DEP ARTMENT OF THE AI R FORCE
HEADQUARTERS AIR FOR CE FLIGHT STANDARDS AGENCY

10 Jun 1 6

MEMORANDUM FOR HQ FAA/AGC

- 10

FROM: HQ AFFSA/ XOF 6500 South MacArthur Blvd, Bldg 4 Oklahoma City, OK 73169

SUBJECT: 14 CFR Exemption 4371 Renewal (Regulatory Docket FAA

- 2000

- 8093)

1. FAA Exemption 4371 was granted to the United States Air Force on 21 Jun 85; as amended to 4371 M on 19 April 20 1 3 , it exempts USAF aircraft from the provisions of Title 14, Code of Federal Regulations § 91.177(a)(2) and 91.179(b)(1) . Military Training Route (M TR) operations are not governed by this exemption since their operations are covered in FAAO 7610.4. T he requirement for USAF aircraft to conduct low

- level operations without complying with en route minimum altitudes for flight under instrument flight rul es (IFR) or direction of flight requirements for IFR en route segments in uncontrolled airspace has changed

.

2 . At a minimum , the USAF requests that the FAA grant a renewal of the parameters within the current Exemption 4371M. The current exemption st ates:

a. “ Operations under this exemption must be conducted at an altitude of at least 250 feet (with Terrain Following/Terrain Avoidance (TF/TA) Radar Systems) above the highest obstacle along the route of flight or 500 feet (without TF/TA) above the highest obstacle within 3 nautical miles (nm) of the course to be flown over mount ainous and other areas. Rotary

- W ing aircraft may operate at an altitude of at least 100 feet (with TF/TA) above the highest obstacle along the route of flight. ”

b. “The max imum route length authorized under this exemption is 40NM.”

3

. However, d ue to technological advances in aircraft systems, as well as current and future operational requirements, the Air Force needs to train aircrew and employ aircraft at altitudes lower and distances longer than granted in the current exemption The refore, the USAF requests the following amendments to 4371M:

a. All aircraft operating within Special Use Airspace (SUA) : i. May fly as low as the bottom of the SUA floor when authorized by the appropriate military authority.

b. Fixed

- Wing Aircraft operating IFR outside SUA or MTRs: i. Minimum altitude when employing Terrain Following/Terrain Avoidance (TF/TA) procedures will be no lower than 200 feet Set Clearance Plane (SCP)

. ii. Minimum altitude when employing visual low

- level procedures will be no lower than 100 feet above obstacles.GLOBAL ACCESS FOR AMERICA

c. Rotary

- Wing Aircraft operating IFR outside SUA or MTRs: i. Minimum altitude when employing TF/TA pr ocedures will be no lower than 100 feet SCP. ii. Mini mum altitude when employing visual low

- level procedures will be no lower than 50 feet above obstacles.

d. Tilt

- Rotor Aircraft operating IFR outside SUA or MTRs: i. Minimum altitude when employing TF/TA pr ocedures in “Airplane” mode will be no lower than 1 00 feet SCP. ii. Minimum altitude when employing TF/TA pr ocedures in “Conversion” mode will be no lower than 50 feet SCP. iii. Minimum altitude when employing visual low

- level procedures in “Airplane” mode will be no lower than 100 feet above obstacles. iv. Minimum altitu de when employing visual low

- level procedures in “Conversion” mode will be no lower than 50 feet above obstacles.

e. All aircraft operating IFR outside SUA or MTRs under this exemption are limited to a maximum route length of 2 40NM.

4 . T he requested altit ude s and route lengths represent an attempt to update the current exemption to complement newer capabilities of USAF aircraft and aircrews. Low

- level flight is an operational requirement for USAF aircrews performing missions in the support and defense of national interests and public safety. As a result, aircrews must be tr ained and proficient with the latest flight technologies and procedures in order to ensure a high probably of real

- world mission success. The lower altitudes will allow aircrew to dep loy aircraft resources closer to mission objectives within more austere terrain and weather conditions. The requested maximum route length of 240NM provides adequate terrain variation and approximately 60 min utes of flight time ( where as a 40NM route only provide s 10 minutes) . T his additional time is necessary to replicate effective mission scenarios and provide proper training credit as mandated by USAF regulations

. It will also reduce the negative impacts to safety and fuel efficiency that would be created by multiple route and altitude changes.

5

. Safety will be ensured during all of the above military operations through a combination of airframe technology , tr aining, and mission planning. The proper military authority will limit operations by airframe based upon capabilities (i.e. TF/TA set performance, operating low

- level airspeeds, etc.) and mission requirements. A large number of military airframes must train to low

- level operations to accomplish their mission

- set and it is therefore imperative for them to perform low

- level IFR operations below 1000 feet.

a. USAF aircraft possess the following technologies tha t give them the capability to fly safely at the requested altitudes and route lengths.

i. Fixed

- wing aircraft possessing the TF/TA radar are capable of flying at lower altitudes of 200’ SCP in IMC conditions. When employing visual low

- level procedures, fixed

- wing aircraft possessing the Operational Flight Programs (OFP) have the capability to alert aircrews through visual and audio cues if they descendGLOBAL ACCESS FOR AMERICA below the minimum altitude and provide a climb command that is displayed on the Primary Fli ght Reference instrumentation. In conjunction with the TF/TA radar and OFPs , aircrews utilize Night Vision Devices ( NVD s ) , Infrared Detection Set (IDS), Electro

- Optical Infrared (EO

- IR), Traffic Alert and Collision Avoidance System (TCAS)

, and Ground Coll ision Avoidance System (GCAS) to assist in safely avoiding terrain, obstacles, and other aircraft

.

ii . Rotary

- wing aircraft possess a dual radar altimeter for low

- level flight which includes an audible and visual altitude alert feature with an additional radar altitude display on the heads down display (HUD), as well as a Forward Looking Infrared Radar ( FLIR ) for augme nting day and night vision.

iii. R otary

- wing aircraft possess ing the Helicopter Terrain Awareness and Warning System/Traffic and C ollision Alert Device (HTAWS/TCAD) have the capability to provide audio and visual warning of terrain, obstacles

, and other transpo nder equipped aircraft. The Electronic Horizontal Situation Indicator (EHSI) combines course and heading guidance, weather data

, as well as map and airspace overlays on a single customizable d isplay reducing pilot work load and improving situation al awareness. NVD modification s enhance visual acuity by significantly reducing non

- compatible emissions from within the cockpit while ensuring instrumentation is easily readable.

iv. Tilt

- rotor aircraft possessing the TF/TA radar are capable of fly ing at lower altitudes of 1 00’ SCP (“airplane mode”) and 50’ SCP (“conversion” mode) in IMC conditions

. Additionally, this radar is used in conjunction with NVD and
FLIR technology in order to ensure safe operations.

v. Finally, USAF aircraft possess embedded GPS and RNAV navigation systems to increase lateral positional accuracy and awareness.

b

. The USAF believes it can conduct low

- level operations at the same level of safety , in class G airspace, outside of Military Training Routes and Special Use Airspace without endangerment to the public.

i. Flights within class G airspace will be limited to the m inimum needed to accomplish mission and training objectives. USAF aircraft will continue to attempt to conduct low

- level flights within SUA and MTRs to the maximum extent possible.

i i. Flight duration at the lower altitudes will be limited to the m inimum needed to accomplish mission and training objectives.

i ii . TF/TA equipment have been tested and proven to be effective and safe at the requeste d altitudes and within the capabilities of the aircraft . Aircrews are augmented with the numerous technologies listed in the previous paragraph to assist in safely avoiding other aircraft, obstacles, and persons.GLOBAL ACCESS FOR AMERICA iv

. Aircrews receive extensive training on the employment of low

- level equipment and procedures utilizing simulators, day VFR training flights, and night VFR training flights before performing any IMC low

- level operations. This is further complemented with co ntinuous training sorties which are designed to build aircrew proficiency in both day and night low

- level missions.

v . T he USAF routinely uses risk

- mitigation techniques such as defined climb

po ints, thorough route

- study, avoidance of populated areas

, and review of emergency actions

. T raining is conducted in sparsely populated areas, overwater, or within Low Altitude Tactical Navigation (LATN) training area s

.

v i

. W here feasible, pilots are augmented with additional crewmembers who monitor systems and altitudes and detect possible risks with terrain, other aircraft, and overall public safety, especially when employing visual low

- level procedures

.

v ii . C urrent navigation systems utilizing GPS and RNAV technologies will provide the same positional accuracy and awareness and have no neg ative effect upon extending route lengths to the requested 240NM.

c . G ranting this amendment is in the public interest because it provides USAF aircrews the ability to train with the newest capabilities which will further increase the probability of success in performing missio ns that support national security , search

- and

- rescue, humanitarian assistance, and disaster relief, even i n austere conditions . Additionally, such training will ensur e air crews remain qualified and proficient to perform at these lower altitudes without posing a threat to public safety.

6 . If this exemption is not granted, the USAF will not be able to train to meet current real

- world flight operational requirements at the lower altitude parameters . USAF flying operations must continuously adapt to an ever changing mission set to meet national security, search

- and

- rescue, and humanitarian relief mission needs. Realistic and adequate training scenarios may be hindered or not available with SUA or MTRs. Additionally, without approval, a ll training for IFR low

- level operations will be forced to occur in MTRs, increasing MTR workload as well as increas ing chance s of flight

- path deconfliction challenges. Safety could be n egatively impacted and critical training for contingency operations will be lost impacting the USAF’s ability to accomplish dynamic domestic and global mission s

.

7

. Please contact me at ( 405 ) 734

- 4298 or hqaffsa.xof@us.af.mil if there are any questions o r

concerns

. Thank you in advance for your assistance.

6/10/2016



# X Christopher M. Shea

CHRISTOPHER M. SHEA, Lt Col, USAF HQ AFFSA, Flight Directives Division Signed by: SHEA.CHRISTOPHER.M.1010528379