April 11, 2011

RE: Petition for limited ex emption 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 v ital public life saving serv ice. Chrysler Aviation, Inc. a FAA part 135 Certificate Holder has pr ovided 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 missi ons need rapid response capability using highly trained and dedicated jet pilots.

Typically the missions involve the pickup of a surg ical 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 pr iority as a "Lifeguard" flight. The transplant team is then flown to an airport nearest the or gan donor hospital. The flig ht crews then stand by at the airport. The time required varies de pending on the distance to the hospital and the readiness of the operating room as well as the me dical procedures involve d. 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 retu rn 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 e nds when the surgical team depart s 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 u tilized the flight crews are on duty from 4-14

hours total.

A medical emergency involving th e surgical procedure or ground transportation logistics beyond the control of Chrysler Aviation, the Certificat e 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 usef ul life of the organ is limited and the recipient is often in dire need of the transplant (w hich was the justification for the use of a jet plane) to insure th e 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.com1. A bona fide medical emergency exists which is beyond the control of

The Certificate Holder whic h leads to a delay period;

2. There is insufficient time to disp atch another crew which could complete the flight within the tim e limits specified in FAR 135.267(c)

3. There is insufficient time in the op inion of a medical doctor with knowledge of the medical situation to delay the transportation to replace the aircraft with an altern ative aircraft without jeopardizing either the organ or the recipi ent 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 doe s not exceed 10 hours;

6. Immediately following the flight th e 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 Av iation and Transplant Transportation Services, Inc.

Respectfully submitted,

Eugene W. Comroe Director of Operations

Encl. <Helinet letter.pdf> <TTSI letter.pdf>