HEADQUARTERS 4933 B ailey L oop McClellan, CA 95652 9 16.92 1.4000 T o ll-F ree Membersh ip Line: 888 .207.LI FE CAL STAR 1 CALSTAR 3 CALSTAR5 CALSTAR 7 CALSTAR ;o 177 John Glenn Dr. 13750 Lincoln Way 

# r: 37 Mortense n Ave. 3996 Mitchell Rd. 5835 Price Ave. Concord, CA 9 4520 A u burn, CA 95603 Sa l inas, CA 93905 Santa Maria, CA McClellan, CA 95652 925 .798.7670 530.887.0569

## ~ 40 8 .848.2075 934 55 916.925.0359 805.938.9038 CALSTAR 2 CALSTAR 4 CALSTAR 6 540 Coha n sey Ave. 1351 S . State S t . 

# CALSTAR 1901 Ai rpo rt Blvd. CALSTAR 8 Gilroy, CA 9 5020 Ukiah, CA 9 5482 S. La ke Tahoe. CA 408.8 48.207 5 707.46 2.5972 96150 530.54 4 .2338 

### May 18,2015 U

. S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey

## Avenue, SE Washington, DC 20590 Dear Sirs 301 County Airport Rd. Vacaville, CA 95688 925.798.7670



### Enclosed is a petition to the Federal Aviation Administration (FAA) for an exemption from Section 135.611(b) ofTitle 14 ofthe Code ofFederal Regulations. California ShockTrauma Air Rescue is an Air Ambulance operatorwith over 30 years ofexperience in our operation area. This petition would authorize California Shock Trauma Air Rescue to perform Instrument Flight Rules (IFR) operations at locations that do not report weather without the severe weather detection equipment required in 14 CFR 135.611(b). Thankyou for your consideration. Should you have any questions, I may be reached at my office 916-921-4029 or cell608-220-1760. Sincerely

Scott Tish Director ofOperations Enclosure

CALSTAR.ORC Critical Care inMotion**Ct11ilt:;**

### California Shock Trauma Air Rescue (CALSTAR) Certificate# STRA2901 4993 Bailey Loop McClellan, CA 95652 Contact: Scott Tish , Director of Operations Phone: 916-921-4029 FAX: 916-921-4080 Email : stish@calstar
.org ******************************************************* This is a petition to the Federal Aviation Administration (FAA) , pursuant to 14 CFR Section 11 .61 (b), 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. CALSTAR is seeking immediate relief from 14 CFR 135.611 (b) to the extent necessary to allow CALSTAR to perform instrument flight rules (IFR) departures and IFR instrument approach procedures (lAP) at airports and/or heliports that do not have an approved weather reporting source, without airborne radar or thunderstorm detection equipment installed on our aircraft. CALST AR is an Air Ambulance operator based at McClellan Field in Sacramento, CA with over 30 years of air ambulance experience in our operational area. We operate eight Helicopter Air Ambulances (HAA) and one Airplane Air Ambulance (AAA) bases across Northern California. The exemption we are requesting has the following conditions : 1. The exemption is limited to the CALSTAR helicopters , which are configured for nine or less passengers , listed in our operations specifications. 2 . The exemption will only apply when current weather reports indicate that thunderstorms or other potentially hazardous weather conditions are not reasonably expected to exist at the destination and at the alternate at the estimated time of arrival (ETA) . 3. The pilot will use all available weather products during preflight planning (i.e. RotorWatch , DUATS, ADDS, and any other NWS data) to determine that severe weather does not exist, nor is forecast to exist, at the destination and at the alternate at the ETA. 4. The CALSTAR Flight Risk Assessment Tool (FRAT) will be structured to identify any IFR operation to a destination and alternate where the potential for severe weather exists . Constant monitoring and continued risk mitigation with the certificate holder or the Operational Control Center will be required prior to and during flight if that risk is identified . The flight will be declined or aborted if the risk cannot be mitigated. 

### Serving the best interest of the public: • CALSTAR maintains it is in the public's best interest to utilize the IFR infrastructure to the fullest extent possible by allowing access to all lAP's, regardless of their weather reporting capabilities in accordance with (JAW) 14 CFR 135 .611 (a) , (c) , and (d) . This w ill serve the public's best interest by allowing the public greater access to 

### HAA assets that can expedite the air transportation of the patient directly to a specialty care facility. This will avoid the delay of ground transportation by allowing flight in weather conditions that would benefit from an IFR flight plan , while still avoiding flight in severe weather conditions. • CALST AR operates in an environment challenged by the visibility and ceiling limitations of stratus and marine layer cloud cover on a consistent basis. Denial of a patient's access to the specialty care they need , in the time frame they need it, by restricting IFR operations in weather thatgenerally does not include any severe or convective activity, such as these stratus or marine f ayers. is contra to the public's best interest. Maintaining and enhancing an equivalent level of safety: • This exemption, if allowed, will help avoid the potential for Controlled Flight into Terrain (CFIT) accidents caused by pilots trying to remain in visual meteorological conditions (VMC) when the weather is clearly instrument meteorological conditions {IMC). The underlying purpose of Section 135.611 is to facilitate IFR operations by HAA operators, resulting in more aircraft operating in a positively controlled environment, thereby enhancing safety. This is also consistent with recommendations made by the National Transportation Safety Board (NTSB) on February 18, 2010 in a fact sheet issued by the FAA that calls for the need to facilitate "...more IFR operations bypermitting helicopterairambulance operators to continue IFR approaches into hospitals and airports using weatherreports from nearby stations rather than requiring weatherreports specifically from the destination location." • In support of conditions# 1-41isted above, CALSTAR will mitigate the risk of flight into severe weather by training its pilots and operation control specialists on the following subjects. The following training will be completed and evaluated annually: 1 . IFR Flight Planning 2. Use and interpretation of NWS weather charts 3. Interpretation of live radar feeds 4. SIGMETS and AIRMETS 5. MET ARS and TAFS's 6 . Interpretation and appropriate use of available cockpit weather displays 7. The applicability and use of this exemption • CALST AR's General Operations Manual (GOM) clearly restricts flight into " thunderstorms orother hazardous weatherconditions"with aircraft that do not have thunderstorm detection equipment or airborne weather radar installed . CALSTAR GOM 5. 14 (C) states: " if thunderstorms orotherpotentially hazardous weather conditions exist or

### is expected along the route offlight , CALSTAR aircraft equipped with thunderstorm detection equipment orairborne weatherradar equipment must have this equipment in operational condition. Pilots will not depart into forecast thunderstorms unless the aircraft

### is equipped with operable thunderstorm detection orairborne weather radarequipment ." In summary, CALSTAR will maintain an equivalent level of safety to 14 CFR 135.611{b) with consistent, thorough and effective preflight planning, weather interpretation training for its pilots , and clear guidance paired with constant operational control oversight and monitoring by the certificate holder. Thank you for your consideration of this exemption Respectfully submitted,



# ~ Scott Tish Director of Operations California Shock Trauma Air Rescue