AFS-11-412-E 

October 5, 2011 

 Exemption No. 7118I 

 Regulatory Docket No. FAA-2002-11655 

Mr. William E. Butts 

Intermountain Life Flight 

250 North 2370 West 

Salt Lake City, UT 84116 

Dear Mr. Butts: 

This letter is to inform you that we have denied your petition to amend Exemption 

No. 7118, as amended. It explains the basis for our decision, describes its effect, and lists the 

conditions and limitations. 

The Basis for Our Decision 

By letter dated July 22, 2011, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Intermountain Life Flight for an amendment to Exemption No. 7118, as amended. 

That exemption from § 133.45(e)(1) of Title 14, Code of Federal Regulations allows 

Intermountain Life Flight to conduct Class D rotorcraft-load combination rescue operations 

with an Agusta A109K2 helicopter certificated in the normal category under part 27. The 

amendment you request would amend Condition No. 4 by removing the phrase “repositioning 

flight to the nearest suitable landing zone to land the rotorcraft and load the rescue target in 

the rotorcraft.”

In your letter, you stated that compliance with this condition is “burdensome” and provides 

“little benefit toward proficiency....” 

Prior to the March 2011 grant of exemption, it was believed (albeit incorrectly) that each hoist 

iteration performed by Intermountain Life Flight resulted with the rescue target being 

recovered directly into the fuselage when it reached the aircraft. It was learned that, in 

actuality, a “short flight” to a nearby location to land and recover the rescue target into the 

aircraft was necessary. The rescue target remains outside the fuselage and attached to the 

hoist, thus remaining an external Class D load, during this time. The recovery of the rescue 
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target is incomplete until such time as this task of landing and loading the target is 

accomplished or the rescue target upon reaching the landing zone is able to depart the area 

under its own power. 

To not require the conditions listed in Condition No. 4 to be conducted would render the 

entire rescue activity incomplete and does not provide true scenario-based training for the 

crew. Therefore, your request to amend Condition No. 4 is denied. 

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 7118, as 

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

Therefore, under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA 

Administrator has delegated to me, I deny your petition. The conditions and limitations 

remain the same. 

Conditions and Limitations 

1. Intermountain Life Flight will conduct training for pilots and crewmembers in 

accordance with a Class D external load training program accepted by the 

Administrator before commencing the conduct of Class D rotorcraft load combination 

operations. The training program will include initial and recurrent training for pilots 

and other crewmembers, in accordance with § 133.37. 

2. Intermountain Life Flight must submit a request to the certificate-holding district 

office (CHDO) for an amendment to its Class D authorization and training program to 

allow the conduct of Class D external load rescue operations with these additional 

limitations. 

3. The rotorcraft used in such rescue operations will be equipped with Arriel 1K1 turbine 

engines. 

4. The pilot in command (PIC) for such rescue operations must have a minimum of 25 

hours of flight time as PIC in the Agusta A109K2. Additionally, each PIC must have 

successfully conducted 20 separate rescue hoist operations in the A109K2, either 

simulated or actual. Each of these hoist operations shall be conducted at an altitude 

that requires the aircraft to hover out of ground effect. Each hoist operation shall 

encompass the following elements: approach to the pickup site; establishment of a 

hover out of ground effect; establishment of a hoist lift where the rescue target is 

hoisted from the surface and is retrieved to a position next to the aircraft; repositioning 

flight to the nearest suitable landing zone to land the rotorcraft and load the rescue 

target in the rotorcraft; and departure from the landing zone. Flights between the 

rescue location and the nearest suitable landing zone must be conducted at a speed that 

allows for maximum control of the rescue target during its time outside of the 

passenger compartment. 
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5. This exemption is not valid for operations conducted below 2,500 feet mean sea level. 

6. This exemption is valid only for rescue operations undertaken to reduce or eliminate a 

significant imminent threat to human health or life and when no other civil aircraft is 

reasonably available that meets the requirements of § 133.45(e): 

a. In evaluating whether a threat is “significant and imminent,” Intermountain 

Life Flight, in consultation with appropriate and qualified rescue or medical 

personnel, must reasonably determine that a threat of serious injury or death is 

present; and 

b. In evaluating whether any other civil aircraft is “reasonably available,” 

Intermountain Life Flight must determine that, at the time of the rescue 

operation, no other civil aircraft meeting the requirements of § 133.45(e) is 

available and capable of responding to the threat in a timely manner. 

7. Prior to any flight conducted under this exemption, Intermountain Life Flight must 

conduct and document a risk assessment to determine that the operation can be safely 

conducted. A copy of each completed risk assessment must be retained for 2 years 

and made available on request to the CHDO. 

8. Intermountain Life Flight, in consultation with the appropriate rescue or medical 

personnel, must reasonably determine that an external load hoist operation is 

necessary to respond to the threat in that the rotorcraft external load hoist operation 

offers the best opportunity to reduce or eliminate the threat to human health or life. 

9. Transport of passengers rescued under this exemption must be conducted in 

accordance with the requirements of Intermountain Life Flight’s part 135 operating 

certificate (Certificate No. I7LA073J) and operations specification paragraph A021. 

10. Intermountain Life Flight must provide the FAA with current information on the status 

of its helicopter replacement project. This information must include an expected 

timeline for fleet replacement. This information must be provided to the CHDO on a 

yearly basis, beginning August 30, 2011. 

The termination date remains August 31, 2012, unless sooner superseded or rescinded. 

All conditions and limitations of Exemption No. 7118, as amended, remain the same. This 

letter must be attached to, and is a part of, Exemption No. 7118. 

Sincerely, 

/s/ 

Raymond Towles 

Acting Director, Flight Standards 

 Service