10888 South 300 West South Jordan, UT 84095 

Phone (801) 619-4900 1 Fax (801) 619-8077 1 Web www.amrQ.com 

Description of Requested Relief 

This is a petition to the Federal Aviation Administration (FAA) pursuant to 14 CFR Section 11.61 for an 

exemption from 14 CFR 135.611(b), as that section has been recently interpreted by the FAA's Flight 

Standards Service in internal guidance to Principal Operations Inspectors. Air Medical Resource Group 

(AMRG) is seeking immediate relief to the extent necessaiy to allow AMRG to resume performing 

instrument flight rules (IFR) departures an approach procedures (IAP) at airports and or heliports that 

do not have an approved weather repoi•ting source without airborne radar or lightning strike detection 

equipment installed in its helicoptei•s with a passenger seating configuration of 9 seats or less (excluding 

any pilot seat). Consistent with AMRG Operations Specification and its operational practice for several 

years before interpretation, the requested exemption, if granted will be limited as follows: 

A. The exemption would apply to operations of AMRG helicopters with a passenger seating configuration 

of 9 seats or less (excluding any pilot seat) listed in our Operations Specifications when - 

1. Current weather reports or forecast indicate that there is no reasonable possibility of 

thunderstorms or other severe weather expected to exist at the destination, alternate or along the 

route to be flown for the period of time planned for the flight; and - 

2. Additional preflight planning is triggered by the AMRG Preflight Risk Assessment Program that 

must be completed before the first leg of each 1-lelicopter Air Ambulance Operation (HAAO), 

conducted under § 135.611. 

B. For a flight to be conducted under § 135.611, the additional weather briefing, flight rnonitoring and 

related training actions described below must be talcen. These actions are describeci in the AMRG 

General Operations Manual and Approved Training Programs. 

1. Additional Weather Briefing Requirements for Flights Under Section 135.611 

a. The pilot will use information obtained frorn the National Weather Service to determine 

that there is not reasonable possibility of tllundei•storms or other severe weather 

conclitions expected to exist at the destination, alternate or along the route to be flown for 

the period of time planned for the fliglht; 

b. '1'lie following aviation weather products must be reviewed in malcing that determination; 

AIItMET, SIGMET, CONVECTIVE SIGMET, METAR, REGIONAL NEXRAD, NOTAM, PIREP, and 

TAF; and - 
10888 South 300 West South Jordan, UT 84095 

Phone (801) 619-4900 1 Fax (801) 619-8077 1 Web www.amrq.com 

c. No IFR operation under Section 135.611 will be released if current weather reports for 

forecasts indicate the potential for thunderstorms or other severe weather to exist at the 

destination, alternate or along the route to be flown for the period of time planned for the 

flight. lf such potential exists, the pilot must refuse the flight. 

2. Flight monitoring by the Operations Control Center 

Once the flight becomes active, the AMRG Operations Control Center uses specialized software that 

automatically monitors the flight plan, current position and destination of all active flights. The AMRG 

Operations Control Center continuously monitors all flights for thunderstorms and severe weather 

and provides that information to the pilot by: 

• Relay through the Communications Center to the pilot; 

• Contacting the pilot directly over our internet based voice communications system; or 

• Contacting the pilot directly via satellite phone. 

The Operations Control Center provides general advice such as, "there are thunderstorms to your 

west - recommend you divert to the east." 

1' ► •aining for our pilots and operations control specialists will be completed on an annual basis and 

inclucies: 

a. IFR Flight Planning (4.0 hours) 

b. Use and interpretation of NWS weather charts (2.0 hours) 

c. Interpretation of live radar feeds (2.0 hours) 

d. SIGMETS and AIRMETS (2.0 hours) 

e. METARS and TAFs (2.0 hours) 

E lnterpretation and appropriate use of available cockpit weather displays (2.0 hours) 

g. The applicability and use of this exemption (1.0 hour) 

Granting the Requested Exemption would enhance safety anci is in the Public tnte,•est 

AMRG maintains that it is in the public interest to utilize the IFR infrastructure to the fullest extent 

possible thereby avoiding the potential for controlled flight into tei•rain (CF1T) accidents caused by pilots 

trying to remain VFR wlien weather is marginal. The public interest also will be served by increasing tlie 

opportunity for additional access to critical care patient flights. 
10888 South 300 West South Jordan, UT 84095 

Phone (801) 619-4900 1 Fax (801) 619-8077 1 Web www.amrq.com 

AMRG believes that, by granting this petitions, the FAA will permit an alternate means of compliance that 

is an equivalent level of safety as provided by § 135.611(b) to be maintained an will be acting in a manner 

consistent with the aviation safety goal of § 135.611. AMRG believes that the true mitigation of the risk of 

operations in areas of severe weather lies in effective and consistent preflight planning and training for 

its pilots and operational control oversight by the certificate holder. lf this exemption is not granted it 

would negatively affect the public interest by reducing the number of available HAA flights. A fully 

trained crew, following proper IFR procedures, in a properly equipped aircraft, can only enhance safety. 

The underlying purpose of § 135.611 is to facilitate IFR operations by helicopter air ambulance operatoi -s 

and result in more aircraft operating in a positively controlled environment, thereby increasing safety. 

The i-ecent interpretation of the rule instead has the unintended consequence of encouraging HAA 

ope ► •ators to fly in marginal weather conditions under VFR because the interpretation requires Airborne 

Weather Radar or Lightning Detection equipment. 

AMRG is conimitted to the safe and successful completion of its air medical flights and believes that it is 

safei-to file anci IFR flight plan and to operate under IFR than to conduct flight operations under VFR in 

marginal VMC weather conditions has been the single most frequent causal factor in EMS airci -aft 

accidents 

AM RG further believes that the proposed exemption is in keeping with the safety purpose of the i•u le by 

permitting HAA operators the ability to operate in accordance with IFR more often. This woulcl i>>iniiTiize 

the need for marginal VFR flight operations. 

Granting the prosed exemption in regard to § 135.611(b), as interpreted, would not promote tlights into 

severe weather, because AMRG does not conduct IFR operations in seve ► •e weather conclitions. 

Further Justifying Infornlation 

i111 AN/t 12G aircraft fly with an electronic flight bag (EFB), with the Forelfight mobile APP. This allows pilots 

inl'light to flight plan, checic weather and airport information. With this info ►•n~ ation readily available to 

the pilot and the oversight provided by the Operational Control Center, this will provide a redundant 

system that will prevent pilots from flying into severe weather. This is in addition to the training and 

limitation of not flying in severe weather. 
10888 South 300 West South Jordan, UT 84095 

Phone (801) 619-4900 1 Fax (801) 619-8077 1 Web www.amra.com 

Summary 

In Summary, immediate granting of the requested relief will enhance aviation safety and be in the public 

interest. Each day that passes without relief from the recent interpretation of §135.611(b) prevents safe 

IFR operations and unnecessarily restricts public access to air niedical transportation. We appreciate you 

positive and expeditious consideration of our request for this relief. 

Respectfully sub itted, 

~ 

Mark Chmieleski 

Director of Operations 

Air Medical Resource Group 

10888 South 300 West 

South Jordan, UT 84095 

markchmieleski0amrg.com 

801.619.4900 

Swiimary of Petition for Publication 

AM RG seeks an exemption for § 135.611(b) of Title 14 of Code of Federal Regulations, as that section has 

been recently interpreted by the FAA's Flight Standards Service in internal guidance to Principal 

Operations Inspectors. AMRG is seeking relief to the extent necessary to allow AMRG to resume 

performing instrument flight rules (IFR) departures and to perform IFR instrument approach p ► •ocedures 

(IAP) at airports and or heliports that do not have an approved weather reporting source without 

airborne r•adar or lightning strike detection equipment installed in its helicopters with a passenger 

seating configuration of 9 seats or less (excluding any pilot seat), witli limitations consistent with the 

company's past operating practices.