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 qualityofcare to patients, safety in aviation operations. Transcending three decades, we continue to maintain our industry-leading position and currently have more than 300 bases ofoperation that serve 48 states. Air Methods is requesting an exemption from the requirements of 14 CFR 43.3(h)(1)to allow properlytrained pilots underan approved training program, to accomplish items of preventive maintenance as defined by 14 CFR 43 Appendix A paragraph (c), when the mechanical difficultyor malfunction occurred in areas not considered remote. This would applyto all Air Methods rotorcraft used in operations under 14 CFR 135.
An excerptfrom the supplementary information for the final rule forAmendment 43-36 (1996) States: 'The FAA has determined that ifa properlytrained pilot can change seat configurations in a remote area where a certificated mechanic is not available (and which might be performed underadverse conditions), he or she would be capable ofand should be allowed to perform the same conversions under betterconditions such as those present atthe operator's maintenance base.
Air Methods agrees that ifa pilot is trained to perform certain tasks then he/she is capable of performing those tasks atany location. We currently have a program in place which includes the training process, provides written procedures, and establishes atraining record for our pilots. Recurrent training is required annually and competency is evaluated by an instructorobserving pilot performing the procedure. Items of preventive maintenance are included in this program. We believe that ifour pilots are trained to perform these procedures under unfavorable circumstances, that same training and knowledge is available to them during normal, everyday will not

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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 maydecline the original call, he could change the bulb and be readyfor the nextcall within minutes instead of remaining outofservice until ourcertificated mechanic becomes available. 2) Enroute to an accident scene a chip light illuminates. In less than the amountoftime it takes forthe medical crewto administeron-scene care to our patient, the pilot could check the magnetic chip detectorand, as long as it is within acceptable criteria, be ready to transportthe patient to the hospital atthis most critical time. Current circumstances would force the pilotto abandon the mission resulting in the pursuit ofan alternate method oftransportation, possiblyjeopardizing the patient's recovery by delaying care. Webster's dictionarydefines "remote" as: far away; far awayfrom people, houses, cities, etc. Words like "remote" and "faraway" are subjective. The issue thatwe are trying to clarify is the availabilityofa person qualified to perform the action so that ouraircraft can delivercritically injured people to a where they can receive the care they Ifan Air Methods certificated is not available, but a pilot who has been trained and is proficient in performing simple is that is more importantthan the location of
is to keep our remote or that is available life-saving missions, for us to serve our in ornight, manner