June 4 

Sir or Madam: 

Air Methods Corporation is a 135 operator providing medical emergency transportation 

a day. We are dedicated to medical transport and grown to 

the most experienced air medical operator in the industry. Our focus is on the quality of care to 

patients, safety in aviation operations. Transcending three decades, we continue to 

maintain our industry-leading position and currently have more than 300 bases of operation that 

serve 48 states. 

Air Methods is requesting an exemption from the requirements of 14 CFR 43.3(h)( 1) to allow 

properly trained pilots under an approved training program, to accomplish items of preventive 

maintenance as defined by 14 CFR 43 Appendix A paragraph (c), when the mechanical 

difficulty or malfunction occurred in areas not considered remote. This would apply to all Air 

Methods rotorcraft used in operations under 14 CFR 135. 

An excerpt from the supplementary information for the final rule for Amendment 43-36 (1996) 

States: 'The FAA has determined that if a properly trained pilot can change seat configurations 

in a remote area where a certificated mechanic is not available (and which might be performed 

under adverse conditions), he or she would be capable of and should be allowed to perform the 

same conversions under better conditions such as those present at the operator's maintenance 

base. 

Air Methods agrees that if a pilot is trained to perform certain tasks then he/she is capable of 

performing those tasks at any location. We currently have a program in place which includes the 

training process, provides written procedures, and establishes a training record for our pilots. 

Recurrent training is required annually and competency is evaluated by an instructor observing 

pilot performing the procedure. Items of preventive maintenance are included in this 

program. We believe that if our pilots are trained to perform these procedures under unfavorable 

circumstances, that same training and knowledge is available to them during normal, everyday 

will not 
~~iI"'AirMethD 

Under this 

Common, uncomplicated events, which a properly trained could safely perform, will make 

our unavailable for life-saving missions. For 

1) A pilot takes a call for a mission but discovers that a position light bulb is inoperative. 

Though the pilot may decline the original call, he could change the bulb and be ready for 

the next call within minutes instead of remaining out of service until our certificated 

mechanic becomes available. 

2) Enroute to an accident scene a chip light illuminates. 

In less than the amount of time it takes for the medical crew to administer on-scene care 

to our patient, the pilot could check the magnetic chip detector and, as long as it is within 

acceptable criteria, be ready to transport the patient to the hospital at this most critical 

time. Current circumstances would force the pilot to abandon the mission resulting in the 

pursuit of an alternate method of transportation, possibly jeopardizing the patient's 

recovery by delaying care. 

Webster's dictionary defines "remote" as: far away; far away from people, houses, cities, etc. 

Words like "remote" and "far away" are subjective. The issue that we are trying to clarify is the 

availability of a person qualified to perform the action so that our aircraft can deliver critically 

injured people to a where they can receive the care they If an Air Methods 

certificated is not available, but a pilot who has been trained and is proficient in 

performing simple is that is more important than the location of 

is to keep our 

remote or that is 

available life-saving missions, 

for us to serve our in 

or night, 

manner