HEADQUARTERS 

4933 Bailey Loop 

McClellan, CA 95652 

9 16.921.4000 

Toll-Free Membership 

Line: 888.207.LIFE 

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 94520 Auburn, CA 95603 Salinas, CA 93905 Santa Maria, CA McClellan, CA 95652 

925.798.7670 530.887.0569 

~ 408.848.2075 93455 916.925.0359 805.938.9038 CALSTAR 2 CALSTAR 4 CALSTAR 6 

540 Cohansey Ave. 1351 S. State St. CAL STAR 1901 Airport Blvd. CALSTAR 8 

Gilroy, CA 95020 Ukiah, CA 95482 S. Lake Tahoe. CA 

408.848.2075 707.462.5972 96150 

530.54 4.2338 

May 18,2015 

U. S. Department of Transportation, 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) of Title 14 of the Code of Federal Regulations. 

California Shock Trauma Air Rescue is an Air Ambulance operator with over 30 

years of experience 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). 

Thank you 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 of Operations 

Enclosure 

CALSTAR.ORC Critical Care in Motion 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 will 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 that 
generally does not include any severe or convective activity, such as these stratus or marine 

fayers. 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 

by permitting helicopter air ambulance operators to continue IFR approaches into hospitals and 

airports using weather reports from nearby stations rather than requiring weather reports 

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 T AFS'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 or other 

hazardous weather conditions" with aircraft that do not have thunderstorm detection equipment or 

airborne weather radar installed. 

CALSTAR GOM 5.14 (C) states: "if thunderstorms or other potentially hazardous weather 

conditions exist or is expected along the route of flight, CALSTAR aircraft equipped with 

thunderstorm detection equipment or airborne weather radar equipment must have this 

equipment in operational condition. Pilots will not depart into forecast thunderstorms 

unless the aircraft is equipped with operable thunderstorm detection or airborne weather 

radar equipment." 

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