AFS-13-318-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) petitioning 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 substitute a Manual Approach to a Controlled Hover (MATCH) for the two 

precision approaches required for the practical test portion of the Airline Transport Pilot 

(ATP) certificate.

The USCG requests relief from the following regulation:

Section 61.157, specifically as it applies to FAA-S-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 Aircraft Type Rating 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 provides 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 determined 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 instrument precision approach and 

therefore no changes to the current ATP PTS will be made. The FAA finds that conducting 

the MATCH approach requires a high level of skill. However, the procedural elements 
2

contained in the MATCH approach differ materially from a standard published instrument 

precision approach.

The airman would not have access to a United States Terminal Procedures/Instrument 

Approach Procedures chart. Instead, the airman would use an approach procedure 

established by the USCG. Since instrument 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 exhibits adequate knowledge such as applying the necessary 

adjustments to the published decision height and visibility criteria for the helicopter approach 

criteria category, which could not be evaluated using the MATCH approach. Further, the 

FAA would be unable 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 

and 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 established 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 closing out your request for exemption because the issue of whether to waive a task 

or maneuver established by policy is not appropriate for consideration as a petition for 

exemption from the flight proficiency requirements of § 61.157.

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service