AFS-13-348-E

August 26, 2013

 Exemption No. 6175I

 Regulatory Docket No. FAA-2001-9195

Mr. Matthew Zuccaro

President

Helicopter Association International

1635 Prince Street

Alexandria, VA 22314

Dear Mr. Zuccaro:

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

No. 6175, 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 April 25, 2013, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Helicopter Association International (HAI) and Association of Air Medical Services 

(AAMS) for an extension of Exemption No. 6175, as amended. That exemption from 

§ 135.213(a) of Title 14, Code of Federal Regulations (14 CFR) permits part 135 certificate 

holders that conduct helicopter air ambulance (HAA) operations, and are members of both the 

HAI and AAMS, to conduct HAA departures under instrument flight rules (IFR). These 

departures occur in weather that is at or above visual flight rules (VFR) minimums, from 

airports or heliports at which a weather report is not available from the U.S. National Weather 

Service (NWS), a source approved by the NWS, or a source approved by the Administrator.

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 FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to HAI. 
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 6175, 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 grant your petition, subject to the conditions and limitations listed 

below.

Conditions and Limitations

1. Only departures are authorized under this exemption. Instrument approach procedures 

(IAP) are not authorized under this exemption.

2. Use of this exemption is authorized only at airports or heliports at which a weather 

report is not available from the NWS, a source approved by the NWS, or a source 

approved by the Administrator. IFR departures at such airports or heliports are 

authorized only after the pilot in command (PIC) of the affected flight determines that 

the weather conditions at the departure airport or heliport are at or above VFR 

minimums. This may be determined by the PIC’s own observation or that of another 

person competent under Condition No. 6 below to supply appropriate observations.

At any airport or heliport at which there is a weather report from the NWS, a source 

approved by the NWS, or a source approved by the Administrator, that weather report 

will be the controlling weather report. Thus, this exemption does not give the PIC, or 

anyone else, the authority to substitute his or her opinion as to the weather conditions 

if the airport or heliport has a weather report from the NWS, a source approved by the 

NWS, or a source approved by the Administrator.

3. Departures under this exemption are authorized only for flights on which there is a 

patient who has a medical condition that requires, and is appropriate for, transportation 

by HAA. This medical determination will be made by the medical provider who has 

evaluated the patient. Departures are not authorized under this exemption for the 

transport of patients who do not require transportation by HAA, for the routine 

transport of patients, or for any other type of transportation or operation.

4. Each pilot who conducts operations under this exemption must be:

a. Certificated to conduct the IFR operations permitted;

b. Trained in accordance with the certificate holder’s approved training program;

c. Qualified in accordance with qualification requirements of part 135; and

d. Current in all requirements to perform operations under IFR in the model of 

helicopter that is being utilized.
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5. Each helicopter operated under this exemption must be fully equipped and certified to 

conduct IFR operations under part 135. Each helicopter operated under this exemption 

must be equipped with an approved and operable radar altimeter and either an 

approved and operable weather radar or approved and operable lightning detection 

equipment.

6. Before conducting any operation under this exemption, each certificate holder must 

submit to, and have approved by the FAA principal operations inspector assigned to 

the certificate holder, an amendment to the certificate holder’s approved training 

program. The amendment must include the ground school course curriculum proposed 

by HAI and AAMS in the original exemption. Authorization is limited to pilots who 

annually complete an approved course on weather observation and instrument 

operating procedures for locations without weather reporting. The ground school 

course curriculum must include, as a minimum, the following:

a. 14 CFR Review—review of parts 1, 61, 91, and 135 as they apply to flight 

under IFR (1.5 hours);

b. Airmen Information Manual (AIM) Review—a review of AIM with special 

emphasis placed on IFR operations as covered in Chapter 5 of the AIM 

Glossary (1 hour); 

c. Interpreting Weather and Weather Reports/Forecasts—review of weather 

phenomenon and systems, as well as weather services available to the pilot 

such as sequence reports, area and terminal forecasts, pilot reports, and 

in-flight advisories (2.0 hours);

d. Instrument Chart Review—covers instrument flight planning, instrument 

procedures at both controlled and uncontrolled airports, and a review of

instrument charts (2.0 hours); 

e. Cockpit Resource Management (CRM)—review of key CRM concepts such 

as decision-making and judgment, situational awareness, and management of

flight resources (1.5 hours); and
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f. Methods for Determining Weather Observations by the Pilot—covers methods 

for determining present visibility (measured or estimated), methods for 

determining estimated ceilings, and the methods for weather observation used 

by the NWS (2.0 hours). 

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 6175, as amended, to 

September 30, 2015, unless sooner superseded or rescinded. 

Sincerely,

/s/

Michael J. Zenkovich

Deputy Director, Flight Standards

Service