FAA Project No.: Pending project number - FAA Chicago

Re.: 14 CFR 25.562 and 25.785(b), Exemption to allow Aero Medical Products Mfg., Inc to install a medical - patient litter assemblies per report 006 in a Gulfstream G - IV - X, G - V, G - VIseries airplanes. Aero Medical Products Mfg., Inc hereby petitions for an exemption from 25.562 and part of 25.785(b) of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to permit installation of a medical - patient litter assemblies, for transport of person s whose medical condition dictates such accommodations, on Gulfstream Model G - IV - X, G - V, G VIseries airplanes. **Specific sections of 14 CFR from which relief is sought Section 25.785(b)**  at amendment 25 - 88, requires that each seat, berth, safety belt, harn ess and adjacent part of the airplane at each station designated as occupiable during takeoff and landing must be designed so that a person making proper use of those facilities will not suffer serious injury

in an emergency

landing as a result of the iner tia forces specified in 25.561 and 25.562. **Section 25.562** specifies dy namic test conditions for qualification of occupant injury , as well as structural retention criteria. **Extent of relief, and reason** Aero Medical Products Mfg., Inc owns supplemental ty pe certificates (STCs) for the Gulfstream I, II, III, IV and for numerous 14 CFR part 25, 23, 27 and 29 airplanes. The certification requirements for those airplanes have resulted in good service history with no adverse experience. No medical - patient loading and utility s ys tem installations have been shown to meet the dynamic criteria. 14 CFR parts 23,27, and 29 specifically exclude stretcher litters from the dy namic criteria. Aero Medical Products Mfg., Inc notes that the estimated cost of demonstrating comp liance is quite high considering the limited number of unites for which the cost could be amortized. Since none have been shown to comply with the dy

namic test criteria, stretchers cannot currentl y be used on airplanes whose type certificate basis includes the dy

namic requirements. In this case, a person who needs to travel for essential medical care can either charter an airplane, at 5 to 10 times the cost of a commercial ticket, or if the cost is prohibitive, fail to receive the needed treatment (the cons equences of which may

be fatal). Another alternative would be flying an alternate route on an airplanes the certification basis for which does not require dyn amic testing. This would offer no increase in safety and may not be available. **Why granting this r equest would be in the public interest; how it benefits the public**  **as a whole** Aero Medical Products Mfg., Inc feels that granting the petition would be in the public interest for the following reasons:  The exemption would relieve an economic burden on a se gment of the traveling public already dealing with adversity , The level of safet y that would be provided is an acceptable level of safety given the limited usage and exposure of the stretcher,  Compliance with the dy namic test requirements would be difficul t at best, and very expensive, while returning a marginal safet y benefit. In addition, 14 CFR 25.562 is written for seats and would not be easil y applied to a litter. **Why granting 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 exemption is sought**  As noted above, the level of safet y is acceptable given the limited usage and exposure of the stretcher and service history (no unsafe conditions) associat ed with Aero Medical Products Mfg., Inc stretcher installations. **Request to forego summary -**  **notice publication in the Federal Register for public comment**  Aero Medical Products Mfg., Inc also requests that the FAA waive publication and public comment for goo d cause. Aero Medical Products Mfg., Inc applied for the STC in June, 2013 and has commitments requiring an STC by Sept 2013. A delay

in acting on the petition would be detrimental to Aero Medical Products Mfg., Inc as well as delaying the deploy ment of li fesaving equipment. **Additional information, views ,**  **or arguments supporting this**  **request** This petition is consistent with Exemption No. 6625, 6920, 7318 and 7393, which were granted for Li fePort litter installations in Cessna 750 (Citation X), Falcon 2000, Cessna Citation 560XLand Learjet 45, respectivel y. In this case, the intent for the exemption is for non - ambulatory

persons. Aero Medical Products Mfg., Inc recommends that this intent be covered b y:  a limitation in the Flight Manual Supplement, and  a co nspicuousl y located placard that states that occupancy of the stretcher litter during takeoff and landing is for non - ambulatory persons only . **Operation outside the United States** This exemption is intended for operation inside and outside the US as many peo ple travel outside the US because we are a Global society seeking business with the world. The Gulfstream aircraft is a global ty pe aircraft. Paul M. Egan, CEO Aero Medical Products Mfg., Inc 2230 Stonebridge Rd West Bend, WI53095 1 - 262 - 335 - 8000 Cell: 1 - 262 - 305 - 4247