P P ^ kA pi^T j A TR 1515 Tongass Avenue Ketchikan, Alaska 99901 

mcH,KAM.A..sKA p^^^^ ^^^ ^ 225-3845 Fax (907) 247-3875 

October12, 2011 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor, 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

RE: Extension of Exemption 8674B Docket No.FAA-2005-23001 

Dear Administrator: 

PM AIR LLCdba Promech Air request an extension of Exemption 8674B from Part§ 135.203(a)(1) of Title 14, CFR 

which allows PM AIR LLC to conduct operations under part 135 to operate seaplanes under visual flight rules 

outside controlled airspace, over water, and below 500 feet above the surface. 

PM AIR LLC dba Promech Air states that the facts, conditions, circumstances, and reasons remain the same as 

presented in the original exemption and subsequent petitions for extension. Additionally, PM AIR LLC has operated 

successfully under this exemption since the date of decision by the FAA. 

AMENDMENTS: To Exemption 8674B Docket No. FAA-2005-23001 Dated October 9. 2009 

PM AIR LLC dba Promech Air would like to add an amendment from the original issued exemption under 

"Conditions and Limitations": 

1. PM AIR must conduct operations under this exemption: 

(e) Within U.S. airspace defined by a line from: Change to read the following: 

Confinement to the area of Tongass Narrows, to Confinement to the area of Ciarence Strait southern 

portion defined by a line extending from Kendrick Island (latitude 54° 53 N. longitude 131° 58 W) to 

Percy Island (latitude 54° 55 N. longitude 131° 35 W), to Ciarence Strait northern portion defined by a line 

extending from Point Colpoys (latitude 56° 20 N. longitude 133° 11 W) to Macnamara Point (latitude 56° 19 

N. longitude 133° 03 W), 

to Confinement to the area of Whale Passage, to Confinement to the area of Lake Bay, to Confinement to 

the area of Thome Bay, to Confinement to the area of Tolstoi Bay, to Confinement to the area of Kasaan 

Bay, to Confinement to the area of Karta Bay, to Confinement to the area of Twelvemiie Arm, to 

Confinement to the area of Skowl Arm, to Confinement to the area of Polk Inlet, 

to Confinement to the area of McKenzie Inlet, to Confinement to the area of Cholmondeley Sound, 

to Confinement to the area of Moira Sound, to Confinement to the area of Nichols Passage, to Confinement 

to the area of Felice Strait, 

to Confinement to the area of Reviilaqiqedo Channei southern portion defined by a line extending from 

Mary Island Edge Pilot (latitude 55° 02 N. longitude 131° 11 W) to Kah Shakes Cove (latitude 55° 02 N. 

longitude 130° 59 W), to confinement the area of Boca De Quadra, to confinement the area of East Behm 

Canal and West East Behm Canal 
to Confinement to the area of Thome Arm, to Confinement to the area of Carroll Inlet, to Confinement to the 

area of George Inlet, to Confinement to the area of Clover Passage, to Confinement to the area of Helm 

Bay, to Confinement to the area of Traitors Cove, to Confinement to the area of Neets Bay, to Confinement 

to the area of Gedney Pass, to Confinement to the area of Spacious Bay, to Confinement to the area of Yes 

Bay, to Confinement to the area of Hassler Pass, to Confinement to the area of Bell Arm. 

PM AIR, LLC petitions the amendment "Conditions and Limitations" of the above mentioned Airspace Defined. As 

this will greatly reduce the Original Airspace defined to a much smaller scale and scope and a more practical usage 

to our areas of air commerce in which we operate. 

Also noted that the amendment Airspace Defined does not include any points in Canadian Airspace. 

PM AIR, LLC Equivalent Level of Safety Areas: 

Pilot Flight Training: 

PM AIR LLC is proposing that an equivalent level of safety to Exemption 8674B can be achieved through pilot flight 

training in which, each PM AIR Pilot operating under this exemption will receive annual flight training en-route at 

200 feet above the surface in a simulated emergency landing downwind to allow for a safe accomplishment of an 

unscheduled water landing. 

Pilot Flight Training and PM AIR. LLC Company Culture Safetv: 

The Medallion Foundation, Inc. is a non-profit aviation safety organization that provides management resources, 

training and support to the Alaskan aviation community. The Medallion Five Star Shield program is an enhanced 

Safety Management System (SMS) that takes a business-like approach to safety, providing for the setting of goals 

as well as planning and measuring performance in specific areas through the use of System Safety concepts. A 

Safety Management System can be defined as a systematic, explicit and comprehensive process for the 

management of safety risks. Another definition is an integrated set of work practices, beliefs and procedures for 

monitoring and improving the safety and health of all aspects of an operation. 

The Medallion Five Star Shield program is voluntary and focuses on establishing and sustaining an elevated level of 

safety performance through: 

• The development of a safety culture that holds safety as a core value. 

• Continuous professional development of individual skills and competence. 

• Proactive sharing of operational control responsibilities. 

• Hazard identification and risk management. 

• Management practices that support the organization's safety objectives 

PM AIR, LLC is a participant in the nationally acclaimed Medallion Foundation Aviation Safety Program. The 

program was established to provide safety management systems and support to Alaska aviators. The foundation 

uses a Five-Star Program to provide process guidelines, training, and follow up with audit support and coordination 

to ensure compliance. PM AIR, LLC has been awarded 1 out of the 5 stars. PM AIR, LLC is in the process of 

acquiring the coveted Medallion Shield award. The CFIT Avoidance Star is awarded in the following disciplines: 

CFIT Avoidance Star - PCATD/Simulator Training Program - Awarded Aprii 2010: This star includes a classroom 

training program as well as training on a PC based computer simulator or equivalent device. Each PM AIR, LLC 

Pilot is trained to the standards policies and procedures that PM AIR, LLC will use in relation to CFIT Avoidance 

during all phases of flight in the following: Deteriorating Visibility, Flat Light, and White-out Inadvertent IMC 

Conditions. The CFIT Avoidance Star Program addresses CFIT risks. 
The Alaskan Region's "Capstone Program" Technology: 

PM AIR, LLC has installed state-of-the-art navigation technology in all DeHavilland Beaver and Otter floatplanes in 

its fleet because of an uncompromising commitment to safety. This program is intended to reduce the incidence of 

weather-related accidents, mid-air collisions and terrain-based concerns. This is achieved by improving a pilot's 

situational awareness through advanced technologies, modern avionics, and information services. 

The Alaskan Region's "Capstone Program" is a technology focused Safety Program in Alaska that seeks near term 

safety and efficiency gains in aviation by accelerating implementation and use of modern technology. Capstone 

links multiple programs and initiatives under a common umbrella for planning, coordination, focus and direction. It 

also develops capabilities and requirements jointly with FAA, the Alaskan community and aviation industry in a 

manner consistent with future National Airspace System plans and concepts, with implementation in a manner 

leading to self-equipage. 

The Capstone program began in Southeast Alaska in FY2001. Capstone is an accelerated effort to improve aviation 

safety and efficiency through the installation of government furnished Global Positioning System (GPS) based 

avionics and data link communications suites in commercial aircraft. Compatible ground systems, equipment, and 

services are also provided. The name "Capstone" is derived from the program's effect of drawing and holding 

together concepts and recommendations contained in reports from the National Transportation Safety Board, the 

Mitre Corporation's Center for Advanced Aviation System Development, and Alaskan aviation industry 

representatives. In addition to the avionics suites. Capstone will deploy a ground infrastructure for weather 

observation, data link communications, surveillance, and Flight Information Services to improve safety and enable 

eventual implementation of new procedures. 

CUE-BASED TRAINING: 

In July 27. 2009 PM AIR. LLC integrated the FAA Cue-Based Pilot Training Program into the Company FAR 135 

Flight Training Program. Each PM AIR. LLC pilot participates into the utilized program every year during initial and 

recurrent training. The following is a summary of the program: 

In 2007, the National Transportation Safety Board (NTSB) proposed Safety Recommendations A-07-18 through -26 

specific to Hawaii in response to past fatal air tour operator accidents. In light of the fatal air tour accidents in Alaska 

in 2007, A-07-18 was deemed relevant in Alaska as well. Work was therefore begun on the FAA Cue-Based Pilot 

Training Project under the Federal Aviation Administration Safety Team (FAASTeam) business plan in fiscal year 

2008 to reduce air tour accidents in Alaska and Hawaii. 

The NTSB then proposed Safety Recommendations A-08-59 through -62 for Alaska. A-07-18 (Hawaii) and A-08-61 

(Alaska) are very similar. They recommend that the FAA develop, in cooperation with commercial air tour operators, 

aviation psychologists, and meteorologists, among others, a cue-based training program for commercial air tour 

pilots that specifically addresses the hazardous aspects of local weather phenomena and in-flight decision-making. 

This product is the first stage in answering that challenge. 

Product Philosophy 

The NTSB concluded "...Cue-Based training, tailored to the dynamic local... climate conditions, could provide an 

important safety benefit to pilots who are new to flying in the state." We understand the importance of "Staying 

ahead of the aircraft," - and staying ahead of the weather. In-flight decision-making skills and local weather 

phenomena can be taught with advanced cue-based training technologies at a fraction of the cost of traditional inaircraft experience. And the more realistic the training experience, the better it transfers as a positive real-world 

habit for the pilot. 

To demonstrate this reality, this product is intended to impart the following capabilities: 

1. Understanding alternate route options 

2. Visualizing decision points at which visibility and wind velocity are checked 

3. Recognizing situational cues that must be evaluated before proceeding into an 

area of restricted maneuvering room. 
Proof-of-Concept - Misty Fjords 

This first iteration of visual cue-based training products is presented as a shared Standard Operating Procedure 

(SOP) program for Part 135 air tours operating in the Ketchikan, AK - Misty Fjords area. This area is commonly 

known for its stunningly beautiful geographic features; equally impressive are the flight challenges posed by such 

dramatic terrain and volatile weather conditions. 

In order to standardize the decision making process for flight continuation in deteriorating weather, the cue-training 

development team has enlisted the help of local flight operators to break the common tour routes into a series of 

shared flight segments. The end of each segment represents a fixed geographic location where pilots are expected 

to review conditions and make a conscious decision whether to continue on the route, select an alternate route, or 

return to base. This tool presents each of these routes in turn, with the decision points along the way. At each of 

these decision points, there is a visual cue or landmark that may be used in determining whether continued flight 

along the route is acceptable. 

These decision points, and their landmarks are set into geographic context through a series of virtual flight 

renderings and text descriptions. In order to help users apply the training in real 

world circumstances, the tool will also present three views of each landmark under different weather conditions. 

The first view will set the stage for identifying the landmark by presenting a clear day view of the landmark from the 

perspective of the decision point. The second view presents a view of the landmark on a marginal day, so that one 

may see how the context changes when the cue is just 

barely visible. The last view is an image of the landmark on a day that is considered impassible. Under these 

circumstances, visibility limits the pilot's perspective such that the visual cue is barely obscured. 

The possible responses to each of these conditions are described alongside the images. 

PM AIR LLC dba Promech Air request that the renewal of this exemption not be delayed by publishing in the 

Federal Register and states that this will not set a precedent. 

Your timely extension of the exemption, which expires on December 31, 2011, will allow us to continue to provide 

safe, efficient and timely air commerce to the traveling public. 

Authority to conduct in accordance with this exemption is in the public interest. 

Your assistance in this matter is appreciated. 

Best regards. 

Tony Dupea 

Chief Pilot 

PM AIR LLC dba Promech Air 

Enc: MAP Amendment Airspace Defined 

cc: Jon Percy POI 

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