environment, using 

specialized police equipment, and be held to standards of AirOps Section policies and 

procedures, which are oftentimes quite different and more stringent than those taught by a 

commercial flight school. This avoids the bad side of the Primacy Effect: The need to "unteach" what the pilot learned first, which is often more difficult than teaching the pilot in the 

first place. 

• The OH-58 helicopters are public aircraft, and technically, civilian pilot certificates are not 

required to fly them. Pasadena AirOps has always required a Commercial Pilot certificate 

with a Rotorcraft Helicopter rating for the section's pilots, and Rotorcraft Helicopter ratings 

for our instructors, in the interest of safety - and to take advantage of the knowledge and 

proficiency that training for those certificate carries with it. 

• In the fundamental stages of learning, we will have opportunities to teach Pasadena pilots 

flight tasks that not only address PTS requirements, but other types of flying directly related 

to our missions that civilian pilots may never experience. (Examples: vertical reference 

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operations, flying using night vision goggles, use of unique law-enforcement-oriented 

equipment in AirOps helicopters, etc.) 

• Pasadena Police AirOps places heavy emphasis on safety. Although the OH-58s are operated 

as public aircraft, the section's operational and maintenance practices were modeled after 

Part 135 requirements. 

The Pasadena Police Department's need to balance strict adherence to specific restrictions 

applicable to public aircraft flying with the need to conduct efficient, practical, and cost-effective 

training are, in fact, the reason for this petition. 

§ll.Sl(f): FEDERAL REGISTER SUMMARY OF THIS PETITION 

This petition would grant relief from the provision of 14CFR61.51G), which requires that logged 

flight time be in aircraft of U.S. registry with either a standard or special airworthiness 

certificate, or public aircraft while engaged on an official law enforcement flights. The relief 

would permit Pasadena, California Police Department Air Operations Section pilot and flight 

instructor trainees to log flight time in the department's refurbished military-surplus OH-58 . 

helicopters, which are operated as public aircraft, by classifying training flights in those aircraft 

as "official law enforcement" flights as provided in 14CFR61.51G)(4). 

§ll.Sl(g): ADDITIONAL INFORMATION TO SUPPORT THIS PETITION 

For further information about Pasadena Police Department's Air Operations Section, please see 

the Supplementary Information document appended at the end of this petition. 

Although the AirOps OH-58s are operated as public aircraft, the section's policies and 

procedures closely duplicate - and in many cases exceed- the standards set for revenue 

operations under Part 135. AirOps has developed its own 25-hour "letter check" inspection and 

maintenance program based upon a blending of Army practices and those developed by Bell for 

civilian helicopters. Applicable component life limits and type-restricted-category ADs are 

complied with, as well as any regular Airworthiness Directives applicable to civilian-certificated 

parts that may be installed on the OH-58s, or military parts that share civilian part numbers- as 

well as any that warrant compliance from a safety standpoint. All engine maintenance is 

accomplished in accordance with the applicable Rolls Royce manuals. Mechanics working on 

AirOps ships are factory trained, and most work is done at AirOps' own facility. Outsourced 

component inspection and overhaul is accomplished at organizations supported by Bell, and/or at 

properly certificated Part 145 repair stations. Specialized equipment installations on the OH-58s 

are accomplished in compliance with FAA-approved data via STCs or FAA Forms 337. 

Strong emphasis is placed on the "no double standard" concept: The military surplus ships are 

maintained to the same standard as AirOps helicopters with standard airworthiness certificates. 

Many visitors to AirOps have commented that the section's OH-58s are the best they have ever 

seen. 

Pilot training and operational standards are similarly high, based upon AirOps' comprehensive 

Standard Operating Procedures Manual, a separate supplemental SOP manual dealing with night 

vision goggle operations, and the section's standardized Flight Training Curriculum manual, 

which integrates required tasks from the applicable Practical Test Standards with procedures and 

policies unique to Pasadena PD's equipment, operating environment, and mission. AirOps pilots 

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attend specialized initial and recurrent emergency training in aircraft compatible with our 

fleet, either at local flight training organizations which specialize in specific maneuvers (fulldown autorotations, for example), or factory emergency procedures training courses, where we 

believe the risk of damage to our own equipment is not justified, but the training is necessary. 

Numerous other police agencies have used Pasadena's program as a model for their own airborne 

units, and adopted operational and training manuals authored wholly or in part by Pasadena PD 

officers. 

The AirOps section has enjoyed a remarkable record with the OH-58s. The first of these ships 

was placed in service in 1997; since that time Pasadena PD has accumulated more than 20,000 

flight hours in these aircraft. 

§11.81(h): APPLICABILITY OF PETITION OUTSIDE THE UNITED STATES 

Pasadena Police Department does not intend to seek authorization to apply this exemption (if 

granted) to operations outside the United States. 

CONCLUSION 

We believe this petition provides not only an equivalent, but actually a superior level of safety, 

by training our pilots and instructors in the aircraft, in the environment, and according to the 

procedures they will use in service - thus allowing us to better embrace the rule of primacy in 

our training efforts. It is clearly in the public interest, because the ability to use our OH-58s will 

save AirOps, the Pasadena Police Department, and ultimately the taxpayers of Pasadena and the 

other cities our unit serves a significant amount of money- which is then available for other uses 

more directly related to our mission. 

Lastly, Pasadena's AirOps unit is in a somewhat unique situation because of our use of 

refurbished and updated military surplus OH-58 helicopters and our high operating standards. 

On one hand, these ships give us an unusually reliable, capable, economical resource supported 

by a large supply of airworthy surplus parts ... but on the other, they carry "public aircraft" 

restrictions which we must address. 

A grant of this petition will allow us to extend these advantages of safety, public interest, and 

economy into our pilot and instructor training activities. 

The PPD Air Operations Section stands ready to discuss, clarify, or amplify upon any aspect of 

this petition with FAA personnel to the extent allowed by agency policy. Please feel free to 

contact me if any such additional information is needed. 

cerely, ~ 

. ~,).A ____ "" HILLIP L. SANCHEZ 

Chief of Police 

Pasadena Police Department 

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Please scroll down for attachment 

appended to this document: 

Supplementary Information 

PASADENA POLICE DEPARTMENT 

AIR OPERATIONS UNIT 
Supplementary Information

PASADENA POLICE DEPARTMENT AIR OPERATIONS UNIT

Petition for Exemption from Provisions of

14 CFR 61.51(j)(1) and (j)(4)

Pasadena Police Department Air Operations Section’s helicopter operations manual and its 

maintenance and inspection programs were modeled with the objective of meeting FAA Part 135 

standards. 

Although they are operated as public aircraft, AirOps’ surplus OH-58 helicopters are each put 

through an extensive overhaul and refurbishment program before being placed in service. The 

process includes general reconditioning, rewiring, component inspection, overhaul, repair, and 

stripping and painting. This effectively brings the ships up to the same standards of 

airworthiness as civil helicopters with standard airworthiness certificates, and results in an 

exceptionally reliable, flexible, and cost-effective police helicopter. The process is a prerequisite 

for placement on the AirOps helicopter inspection and maintenance program. 

In the course of this process, the ships are equipped with an extensive suite of specialized 

equipment that AirOps has determined is necessary for efficient and effective use in their 

mission. This includes –

• Gyro stabilized binoculars 

• Cockpit compatible with night vision goggle (NVG) operations (the fleet is being 

equipped with NVG capability at this time)

• Technisonic police radio system including audio panels, four independent VHF-UHF 

options, compatibility with Pasadena PD’s encrypted radio communications protocol, 

and intercom capability at all seats

• Forward-looking Infrared (FLIR) imaging system

• Churchill Navigation “Augmented Reality System” (ARS) GPS mapping with FLIR 

overlay capability on the display. This system provides high-resolution geographic 

information, street address overlay, satellite imagery and topographic map resources 

integrated with the FLIR imagery

• Downlink system allowing cockpit display images to be broadcast to ground units

• Garmin GNS-430W incorporating VHF aircraft comm, VHF nav, GPS capability and 

Traffic Information System (TIS) display

• Garmin mode A/C transponder

• External public address speaker

• Enhanced Nightsun searchlight, 50 million candlepower 

• Radar altimeter

• Solid-state “glass” attitude indicator; directional gyro, vertical speed, and turn & bank 

indicators; flight instruments arranged in “basic-T” configuration 

• Conventional aircraft instruments and other equipment compliant with 14CFR91.205(a) 

through (c)

• Pacific Scientific four-point shoulder harness/seat belt units at all seats

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PASADENA POLICE DEPARTMENT AIR OPERATIONS SECTION PHOTOS

Pasadena Police Department Heliport

Two Pasadena PD OH-58s in flight over Pasadena

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Surplus OH-58 helicopter undergoing refurbishment prior to being placed in service

Inflight night shot showing OH-58’s Augmented Reality System/FLIR display

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Pasadena Police OH-58; maintenance hangar and fueling facility in background

FLIR and PA loudspeaker PPD OH-58 belly

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Enhanced 50-million candlepower Nightsun searchlight on OH-58

PPD OH-58 cockpit

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Fuel capacity boost modification on OH-58

Pasadena PD Heliport fuel farm

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OH-58 rear seat area

Director of Maintenance Randall James working on the AirOps Bell 206B

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