July 8, 2015

John Coryell

Life Flight LLC

1601 Fox Hollow Road

Greensboro, NC 27410

Dear Mr. Coryell:

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days.

Why We Can Not Process Your Request

We entered your April 23, 2015 exemption request on behalf of Life Flight LLC into the 

public docket (No. FAA-2015-1152), but we are unable to process your request any further. 

The information you sent does not comply with the requirements of § 11.81 (copy enclosed). 

For us to consider the request any further, you must send us all of the following:

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief.

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

 The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption.

 Any additional information, views, or arguments available to support your request.

What You Should Do

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption.
2

If We Do Not Hear From You

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677.

Sincerely,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
Life Flight LLC - Exem ption/Rulem aking

This Other document was issued by the Federal Aviation Administration

(FAA)

For related information, Open Docket Folder 

C ontent

PETITION FOR EXEMPTION OF: LIFE FLIGHT LLC 

FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS REGARDING VISUAL LINE OF SIGHT 

REQUIREMENTS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-

95). 

SUMMARY 

Life Flight LLC intends to produce Unmanned Aircraft for the express 

purpose of providing emergency medical relief in cases of anaphylactic 

shock and sudden cardiac arrest. Life Flight Unmanned Aircraft will 

transport a defibrillator and an epinephrine autoinjector (epipen) to 

victims of these specific and exigent medical emergencies at the 

judgement of 911 operators who reasonably believe: 

-The victim is experiencing sudden cardiac arrest or anaphylactic shock 

-The Life Flight Unmanned Aircraft can arrive at the victims location 

before the Fire Department (FD) or Emergency Medical Service (EMS). 

Life Flight Unmanned Aircraft will be operated by either FD or EMS 

personnel. Life Flight Unmanned Aircraft will ONLY be used for either of 

the two aforementioned medical emergencies. 

BASIS OF PETITION 

Life Flight LLC seeks exemption from Visual Line of Sight Rules and 

Restricted Airspace Over Major Cities. Life Flight Unmanned Aircraft will 

fly under 200 feet, during daytime fair weather operating conditions, will 

stay a preset distance (determined by the FAA) away from airports, 

operational control towers, and heliports, and will weigh less than 55 

pounds. 

Visual Line of Sight Rules will be a burden to FD and EMS personnel 

because victims may need medical attention within up to a 5 mile radius 

around the Life Flight Unmanned Aircrafts base. Life Flight Unmanned 

Aircraft will most likely be a fire station. 

Restricted Airspace Over Major Cities will be a burden because Life 

Flight Unmanned Aircraft will be most effective around populations. 

 

C om m ent N ow !

ID: FAA-2015-1152-0001

D ocum ent Inform ati

Date Posted:

Apr 23, 2015

Show More Details 

Subm itter Inform atio

Submitter Name:

John Coryell

Mailing Address:

1601 Fox Hollow Road

City:

Greensboro

Country:

United States

State or Province:

NC

ZIP/Postal Code:

27410

Organization Name:

Life Flight LLC

C om m ents

0

D ocket Inform ation

This document is contained in

FAA-2015-1152

Related Dockets:

None

Related RINs:

None

C om m ents Received

Regulations.gov - Other Document Page 1 of 2

http://www.regulations.gov/ 4/24/2015
WE CAN PROVIDE PUBLIC SAFETY by guaranteeing airworthiness 

certification for our Unmanned Aircraft as per The Aircraft Certification 

Service, AIR-113 at FAA headquarters in Washington, D.C. Life Flight 

Unmanned Aircraft will never feature a remote-controlled release of 

medical supplies. Rather, medical supplies will be attached to the drone 

and removed manually by non-electronic apparatus. 

THIS REQUEST IS IN THE PUBLIC INTEREST BECAUSE: 

1 - Life Flight Unmanned Aircraft will only be operated by FD and EMS 

personnel under very specific circumstances. 

2 - Life Flight Unmanned Aircraft will only be used when there is a 

reasonable belief that FD and EMS personnel cannot arrive at the scene 

of a medical emergency before a Life System Unmanned Aircraft. 

3 - In the case of Sudden Cardiac Arrest victims have minutes before 

vital organ failure incurs permanent injury or death. The Sudden Cardiac 

Arrest Foundation estimates 326,200 victims within the U.S. each year 

experience Sudden Cardiac Arrest and 9 out of 10 victims die. 

Additionally When bystanders intervene by giving CPR and using 

Automated External Defibrillators before EMS arrives 4 out of 10 victims 

survive. Already many commercial buildings are required to have a 

defibrillator on premise. In contrast, very few residences have fast 

access to a defibrillator. According to Heart.org 88% of Sudden Cardiac 

Arrests occcur at home. According to Early-Defib.org defibrillation within 

1-2 minutes can increase survival rates up to 90%. 

4 - In the case of anaphylactic shock The Food Allergy & Anaphylaxis 

Network (FAAN) has stated that approximately 200 people die from 

anaphylaxis each year in the USA from food allergic reactions. The 

actual figures may be much higher, especially since almost 50,000 visits 

to emergency rooms occur each year from allergic reactions. 

In summary this is in the Public Interest because Life Systems 

Unmanned Aircraft will be used for public health at the judgement of 

trained operators for specific medical situations. 

Related Documents:

None

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*

Regulations.gov - Other Document Page 2 of 2

http://www.regulations.gov/ 4/24/2015