AFS

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- E April 29, 2014

Lieutenant Simon Greene

United States Coast Guard Air Station Sitka, Alaska 611 Airport Road Sitka, AK 99835

Dear Lieutenant Greene:

This is in response to your April 5, 2013 letter sent to the public docket ( No. FAA

- 2013

- 0325 ) p etitioning the Federal Aviation Administration on behalf of United States Coast Guard (USCG), Air Station Sitka, Alaska for an exemption from § 61.157 of Title 14, Code of Federal Regulations ( 14 CFR) . That exemption, if granted, would allow

USCG to subst itute a Manual Approach to a Controlled Hover (MATCH) for the two precision approach es required for the practical test portion of the Airline Transport Pilot (ATP) certificate

.

The USCG requests relie f from the following regulation :
Section 61.157, speci fically as it applies to FAA

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- 8081

- 20 Airline Transport Pilot and Aircraft Type Rating Test Standards for Helicopter, requires an applicant to execute two precision approaches during the practical portion of the Helicopter ATP

check ride.

The ATP and Air craft Type R ating Practical Test Standards (PTS) for Helicopter specifies the areas in which knowledge and skills must be demonstrated by the applicant before the issuance of an ATP certificate and aircraft type rating in helicopters . Part 61 provide s the flexibility to permit the FAA to publish PTS which are regulatory in nature containing specific tasks. Adherence to provisions of the regulations and the PTS is mandatory for the evaluation of applicants. The FAA has examined your petition and determine d that since this would be a policy change, an exemption is not the appropriate avenue for the relief sought. Additionally the FAA has determined that an equivalent level of safety would not be assured by substituting the MATCH for a standard published in strument precision approach and therefore no changes to t he current ATP PTS will be made

. The FAA finds that conducting the MATCH approach requires a high level of skill. However, the procedural elements2 contained in the MATCH approach differ materially from a standard published i nstrument precision approach.

The air man would not have access to a United States Terminal Procedures/Instr ument Approach Procedures chart. Instead, t he airman would use an approach procedure

established b y the USCG

. Since ins trument approach procedures charts are graphic representations of approach procedures, these charts reflect specific standards developed by

the FAA and referenced in 14 CFR part 67. Objectives listed in the PTS are used to determine that the applicant exh ibits adequate knowledge such as applying the necessary adjustments to the published decision height and visibility criteria for the helicopter approach criteria category , wh ich could not be evalu ated using the MATCH approach. Further, the

FAA would be un able to evaluate the applicant’s use of the flight data center and Class II Notice to Airmen ( NOTAMS ) , inoperative helicopter ground navigation equipment, visual aids associated with the landing environment, or considerations of weather reporting factors

a nd criteria. Finally, the MATCH procedures are designed for an instrument letdown over water to a specific point at a 50

- foot hover, as opposed to continuation to landing or missed approach , which are critical objectives of PTS

.

The FAA has not establish ed guidance that a designated pilot examiner or Aviation Safety Inspector could use to evaluate an applicant performing a MATCH approach, and therefore it could not be assured that the applicant would be evaluated to the appropriate skill level.

We are cl osing out your request for exemption because the issue of whether to waive a task or maneuver established by policy is not appropriate for consideration a s a petition for exemption from the flight proficiency requirements of § 61.157.

Sincerely,

/s/

John Barbagallo Acting Deputy Director, Flight Standards Service