HelpFourPaws 

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April 30, 2010 

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U.S Department of Transportation 

Docl<et Operations 

West Building, Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

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Subject: Petition for exemption from Section 61.113(c) of Title 14, Private pilot privileges awd Limitafibns, Pilot in 

command. 

Attachment: Petition for exemption from reimbursement of fuel costs for Volunteer Pilots Conducting Charitable Flights. 

Dear Administration, 

In accordance with 14CFR §11.63, we respectfully request that you consider the attached petition for exemption which is 

being submitted by HelpFourPaws, a Volunteer Pilot Organization engageid in facilitating charitable animal rescue air 

transport for animal rescue organizations. This petition is being submitted to relieve HelpFourPaws from specific and 

limited provisions of 14CFR § 61.113(c) in order to provide additional aviation safety measures and contribute to the 

public as a whole. Our request follows Exemption No. 10009 recently granted to Angel Flights, Mercy Medical and Airlift 

Hope of America. Thank you for your time and consideration. 

We welcome you to contact us with any questions at the following address: 

HelpFourPaws 

303-B Anastasia Blvd, Suite 160 

Saint Augustine, Florida 32080 

Attn: Elliot Mintzer 

Email: info@helpfourpaws.orq 

Phone: 904 333 8949 

Sincerely, 

ei^ 

Elliot Mintzer, President and Founder 

HelpFourPaws, Inc. 
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HelpFourPaws 

Attachment to Petition for Exemption from Section 61.113(c) of Title 14, Private pilot privileges and limitations, Pilot in command. 

Petition for Exemption: Reimbursement of fuel, oil, airport expenditures, or rental fees for 

Volunteer Pilots Conducting Charitable Flights 

HelpFourPaws is petitioning for an exemption from provisions in the regulations that currently dp not allow for 

reimbursement of volunteer pilots for fuel, oil, airport expenditures, or rental fees ihcurred in conducting charitable flights 

to rescue animals from certain death at shelters where their lives are in danger and to transport those animals out of 

harm's way. HelpFourPaws believes that it is in the general public's best interest to allow charitable organizations to 

provide volunteer pilots with reimbursement of incurred fuel, oil, airport expenditures, or rental fees. 

Section 61.113(c) requires that: 

(A) A private pilot may not pay less than the pro rata share of the operating expense of a flight with passengers 

provided the expenses involve only fuel, oil, airport expenditures, or rental fees. 

The effect of current regulations in an environment where aviation fuel and aircraft operations are at a much higher cost is 

creating a steady decline in charitable aviation activities. 

We believe that granting this exemption is in the public's best interest, which is, to save animals that would be Without a 

chance to live a wonderful and fulfilling life. This would not be possible without this exemr^tion. 

Supportive Information 

We believe that a targeted exemption can be granted so that both aviation safety cap be maintained as well as allow for 

volunteer pilot reimbursement to reverse the existing steady decline in charitable animal rescue flights. 

We recommend the exemption document utilize the following definitions to ensure a common clear understanding of the 

request presented. 

Voiunteer Pliot Organization (VPO) 

An IRS approved 501(c)(3) organization with a purpose of providing charitable public benefit flights. The 

VPO must function through an organized corporation of registered or member-volunteer pilots. Said 

organization must have in place the following: 
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HelpFourPaws 

Attachment to Petition for Exemption from Section 61.113(c) of Title 14, Private pilot privileges and limitations, Pilot in command. 

A structured and documented pilot registration process that has an annual renewal requirement and 

ensures that only qualified pilots are registered and oriented prior to conducting any charitable flight. 

• On file documentation authenticating registered pilots experience, ratings, insurance, FAA physical, 

etc. 

A system that evaluates the pilot's condition at the time he/she accepts and prepares to conduct the 

flight. In addition, that he/she meets all the minimum standards and appropriate currency 

requirements and will conduct the flight in accordance with applicable FAA regulations. 

A file of all records relating to flight and reimbursements. This will be made available to the FAA for 

viewing at a designated office site location. Records shall be kept for a minimum of seven years. 

Charitabie Flight 

A flight conducted by the VPO for which no payment is made to the pilot, the VPO or any other party or 

entity. The purpose of the flight must be totally dedicated to the charitable goal that has demonstrated a 

public benefit. Examples of charitable flights are as follows but not limited to this list: Transport of 

animals from shelters where the face certain death to a location where an organization will provide a safe 

haven until a permanent home can be found. Both Pre-positioning and De-positioning flights directly 

involved with the charitable event are considered charitable. The pilot must note in his/her flight log the 

charitable purpose of the flight. 

Reimbursement 

If there is any reimbursement, the reimbursement process must be administered as stated herein: 

• The reimbursement process must be administered by the VPO that facilitated the flight. 

• The reimbursement may be for any amount up to the full cost of fuel, oil, airport 

expenditures, or rental fees incurreld in the charitable flight(s). 
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HelpFourPaws 

Attachment to Petition for Exemption from Section 61.113(c) of Title 14, Private pilot privileges and limitations. Pilot in command. 

We further recommend that the exemption require validation every two years in order to remain in effect. New 

submissions or renewal of an application for an exemption submitted by the VPO must document in summary fonn 

compliance with the above definitions and procedures. 

It should be expected that every two years the VPO will |5e required to document that the information provided on their 

exemption remains valid. The two-year validation information should indicate the number of charitable flights conducted 

in the previous two-year period and the number of volunteer pilots receiving reimbursement of any amount during the 

period and the total amount of reimbursement provided. 

Issue of Public interest 

In these economic times it is very important from a public perspective that a means be devised to allow the costs of 

conducting charitable animal rescue transport be spread to a broader base. Today, the total cost to facilitate and maintain 

charitable animal rescue transport rests 100% on the Volunteer Pilot Organization. In addition, the entire cost of the flight 

rests on the volunteer pilot. A large portion of this expense is for fuel, oil, airport expenditures, or rental fees. These costs 

are easily calculated from recorded flight times, normal burn-rates and average retail fuel costs as well as invoices from 

pilots. 

An exenfiption to allow a VPO to reimburse volunteer pilots for some or all of the fuel, oil, airport expenditures, or rental 

fees then allows the opportunity for additional donors to join the process by providing donations to help cover these costs 

and other expenses. The resulting mix of participants will relieve overtsurdened volunteer pilots and allow the influx of 

new volunteer participants which in turn will provide a greater public benefit. 

The past few years have shown a decline in chdritable animal rescue transport which has resulted in fewer animals to be 

adopted. This exemption will reverse that trend and provide a much needed benefit to the animal rescue community. 

Effect of the Exemption of Safety 

The exemption, as proposed, would mandate an increase in the experience level of volunteer pilots serving in charitable 

animal rescue transport through the VPO. The VPO granted an exception should be required to conduct an annual safety 

audit vyhich would then promote a culture of safety and provide a documented safety mahagement strategy. The net 

result would be a smaller but more experienced pilot base along with increased levels of service to the general public. It 

i$ also expected that there will be additional availability of charitable animal rescue transport which will allow for the saving 

of animals that could not be reached due to previous constraints. This will not be available without this exemption. 
HelpFourPaws 

Attachment to Petition for Exemption from Section 61.113(c) of Title 14, Private pilot privileges and limitations, Pilot in command. 

Conclusion 

We believe that the FAA should allow both the exemption and the recommended procedure which will require an absolute 

minimum of workload on the FAA. We believe the exemption as proposed will ensure that only pilots certified as 

"Approved" of the VPO could be reimbursed. We believe that the exemption as proposed will ensure that no 

reimbursement is made that would apply to training or flights for unintended purposes. 

We respectfully request that the FAA allow for exemptions as described herein for fuel, oil, airport expenditures, or rental 

fees reimbursement for charitable animal rescue transport as facilitated by the VPO. We welcome the opportunity to 

interact with those who will be preparing this material for exemption documentation. 
Safety 

Management Plan 

April 30,2010 
PURPOSE: The purpose of establishing a Safety Management Plan is multifold: 

• To facilitate the identification ofhazards and risks. 

• To create and maintain a positive culture of safety. 

• To incorporate safety as a major component of HelpFourPaws aviation 

operations. 

• To combine performance standards with safety standards. 

GOALS: The goals are, as follows: 

• To instill a positive culture of safety at every level of the organization. 

• To create and maintain an environment that promotes continuous improvement, 

training and safety awareness. 

VISION: To offer free transportation of animals from overcrowded shelters where they 

face certain death. Volunteer pilots fly these animals to where qualified families or 

rescue organizations are waiting to adopt or foster them. 

MISSION: Protect animals that are abandoned, abused and or neglected. 

To fransport these animals out of harm's way so they can be placed 

in, a home, where they will be loved and receive quality care. 

To raise funds so that these animals can be rescued, cared for, and 

relocated to a loving owner and have a place to call home. 

DEFINITIONS 

Safety Policy; Outlines the methods and processes to be utilized to achieve desired goals 

that the Safety Policy establishes in order to promote a positive culture of safety 

throughout the organization. 

Risk. Hazard Management: A process that identifies and analyzes hazards and risks, 

and creates controls to manage those risks. 

Safety Assurance: Used to ensure developed risk and hazard controls to achieve 

intended objectives. These monitoring processes may help to reveal risks and hazards not 

previously identified. The process includes program information acquisition, analysis, 

continuous assessment, and development of preventive, corrective action for 

nonconformance. Tracking and measuring the results of safety*related activities and 

training is a component of the process. 
PROGRAMS 

Safety Policy will establish: 

1. Volunteer Pilot minimum qualifications, standards, recommended operating 

procedures and expectations 

2. Continuous hazard and risk assessment 

3. Volunteer Pilot list of best practices 

4. Incident occurrence and hazard reporting 

5. Occurrence investigation and analysis 

6. Periodic safety audits 

7. Non-punitive reporting policy 

8. Volunteer Pilot follow-up and accountability 

9. Continuous safety-related education and communication 

10. Identification of leadership role in the safety process 

11. Emergency preparedness and response 

12. Measurement of performance and continuous improvement 

13. Regular distribution of safety newsletter 

14. Annual Volunteer Pilot affirmation 

15. Director of Aviation Safety - Rebekah S wenson/Panama City region 

a. COM, MEL, SEL with instrument privileges, CFI, MEI, CFII 

16. Director of Aviation Safety - Cary Green/St. Augustine region 

a. Holding the following; COM, ASEL, ASEF, Instrument, CFI, CFII, 

CFIMEI,FE-Turbo Jet 

Risk, Hazard Management 

Risk, Hazard Identification 

• Accident trends and factors for General Aviation fixed wing under 12,500 

lbs. 

• 2008 Air Safety Foundation Nail report. 

High Risk Phases of Flight 

• Takeoff and climb 

Takeoff Stall/Settling 

Loss of airspeed resulting m non-recoverable stall or sink 

rate 

Loss of control 

Crosswind$ /Other conditions leading to loss of 

directional control 

• Maneuvering 

Stall or loss of control 

Loss of airspeed resulting in stall/spin 
Loss of engine power 

Carburetor icing 

Incorrect fiiel mixture 

Wind gusts or wake turbulence 

• Landing 

Loss of directional control 

Crosswinds 

Inadequate airspeed control 

Stalls, hard landing, short-long touchdown 

Runway conditions 

Runway contamination 

• Flight planning, decision-making 

Flight planning 

Improper pre-flight planning 

Insufficient fiiel reserves 

Inadequate in-flight monitoring of groimd speed 

Systems operation 

Improper operation of fiiel system 

Fuel contamination 

Improper fiieling 

• Weather 

Continued VFR mto IMC 

Deficient IFR technique 

Failure to follow appropriate IFR procedures 

Descending below MDA on approach 

Thunderstorm 

Flying too close or penetrating 

Turbulence 

High winds 

Mountainous terrain 

Icing 

Loss of lift and performance 

Instrument malfimction 

Other factors 

Single pilot IFR 

Night operations at unfamiliar airports 

Mission mentality 

Get-tl?ere-itis 

Distractions 

Missed approach/Go around 

Incomplete/Stale weather briefings 
Incomplete/Stale weather briefings 

Regular training, briefing, and awareness of these and other risks and hazards will help us 

achieve our goal of creating a positive culture of safety. 

Safety Assurance 

The Safety Assurance program will use several different processes to verify that the safety 

goals of our organizations are being met and are keeping up with current trends and 

information. These include the following: 

• Establish a non-punitive reporting program for Volimteer Pilots. 

• Create a database of known and previously tmknown risks and hazards. 

• Regularly review pilot post-mission reports. 

• Conduct random pilot flight de-briefings. 

• Conduct regular follow-up with patients/passengers. 

• Solicit input and communication from pilots. 

• Solicit input and communication from Coordination staff. 

Volunteer Pilot Requirements 

Minimum Pilot in Command (PIC) Qualifications 

• For the operation of any single-engine piston aircraft, the pilot shall have a 

minimum total time of 125 hours with no less than 100 hours as Pilot in 

Command (PIC). Minimum of 25 hours in make and model. 

• For the operation of any multiengine aircraft, the pilot shall have a minimum 

total time of 200 hours as Pilot in Command (PIC). Minimum of 150 hours in 

multiengine and a minimum of 50 hours in make and model. 

• For the operation of any turbine powered aircraft, the pilot shall have a 

minimum total time of 500 hoin-s as Pilot in Command (PIC). Minimum of 

100 hours turbine and a minimum of 50 hours make and model. 

• Minimum of 25 hours as PIC shall have been flown and logged within the 12 

months immediately preceding the flight. 

• Minimum of 12 hours flown and logged during the previous 90 days. (This 

requirement can be waived if the pilot completes 2 hours of dual training with 

a certificated flight instructor prior to flying a HelpFourPaws flight.) 

• Pilot shall have a current valid medical certificate, a current flight review, and 

for pilots conducting flights imder IFR, an instrument rating applicable to the 

aircraft to be flown by said pilot and shall be current with applicable flight 

times and rules as set forth in the FARs. 

• Minimum of one million dollars ($ 1,000,000) liability insurance with not less 

than $100,000 per seat shall be in force on any aircraft to be used for 
HelpFourPaws flights. 

• Aircraft must be properly registered, licensed, and airworthy. It is 

recommended that aircraft engine be overhauled prior to reaching 

manufacturer's recommended Time Between Overhaul (TBO). 

• No pilot of 75 years of age or older shall be permitted to fly a HelpFourPaws 

flight. (This requirement can be waived with approval of the VPO's Safety 

Council.) 

In addition to above listed qualifications, the following actions have been 

implemented: 

• Mandatory annual recertification by Volunteer Pilot (must certify that 

minimum standards are met to remain an active pilot). 

• Mandatory affirmation that all qualifications are met prior to date of a flight 

you have accepted. This will be built into our flight coordination system. 

Developing a Culture of Safety 

Besides the Volimteer Pilot Requirements listed above, the following actions wiU be taken 

to develop a culture of safety vwthin our organizations: 

• Establish safety page on website. 

* • Add a safety article to each newsletter. 

• Establish Pilot Mentorship program where veteran pilots are teamed with new 

pilots. 

• Increase emphasis on safety during pilot orientation. 

• Promote Air Safety Foundation (ASF) website (www.ASF.org) where safety 

courses, quizzes, and advisories are readily available. 

• Encourage new pilots to fly with a veteran HelpFourPaws flight pilot prior to 

accepting their first flight as PIC. 

Update terminology to remove undue pressure on pilots. 

Volunteer Pilot Standards 

• Legs will only be flown by pilots meeting minimtim requirements established by 

HelpFourPaws. 

• All animals will be contained within a crate so as not to provide any distractions or 

undue hazard to pilot duties. 

• Pilots must be VFR/IFR current. 

• Pilots must be day and night current to carry passengers. 
• Pilots must hold current medical certificate. 

• 

• 

Aircraft utilized for transport must be airworthy as defined by FAA regulations and, 

to the pilot's best knowledge, be free of any and all defects that could in any way 

compromise the safety of the flight. 

Pilots must have competent knowledge of aircraft systems, emergency procedures, 

avionics operation, etc., for aircraft used for transport. 

• Pilots must complete Go/No-Go checklist; passenger, co-pilot release forms, and 

post-flight report. 

• Pilots are requested to use non-punitive report process to communicate any and all 

situations where, when safety of flight was compromised. 

• Pilots are requested to provide feedback on weather, airports, ATC, other pilots, 

etc., that could conlpromise safety for future flights. 

• Passengers and crew of all transport flights must be restrained by FAA- approved 

seat belts or FAA-approVed child safety seat. The only exception shall be change of 

seat position, quick access to luggage, care and/or feeding of an animal or use of 

lavatory. 

• Pilots will consult available weather products, wind sock, etc., to verify departure 

will be from correct runway relative to wind conditions. 

• Pilots will utilize computer devices and reading material only as these are pertinent 

to safe operation of the flight, and will refrain from any and all distractions 

that could compromise safety of flight 

• Pilots will utilize and brief passengers that a sterile cockpit condition exists during 

taxi and takeoff until reaching cruise altitude and also during descent from cruise 

altitude, descent, approach, landing and taxi to ramp. 

Volunteer Pilot Best Practices 

• Be well rested and healthy for flight. 

• Set aside plenty of time - don't be rushed. 

• Cancel if you don't feel right or feel stressed out. 

• In IMC conditions, plan to land at airport, with a precision approach. 

• Add 100 feet to all approach minimums, especially at night. 

• Weather minimums at the Departure airport, for flight being conducted in IMC conditions, 

are at or above 1000' / 3 mi (DAY) or 2000' / 3 mi (NIGHT) 

• For flights conducted in IMC conditions, there are airports enroute with current and 

forecasted minimums at or above 800' / 2 mi. 
Destination airport minimums, for IMC conditions, at destination airport at ETA +/-1 hour 

must be at or above 1000' / 3 mi (DAY) or 2000' / 3 mi (NIGHT) 

Weather minimums at the Departure and arrival airport, for a flight being conducted 

in VMC conditions, are above 30007 5 mi (DAY) or 5000'/ 5 mi (NIGHT) 

The reported crosswind component for all flights does not exceed 15 knots, including gusts 

at destination and arrival airports. 

Night landing should only be to runways with functional vertical guidance (VASI, 

PAPI, ILS, GPS). 

Do not attempt circling approaches at night. 

Utilize qualified co-pilot when destination is busy Class B airspace with potential 

high workload. If not available, be thoroughly briefed and organized. 

Add 50% to POH runway length to clear the obstacle for take-off and landing under 

ambient conditions. 

IMC take-off: add 50% to approach landing minimums. (Example: FDK minimums 

200/1/2, take-off should be at least 300/1 

If destination is unfamiliar, obtain briefing from pilot with experience with that 

airport prior to flight. 

Expect the unexpected. 

Thoroughly brief passengers on what to expect during flight. 

If in doubt or have lack of confidence, cancel. 

Fly safe or don't fly. 
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Addendum 

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HelpFourPaws 

Annual Pilot Affirmation 

HelpFourPaws believes ttiat Its pilots should maintain a certain level of proficiency in their flying 

to function as Pilot in Command. 

HelpFourPaws does not conduct recunent training or proficiency flight checks, but does expect 

the Pilot in Command to maintain proficiency. HelpFourPaws has set the following proficiency 

standards that must be affirmed by the Pilot in Command annually: 

DI hold a current and valid private Pilot's certificate and a current and valid medical 

certificate. 

• i meet the minimum total time requirements per published standards: 

(125 hours for single engine - 200 houre for multi engine) 

a i witi accept flights only when I have flown at least 12 houre within the previous 90 days 

or I have completed at least 2 dual training houre with a CFI. 

DI am instrument Rated to fly an IFR flight plan 

a I have insurance coverage in effect (liability minimum $1,000,000). 

Name of Insurance Company: Policy #: 

a I agree to abide at all times by applicable FAA Rules and Regulations in the conduct of 

flighte, and to provide transportation in an "airworthy" aireraft, as defined by the FAA 

Rules and Regulations. 

Signature Date 

NAME (Last/First/Middle);. 

DATE OF BIRTH: I 

Please Print 

STREET ADDRESS; 

CITY STATE ZIP 

DAY PHONE: ( 

EMAIL: 

CELL PHONE: ( 

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