AFS-16-12043-E 

September 6, 2016 

 Exemption No. 11197A 

 Regulatory Docket No. FAA-2014-0063 

Mr. Jason Kulbeth 

Director of Operations 

NorthStar Trekking, LLC 

P.O. Box 32540 

Juneau, AK 99803 

Dear Mr. Kulbeth: 

This letter is to inform you that we have granted your petition to extend and amend 

Exemption No. 11197. It explains the basis for our decision, describes its effect, and lists the 

revised conditions and limitations. 

The Basis for Our Decision 

By letter posted to the docket on June 7, 2016, you petitioned the Federal Aviation 

Administration (FAA) on behalf of NorthStar Trekking, LLC (NorthStar) for an extension 

and amendment to Exemption No. 11197. That exemption from §§ 136.9(a), 136.11(a), and 

136.11(c)(2) of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to 

allow NorthStar to operate helicopter commercial air tour flights over bodies of water and 

beyond shorelines crossed while equipped with a life preserver for each occupant but without 

each occupant wearing a life preserver and without its helicopters being float equipped. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 

The amendment you request would add an additional helicopter of the same make and similar 

model to the helicopter model already covered by the existing exemption. This addition does 

not materially alter the conditions and limitations as the added model has identical 

autorotational characteristics and performance as the original make and model. 
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The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension and amendment to the exemption 

would not set a precedent, and any delay in acting on this petition would be detrimental to 

NorthStar. 

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 11197 

remains valid with respect to this exemption and is in the public interest. Therefore, under the 

authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator 

has delegated to me, NorthStar Trekking, LLC is granted an exemption from 14 CFR 

§§ 136.9(a), 136.11(a), and 136.11(c)(2) to the extent necessary to allow Northstar to conduct 

helicopter tour operations, over water, not requiring passengers to wear life preservers while 

overwater within autorotational distance of a suitable landing area in an aircraft without fixed 

or inflatable floats, subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. NorthStar’s helicopters are always operated in a manner that precludes the possibility 

of landing in the water, unless meeting the requirements of 

§§ 136.9(a), 136.11(a), and 136.11(c)(2). 

2. NorthStar will conduct annual training for pilots using an FAA approved training 

module added to its 14 CFR part 135 training program. This module will address the 

environmental aspects and autorotational techniques unique to the specific approved 

routes used. Subjects must include specific tour routes and minimum altitudes, preflight analysis of winds, visibilities, and ceilings to pre-determine availability of 

minimum crossing altitudes along specific tour routes, appropriate diversion flight 

paths from those routes to several specific emergency landing sites surrounding the 

body of water to be crossed. The designated emergency landing sites for each flight 

will be chosen from sites that were previously identified, assessed, and approved by 

the operator. 

3. NorthStar will incorporate into its General Operations Manuals a requirement for its 

pilots to operate at or above the altitude needed to maintain power-off autorotational 

glide capability to designated site-specific emergency landing areas from any point 

over water on each of the subject routes. 

4. Any changes in engine type or helicopter make and model being operated by 

NorthStar Trekking will require the preparation of a detailed analysis demonstrating 

the probability of engine failure does not exceed the 10-6 acceptable risk and 

designated minimum altitudes, routes, and designated emergency landing areas are 

suitable for the new helicopter. This analysis has been presented and accepted for the 

following helicopter make and models: 
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a. Airbus Helicopter AS350B2 (Turbomeca Arriel 1D1 engine) 

b. Airbus Helicopter AS350B3e (Turbomeca Arriel 2D engine) 

5. NorthStar will continue to make life preservers readily available to each passenger on 

all air tour flights. Life preservers are mounted in NorthStar helicopters in an open slot 

located between each passenger’s legs. 

6. As part of the preflight briefing, NorthStar will instruct passengers on the location of, 

and proper donning and use of life preservers following a successful egress from the 

aircraft in the event of a forced water landing as required by § 136.7. 

The Effect of Our Decision 

This exemption terminates on March 31, 2019, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John Barbagallo 

Deputy Director, Flight Standards Service