2230 Stonebridge Rd West Bend, WI 53095-USA 1.262.335.8000 Phone 1.262.335.8008 FAX EIN: 39-1787963

Dear Sirs, Requestfor exemption 11118/2014

FAA Project No.: Pending project number-FAA Chicago www
.MedicaiAircraft

.com

Re.: 14 CFR 25.562 and 25.785(b), Exemption to allow Aero Medical Products Mfg., Inc to install a medical/Divan-patient litter assemblies per report 006 in to a Boeing Business Jet. Aero Medical Products Mfg., Inc hereby petitions for an exemption from 25.562 and part of25.785(b) ofTitle 14, Code ofFederal Regulations (14 CFR) to the extent necessary to permit installation ofa medical/Divanpatient litter assemblies, for transport ofpersons whose medical condition dictates such accommodations Specific sections of 14 CFRfrom which reliefis sought Section 25.785(b) at amendment 25-88, requires that each seat, berth, safety belt, harness and adjacent part of the airplane at each station designated as occupiable during takeoffand landing must be designed so that a person making proper use ofthose facilities will not suffer serious injury in an emergency landing as a result of the inertia forces specified in 25.561 and 25.562

. Section 25.562 specifies dynamic test conditions for qualification ofoccupant injury, as well as structural retention criteria. Extent ofrelief, and reason Aero Medical Products Mfg., Inc owns supplemental type certificates (STCs) for the for numerous 14 CFR part 25, 23, 27 and 29 airplanes. The certification requirementsfor those airplanes have resulted in good service history with no adverse experience. No medical-patient loading and utility system installations have been shown to meet the dynamic criteria in any aircraft. 14CFR parts 23,27, and 29 specifically exclude stretcher litters from the dynamic criteria. Aero Medical Products Mfg., Inc notes that the estimated cost ofdemonstrating compliance is extremely high considering the limited number ofunits for which the cost could be amortized. Since none have been shown to comply with the dynamic test criteria, stretchers cannotcurrently be used on airplanes whose type certificate basis includes the dynamic 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 ofa commercial ticket, or ifthe cost is prohibitive, fail to receive the needed treatment (the consequences ofwhich may be fatal). Another alternative would be flying an alternate route on an airplanes the certification basis for which does not require dynamic testing. This would offer no increase in safety and may not be available

. Why grantingthis requestwould 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 interestfor the following reasons: 

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• The exemption would relieve an economic burden on a segment ofthe traveling public already dealing with adversity, The level ofsafety that would be provided is an acceptable level ofsafety given the limited usage and exposure ofthe stretcher /divan, Compliance with the dynamic test requirements would be difficult at best, and very expensive, while returning a marginal safety benefit. In addition, 14 CFR25

.562 is written for seats and would not be easily applied to a litter/divan.

### Why grantingthe exemption would not adversely affect safety, orhow the exemption would provide a level ofsafety atleast equalto that provided bythe rule from which exemption is sought.


### • Compliance with the dynamic test requirements would be difficult at best, and very expensive, while returning a marginal safety benefit. In addition, 14CFR 25.562 is written for seats and would not be easily applied to a litter/divan 

### Requestto forego summary-notice publication in the FederalRegister for public comment Aero Medical Products Mfg., Inc also requests that the FAA waive publication and public commentfor good cause. A delay in acting on the petition would be detrimental to Aero Medical Products Mfg., Inc as well as delaying the deployment oflifesaving equipment. 

### Additional information, views, orarguments supporting this request This petition is consistent with Exemption No. 6625, 6920, 7318 and 7393, which were granted for LifePort litter installations in Cessna 750 (Citation X), Falcon 2000, Cessna Citation 560XL and Learjet45, respectively. 

### Operationoutside theUnitedStates This exemption is intended for operation inside and outside the US as many people travel outside the US because we are a Global society seeking business with the world. The BBJ aircraft is a global type aircraft.
Paul M. Egan, CEO Aero Medical Products Mfg., Inc 2230 Stonebridge Rd West Bend, WI 53095 1-262-335-8000 Cell: 1-262-305-4247