08/25/2014 11:19 4252271007 ANM7 PAGE 02/12 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Northwest MoLJntain Region 

Office of Regional Counsel 

Colorado, Idaho, Mohtana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Tel: (425) 227-2161 

August26, 2014 

Fax: (425) 227-1007 

jeffrey. harper@ faa .gov 

VIA FACSIMILE AND CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Bullding ' 

800 Independence A venue, Southwest 

Washington, DC 20591 

Re: In the Matter of Air Medical Resources G~:oup, Inc., FAA Case 

No. :Z014NM070012 

Enclosed please find a copy of a request for hearing IU!d the original and one copy of the 

Complaint in this proceeding. 

The FAA requests that the hearing in this matter be held in Salt Lake City, Utah, IU!d expects 

the hearing vvilllast one day. For scheduling ptuposes, counsel for the FAA is unavailable on 

the following dates in 2014: September 12-15, October 24-27, November 21-December 1, 

December 12-15, and December 19-29. In 2015, counsel for the FAA is unavailable 

January 23-26, F~bruary 20-23, March 20-23, April24-27, May 18, June 12-15, July 24-

27, August 21-24, and September 18-21. 

Please address all communications to the undersigned at: 

Federal Aviation Administration 

Northwest Mountain Region, ANM -7 

160 1 Lind AvenJie Southwest 

Renton, Washington 98057 

(425) 2n2161, Fax: (425) 227-1007 

:z~~ FAAAttomey 

Enclosure: Request for Hearing (Appeal) 

Complaint 
08/25/2014 11:19 4252271007 

JEFFREY M. HARPER 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE., SW 

RENTON, WASHINGTON98057 

TEL.EPHONE: (425) 227-2161 

FACS!MJLE: ( 425) 227-1007 

ANM7 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE: OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

FAA Case No. 2014NM070012 

DMS No. Not yrot assigned. 

PAGE 03/12 

Air Medical Resources Group, Inc. 

~0 14 -Oc:J5cJ 

COMPLAINT 

The Federal Aviation Admin.istration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice 14 C.P.R. § 13.208, and states as follows: 

I. 

On A1.l.gust 6, 20 14, Air Medical Resources Group, Inc. was advised through a Final 

Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the 

amount of$12,000. On August 18, 2014, Air Medical Resources Group, Inc. submitted a 

written request for a hearing. 

II. 

1. Air Medical Resources Group, Inc. (AMRG) is now and was at all times material 

herein the holder of Air Operator Certificate No. 7 AJA299N, and conducts its 

operations pursuant to Part l35 of the Federal Aviation Regulations (FAR). 

2. At all times relevant herein, AMRG's General Operations Manual (GOM), Revision 

03·15-13/R-2 was accepted by the Administrator for compliance with Title 14, Code 

of Federal Regulations (C.F.R.), Section 135.21. 

3. At all times relevant herein, AMRG's GOM, Chapter 4, Paragraph 4.8, required pilots 

to "record all commercial flight time and rest periods in the Flight Vector Flight and 

Duty Tracker within 24-hours of the completion of each duty period." 
08/25/2014 11:19 4252271007 ANM7 

4. Gallup Flying Service (GFS) was at all times material herein. the holder of Air 

Operator Certificate No. GNMA391E, and conducts its operations pursuant to 

Part 135 of the FAR. 

PAGE 04/12 

5. At all times relevant herein, Mr. Ryan K.rissman (Mr. Krissman) was qualified to act 

as pilot-in-command for operations conducted by AMRG tuJ.der Parl135. 

6. At all times relevant herein, .Mr. Krissman was qualifi.ed to act as pilot-in-command 

for operations conducted by GFS tulder Part 135. 

7. !Vfr. Krissman Was on duty for GFS on the following dates and times, and flew for 

GFS for the hours listed: 

Date On Duty (Military Time) Hours Flown 

August 8, 2013 1100-2420 

August 9, 2013 1100-2300 

August 10,2013 1100-2300 

August 11, 2013 1100-2300 

August 12, 2013 1100-2300 

August 13, 20 13 1100-2300 

August 14,2013 0700- !900 

August 24, 2013 0700-1900 

August 27, 2013 0700-1900 

August 29,2013 0700-2000 

September 1, 2013 0500- 1700 

September 2, 2013 0500-1700 

September 3, 2013 0500-1700 

September 19, 2013 1100-1900 

September 20, 2013 0500-1740 

September 21,2013 0500-1700 

September 22,2013 0700- 1900 

September 23, 2013 0700- 1900 

September 24, 2013 0700-1900 

September 25, 2013 0700-1900 

October 11,2013 0700-1900 

October 12, 2013 0500- 1700 

October 13,2013 0700-1900 

October 14, 2013 0700- 1900 

October 18,2013 Unknown 

October 20, 2013 0700-1900 

Compll-lint 

In the .Ma:th::::t of Air Medical .Resources Gn~up1 Inc .. 

FAA Case No. 2014NM070012. DMS Nt>. Nat Assi~necl 

Pa.g~ 2 t)f 7 

1.8 

2.2 

1.8 

0.0 

3.1 

3.0 

1.8 

2.1 

1.8 

2.1 

0.0 

0.0 

0.0 

1.6 

3.4 

1.8 

1.8 

0.0 

1.6 

1.6 

0.2 

1.7 

2.2 

1.5 

1.3 

1.3 

J.F.'.f.'r'I~£Y M. HARPER, FAA AlTOR.N'EY 

ill! ... : (425) 227-2161.; FAX.: (425) 227-1007 
08/25/2014 11:19 4252271007 

Date 

October 26, 2013 

October 27, 2013 

October 28, 2013 

October 29, 2013 

October 30, 2013 

ANfH 

On Duty (Military Time) 

1600- 0400 (Next day) 

1600-0400 (Next day) 

1600- 0400 (Next day) 

1600- 0400 (Next day) 

1600-0400 (Nexi: day) 

Hours Flown 

1.5 

1.5 

1.9 

2.3 

2.1 

PAGE 05/12 

8. As ofNovcmber 6, 2013, AMRG flight and duty time records for Mr. Krissmau did 

not docwnent a!lY of the hours Mr. Krissman flew for GFS referenced in paragraph 7. 

9. As ofNovember 6, 2013, AMRG flight and duty time records for Mr. Krissman did 

not accurately reflect Mr. Krissman's duty status with GFS on the following dates: 

August 8, 2013 

August 9, 2013 

August 10, 2013 

August 14,2013 

August 29,2013 

September 1, 20 l3 

Septembet 19,2013 

September ZO, 2013 

October 20, 2013 

October 30, 2013 

10. On or about November 22, 2013,AMRG revised Mr. Krissman.'s flight and duty time 

records. 

ll. The records referenced in paragraph I 0 did not correctly docwnent the hours 

Mr. Krissman flew for GFS on the following dates: 

August 8, 2013 

August 9, 2013 

August 10,2013 

August 12,2013 

August 13, 2013 

August 14,2013 

September 3, 2013 

September 20, 2013 

September 21,2013 

September 22, 2013 

September 24, 2013 

September 25,2013 

October 13, 2013 

October 14, 2013 

October 18, 2013 

October 20, 2.013 

October 26, 2013 

October 27,2013 

October 28,2013 

October 29, 2013 

12. The records referenced in paragraph I 0 did not correctly docum.ent Mr. Krissman's 

duty status with GFS on the following dates: 

August 14,2013 

August 29, 2013 

Septem.ber 22,2013 

October 20,2013 

October 30, 2013 

13. At all times relevant herein since April2, 2013, lvfr. Rick Wysowski was the Assistant 

Director of Operations for AMRG. 

Ccnnp la.htt 

ln. the M11t1:~r of Air Medical Resource~ (tmup~ Inc. 

FAA Ca.'e N". 2014NM070012. DMS N(l. Not Assigned 

Page 3 of7 

)B.~~'RF.Y M. HARPER .. I'AA AHORNEY 

TEL: (425) 227-2161; FAX; (425) 227-1007 
08/25/2014 11:19 4252271007 ANM7 PAGE 05/12 

14. At all times relevant herein, Mr. Wysowski was approved to act as a check ainnan for 

AMRG in BE-90 aircraft. 

15. At all times relevant herein, Mr. Wysowski was qualified to act as pilot-in-command 

for operations conducted by AMRG under Part 135. 

16. On May 30,2013, Mr. Wysowski completed a Competency/Proficiency check to 

demonstrate his qualifications under Sections l35.293(a)(1), 135.293(a)(4)-{8), 

135.297, and 135.299 of the FAR for AMRG. 

17. Mr. Wysowski perfonned the duties of a check airman for AMRG on flights taking 

place on the following dates: 

May 30,2013 (2 flights) 

June 17, 2013 

Jun.e 18, 2013 (2 flights) 

June 19, 2013 (2 flights) 

September 12, 2013 (2 flights) 

September 13, 2013 (2 flights) 

18. As November 13,2013, AMRG :flight and duty time records for Mr. Wysowski did 

not document the flights or duty status described in paragraphs 16 or 17. 

19. On or about November 22, 2013,AMRG revised Mr. Wysowski's flight and duty time 

records. 

III. 

1. By reason ofthe foregoing circumstance(s),A.MRG violated the following sections of 

the Federal Aviation Regulations (14 C.F.R.): 

a. Section !35.2l(a), in that its Jn,anual setting forth its procedures and policies was 

not used by its flight personnel. 

b. Section 135.63(a)(4)(vii), in that it failed to keep an individual record of each 

pilot used in operations under 14 C.F.R. Part 135 which included the pilot's flight 

time in sufficient detail to detennine compliance with the flight time limitations of 

14 C.P.R. Pan 135 

2. Under 49 U.S.C. §§ 46301 (a) and (d), AMRG is liable for a civil penalty not to 

exceed not to exceed $11,000 for each of the violations noted. 

3. Under the facts and circumstances of this case, a civil penalty of$12,000 is 

appropriate. 

Co.mp1nil,t 

T.n. the Matter of A it Mt:d.ic~l Resources (Jroup. Inc.. 

FAA Case No, 20!4NM07D012, DMS No. Not A".ignod 

Page 4 of? 

-'.F..'J:7FREY M. HARP.ER, FAAA1~.t01'lt:-IEY 

TEL: (425) 227-2161; PAX: (425) 227-1007 
08/25/2014 11:19 4252271007 ANM7 

Respectfully submitted this 261

h day of August, 2014. 

Compl.n.iut 

ln. th.e Matter of A lr Modi cal Resources Group1 Inc. 

FAA Case N<>. 2014NM07D0l2. DMS No. NotA«igned 

r:~age 5 t~f 7 

PAGE 07/12 

JiZP'F.I~EY. M. HALWER., FAAATTOR!-.'EY 

TEL: (425) 227·216!; FAX: (425) 227·1007 
08/25/2014 11:19 4252271007 ANH7 PAGE 08/12 

ANSWER 

In. accordance vcith Section 13.209(a) of the Federal Aviation Regulations, AMRG must 

answer this Complaint not later than thirty (30) days after the date the Complaint is 

served. Failure to file an Answer ·within. thirty (30) days without good cause shall be 

deemed an admission of the truth of each allegation contained in the Complaint. 

14 C.F.R. § 13.209(£). 

Co.mp!aint 

In the M1Htrrr of.A.i.r Mcd.ical Resources Group, Inc. 

FAA Case No. 2Q14NM0700l2. DMS No. Not Assigned 

P~J.ge 6 of7 

Ji=.""FFREY M. 1-IA.~.PER, FAA ATTORNEY 

TEL: (425) 227-216\; FAX: (42.5) 227·l007 
08/25/2014 11:19 4252271007 ANM7 PAGE 09/12 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint has been served via facsimile and Certified 

Mail- Return Receipt Requested this date, to the following: 

Federal Aviation Administration 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2Wl 000 

800 Independence Avenue Southwest 

Washington, DC 20591 

Fax: (202) 493-5142 

Gregory S. Winton, Esq. 

The Aviation Law Firm 

1997 Annapolis Exchange Parkway, Suite 300 

Annapolis, MD 21401 

Tel: (301) 294-8550 

Fax: (866) 568-9886 

Dated this 26th day of August, 2014. 

CoJ:t~.pl.alt\1 

.®as~ {jp~ul:fM:A Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Avenue SW 

Renton, WA 98057 

(425)227-2164 

rn the Matter of Alr M<::dkat Resources ('troup_, I.nc. 

JJ::'[~'tl.tb'Y M. I·lAR.PJ~I~. FAA AT"f'ORNEY 

TEL: (425) 227-2161; FAX: (425) 227-1007 

FAA CMC No. 2014NM070012. DMS No. Not Assigned 

Page 7 of 7 
08/25/2014 11:19 4252271007 ANM7 

Regional Counsel 

I'IUG 2 2 '/..Wr 

ANM.-'7 

U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

IN THE MATTER OF 

Air Medical Resource Group, Inc. 

Respondent 

FAA DOCKET NO. 2014NM070012 

(Civil Penalty Proceeding) 

DMS NO. FAA"NOT YET ASSIGNED 

ADMINISTRATIVE LAW JUDGE 

NOT YET ASSIGNED 

Hearing Date: NOT YET ASSIGNED 

Hearing Location: NOT YET ASIGNED 

REQUEST FOR HEARING PURSUANT TO 14 C.F.R. § 13.16 

COMES NOW, Respondent, Ai.t Medical Resource Group, Inc., by and through 

PAGE 10/12 

undersigned counsel pursuant to 14 C.F.R. § 13.16, and hereby requests a hearing concerning the 

allegations raised in the Complainant's Final Notice of Proposed Civil Penalty dated August 6, 

2014, which proposes to assess a civil penalty iu the amount of$12,000.00. Respondent denies 

the violations alleged in the Complainant's Final Notice of Proposed Civil Penalty and prays that 

it be reversed. 

Respondent requests that a heating be held in South Jordan, UT. A hearing is expected to 

last two (2) full days. 
08/26/2014 11:19 4252271007 

Dated: August 18, 2014 

2 

ANM7 

Respectfully submitted, 

Is/ Gregory S. Winton 

GREGORY S. WINTON, ESQ. 

The Aviation Law Firm 

1997 Annapolis Exchange Parkway 

Suite 300 

Annapolis, MD 21401 

Tel: (301) 294-8550 

Fax: (866) 568-9886 

Counselfor Respondent 

PAGE 11/12 
08/25/2014 11:19 4252271007 ANM7 PAGE 12/12 

CERTIFlCATE OF SERVICE 

I hereby certifY lhat I have this date served by regular U.S. mail, postage prepaid, an original 

and one (1) copy of the foregoing Request for Hearing addressed to: 

ORIGINAL AND ONE COPY 

Attention: Hearing Docket Clerk, AGC-430 

Federal Aviation Administration 

Wilbur Wright Building 

800 Independence Avenue, S.W .. 

Washington, D.C. 20591 

And, further, lhat I have this date served by regular U.S. mail, postage prepaid, a copy of the 

foregoing Request for Hearing addressed to: 

Dated: 

Jeffrey M. Harper 

Federal Aviation Administration 

Noriliwest Mountain Region 

Office of the Regional Counsel, ANM-7 

160) Lind Avenue, S.W. 

Renton, Washington 98057 

August 18, 2014 

3 

Respectfully submitted, 

Is/ Gregory S. Winton 

GREGORY S. WINTON, ESQ. 

The Aviation Law Firm 

1997 Annapolis Exchange Parkway 

Suite 300 

Annapolis, MD 21401 

Tel: (301) 294-8550 

Fax: (866) 568-9886 

Counsel for Respondent 
08/25/2014 11:19 4252271007 ANM7 PAGE 01/12 

FACSIMILE MESSAGE 

FEDERAL AVIATION ADMINISTRATION 

OFFICE OF REGIONAL COUNSEL 

ANM-7 

1601 LfND AVENUE S.W. 

RENTON, WASHINGTON 98057 

The information contained in this facsimile message is legally privileged and confidential 

information and is intended only for the use of the individual named on thi.s cover sheet. 

If the reader of this message is not the intended recipient, you are he:r:eby notified that any 

use, dissemination, distribution, or copy of this facsimile is strictly prohibited. Ifyot1 

have received this facsim.ile in error, please immediately notify us by telephone at 

425-227-2007. 

DATE: 

TO: 

FAX NO.: 

PHONE NO.: 

RE: 

Complaint 

August 26, 2014 

Docket Clerk AGC-430 

202-493-5142 

Air Medical Resource 

Group, Inc. 

FAA Case No. 

20l4NM070012 

NO. PAGES: 

FROM: 

FAX NO.: 

PHONE NO.: 

EMAIL: 

1,1 including cover 

Jeffrey M. Harper 

425-227-1007 

425-227-2161 

JEFFREY.HARPER@FAA.GOV