### 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 No t 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 no t comply with the requirements of § 11.81 (copy enclosed). For us to consider the request any further, you mus t send us all of the following:

 The specific section or sec tions 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 reques t.

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 th e proposed effective date of the exemption.

### 2

If We Do No t 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/ B renda Robeson Program Analyst, Airmen and Airspace Rules Division

Enclosure

### Li fe Fl i

ght LLC -

Exem pti on/Rul em aki ng

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. Li fe Flight Unmanned Aircraft will transport a defibrillator and an epin ephrine autoinjector (epipen) to victims of these specific and ex igent 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 att ention 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 at i

Date Posted: A pr 23, 2015

Show More Details

Subm i tter Inform ati o

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 ati o n

This document is contained in FAA-2015-1152

Related Dockets: None

Related RINs: None C om m ents Recei ve d 

### Pa g e 1 of 2 Re g ulations. g ov - Other Document

4/24/2015 htt p ://www.re g ulations. g ov /WE CAN PROVIDE PUBLIC SAFETY by guaranteeing airworthiness certification for our Unmanned Aircraft as per The Aircra ft 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 spec ific 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 Un manned Aircraft.

3 - In the case of Sudden Cardiac Arrest victims ha ve minutes before vital organ failure incurs permanent injury or death. The Sudden Cardiac Arrest Foundation estimates 326,200 vi ctims 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. A ccording to Early- Defib.org defibr illation within 1-2 minutes can increase su rvival rates up to 90%.

4 - In the case of anaphylactic sh ock 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

This count refers to the total comment/submissions received this document , as of 11:59 PM yesterday. Note: Agencies revi e submissions, however some agencies may choose to redact withhold, certain submissions ( o portions thereof) such as those containing private or proprietar y information, inappropriate lang u or duplicate/near duplicate examples of a mass-mail camp a This can result in discrepancies between this count and those displayed when conducting searches on the Public Submis s document type. For specific information about an agency’s p submission policy, refer to its website or the Federal Register document. * 

### Pa g e 2 of 2 Re g ulations. g ov - Other Document

4/24/2015 htt p ://www.re g ulations. g ov /