AFS-10-160-E 

March 12, 2010 

 Exemption No. 9698A 

 Regulatory Docket No. FAA-2008-0335 

Mr. Ryan McCue 

President 

RdM Pilot/Guide, Ltd. 

420 Front Street 

Ketchikan, AK 99901 

Dear Mr. McCue: 

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

No. 9698. It explains the basis for our decision, describes its effect, and lists the conditions 

and limitations. 

The Basis for Our Decision 

By letter dated February 1, 2010, you petitioned the Federal Aviation Administration (FAA) 

on behalf of RdM Pilot/Guide, Ltd. (RdM Pilot/Guide), for an extension of Exemption 

No. 9698. That exemption from § 135.203(a)(1) of Title 14, Code of Federal Regulations (14 

CFR) allows RdM Pilot/Guide to operate seaplanes inside the Ketchikan, Alaska, Class E 

airspace special visual flight rules (SVFR) below 500 feet above the surface. 

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 RdM Pilot/Guide. 
 2

Our Decision 

The FAA has determined that the justification for the issuance of Exemption No. 9698 

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 following conditions and limitations. 

Conditions and Limitations 

1. Each pilot in command employed by RdM Pilot/Guide shall comply with the 

following conditions and limitations: 

a. Operations are limited to seaplanes and amphibious aircraft being operated over 

water within an approved seaplane/amphibian SVFR corridor encompassing the 

Tongass Narrows and Ketchikan Harbor and underlying the Ketchikan Class E 

airspace. 

 b. Operations are authorized only during the hours of daylight or during the hours 

of Alaskan Civil Twilight when the sun is not more than 6 degrees below the 

horizon. 

c. Sky obscuration must exceed five-tenths cloud coverage and must preclude VFR 

flight at or above 500 feet above the surface before operations are authorized 

under the exemption. 

d. Aircraft may be operated below 500 feet above the surface down to an altitude of 

400 feet above the surface only when the flight visibility is at least 2 miles, the 

surface wind velocity along the approved route is 12 knots or less, and the height 

of the sea (waves) is 1 foot or less. 

e. Aircraft may be operated below 400 feet above the surface down to an altitude of 

200 feet above the surface only when the flight visibility is at least 3 miles, the 

surface wind velocity along the approved route is 12 knots or less, and the height 

of the sea (waves) is 1 foot or less. 

f. Operations are authorized only over open waterways, and operators must observe 

the minimum safe altitudes for emergency landings and separation clearance set 

forth in 14 CFR § 91.119(a) and (c). 

g. Operations are authorized only when wind and sea conditions allow for the safe 

accomplishment of an unscheduled landing. 

h. Aircraft position and anticollision lights must be on and functioning when 

operations are conducted under this exemption. 

 i. No aircraft may be operated under this exemption at an altitude of less than 

200 feet above the surface. 

2. RdM Pilot/Guide is authorized to enter into a written agreement with the manager of 

the Ketchikan Flight Service Station (FSS) and the manager of the Anchorage Air 

Route Traffic Control Center to allow simultaneous instrument flight rules (IFR) and 

SVFR operations in the Ketchikan Class E airspace, subject to the following 

conditions and limitations: 

a. The agreement must establish a corridor for SVFR seaplane operations that is 

sufficiently separated laterally and vertically from IFR arrival and departure route 

profiles to allow concurrent IFR and SVFR flight within the Class E airspace. 
 3

b. The corridor will encompass the Tongass Narrows and Ketchikan Harbor. 

c. Airspace within the corridor boundaries will extend from the surface of the water 

to 500 feet above the surface. 

d. Authorization to use the corridor is dependent on each certificate holder having 

on file with the Ketchikan FSS a current and valid letter of agreement. 

e. SVFR operations in the corridor may be suspended by the FAA without prior 

notice, when necessary, in the interest of safety. 

f. An SVFR clearance will be issued for each flight conducted under the terms 

specified in each certificate holder's letter of agreement and this exemption. 

g. Air traffic advisories will be provided to IFR and SVFR traffic at any time the 

SVFR corridor is in use under the terms specified in each certificate holder's letter 

of agreement. 

3. Operations are only authorized when the operator has determined that the weather 

outside of Class E airspace will allow compliance with 14 CFR § 135.203. 

4. RdM Pilot/Guide’s pilots must receive annual training on the conditions and 

limitations of this exemption. 

The Effect of Our Decision 

Our decision extends the termination date of Exemption No. 9698 to May 31, 2012, unless 

sooner superseded or rescinded. 

All conditions and limitations of Exemption No. 9698 remain the same. This letter must be 

attached to, and is a part of, Exemption No. 9698. 

Sincerely, 

/s/ 

John W. McGraw 

Acting Director, Flight Standards 

 Service