## 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 Avenue 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 14CFR61.51G) states: "Aircraft requirementsfor 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 ofa Federal, State, county, or municipal law enforcement agency, ifthe flight time was acquired by the pilot while engaged on an official law enforcement flight for a Federal, State, County, orMunicipal 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.

1
@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 ofthe exemption would not compete with any civilian revenue flight activities, thus satisfying the intent ofthe §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 offlight time- that the aircraft be"

... ofU.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 ofAirOps, 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 ofthe cities ofAlhambra, 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 ofnearly 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 ofhelicopter 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 ofpublic 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 ofairworthy spares with supporting

2records. Even considering AirOps' policy ofrefurbishing surplus components to "civilian" airworthiness standards before using them, the hourly combined operating cost ofthe OH-58s is far less than the 206B

- or oftraining at an outside flight school.
§11.81(e): WHY THIS PETITION PROVIDES AN EQUIVALENT LEVEL OF SAFETY This exemption, ifgranted, 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 ofaircraft they will be flying as AirOps helicopter pilots, rather using than civilian helicopters ofa 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 ofaircraft they will fly in service provides a much more valid and inherently safer experience and knowledge base than training in a make and model ofhelicopter 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 ofa 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 ofhelicopter.

• 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 oftheir 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 ofAirOps 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 ofthe 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 ofthe knowledge and proficiency that training for those certificate carries with it.

• In the fundamental stages oflearning, we will have opportunities to teach Pasadena pilots flight tasks that not only address PTS requirements, but other types offlying directly related to our missions that civilian pilots may never experience. (Examples: vertical reference

3operations, flying using night vision goggles, use ofunique 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 relieffrom the provision of 14CFR61.51G), which requires that logged flight time be in aircraft ofU.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 ofthis 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 ofArmy 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

4attend 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 ofdamage to our own equipment is notjustified, 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 ofthese 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 ofprimacy 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 ofPasadena and the other cities our unit serves a significant amount ofmoney- 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 ofour 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 ofairworthy surplus parts

... but on the other, they carry "public aircraft" restrictions which we must address.

A grant ofthis petition will allow us to extend these advantages ofsafety, 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 ifany such additional information is needed.

# cerely,**~**



# .**~,).A** 

# ____ ""**HILLIP** L. SANCHEZ ChiefofPolice Pasadena Police Department

5 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

6

### PASADENA POLICE DEPARTMENT AIR OPERATIONS SECTION PHOTOS

Pasadena Police Department Heliport

Two Pasadena PD OH
-58s in flight over Pasadena



### 7Surplus OH
-58 helicopter undergoing refurbishment prior to being placed in service

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



### 8Pasadena Police OH
-58; maintenance hangar and fueling facility in background

FLIR and PA loudspeaker PPD OH
-58 belly



### 9Enhanced 50
-million candlepower Nightsun searchlight on OH
-58

PPD OH
-58 cockpit



### 10Fuel capacity boost modification on OH
-58

Pasadena PD Heliport fuel farm



### 11OH
-58 rear seat area

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



### 12