April 11, 2011 

RE: Petition for limited exemption from 14 CFR 135.267(c) 

To Whom It May Concern: 

This letter is to petition for an exemption. 

Background and reasons for the petition: 

The timely transportation of donor organs is a vital public life saving service. Chrysler Aviation, 

Inc. a FAA part 135 Certificate Holder has provided such services on an around the clock, 

nationwide basis for more than 20 years to a number of hospitals and transplant transportation 

originations using jet aircraft. These missions need rapid response capability using highly 

trained and dedicated jet pilots. 

Typically the missions involve the pickup of a surgical team of doctors and nurses, mostly from 

the home base of Chrysler Aviation and sometimes by a flight empty to a pick up airport. These 

flights are filed as "LN" and are afforded ATC priority as a "Lifeguard" flight. The transplant 

team is then flown to an airport nearest the organ donor hospital. The flight crews then stand by 

at the airport. The time required varies depending on the distance to the hospital and the 

readiness of the operating room as well as the medical procedures involved. Often more than one 

organ is involved and sometimes multiple surgical teams harvest the organs. Usually the surgical 

team alerts the flight crew about 30 to 60 minutes before their return to the airport. The flight 

then proceeds to the airport closest to the hospital where the organ recipient is waiting. The 

Lifeguard portion of the flight ends when the surgical team departs the aircraft to return to the 

recipient’s hospital. If not at the home base the team repositions the aircraft to its home base. 

Depending on the distance between the airports utilized the flight crews are on duty from 4-14 

hours total. 

A medical emergency involving the surgical procedure or ground transportation logistics beyond 

the control of Chrysler Aviation, the Certificate Holder conceivably could delay the flight 

beyond the duty time limits posed by FAR 135.267(c). 

This situation poses the risk that the recipient could die because the useful life of the organ is 

limited and the recipient is often in dire need of the transplant (which was the justification for the 

use of a jet plane) to insure the timely delivery of the donor organ. 

A limited exemption from the duty limits of FAR 135.267 (c) for a bona fide medical emergency 

is requested which would extend the duty limit to 16 hours under the following 

conditions: 

Chrysler Aviation, Inc. 

7120 Hayvenhurst Avenue, Suite 309 

Van Nuys, California 91406-3836 

Telephone (818) 989-7900 · Fax (818) 989-0116 

www.ChryslerAviation.com
1. A bona fide medical emergency exists which is beyond the control of 

The Certificate Holder which leads to a delay period; 

2. There is insufficient time to dispatch another crew which could 

complete the flight within the time limits specified in FAR 135.267(c) 

3. There is insufficient time in the opinion of a medical doctor with 

knowledge of the medical situation to delay the transportation to 

replace the aircraft with an alternative aircraft without jeopardizing 

either the organ or the recipient or medical team availability to complete the medical 

procedures necessary; 

4. Adequate rest facilities exist and are utilized during the delay 

period by the flight crews; 

5. The total flight time does not exceed 10 hours; 

6. Immediately following the flight the flight crew is provided the 

rest period specified in FAR section 135.267(e) 

7. The total duty time does not exceed 16 hours. 

In support of this petition I have attached letters from Helinet Aviation and Transplant 

Transportation Services, Inc. 

Respectfully submitted, 

Eugene W. Comroe 

Director of Operations 

Encl. 

 <Helinet letter.pdf> 

 <TTSI letter.pdf>