1815 23rd Avenue North | Fargo, ND 58102 | 701-235-5478 | Toll Free: 1.800.753.4340 | Fax: 701-235-5486 

Email: Aeromed@Spectrum-Aeromed.com | www.Spectrum-Aeromed.com 

May 19, 2010 Spectrum Aeromed Document 7010L 

 Revision: Original 

U.S. Department of Transportation 

Docket Management System 

400 7th Street, SW 

Washington, DC 20591-001 

 

Dear Sir; Madam, 

Summary: 

Snakey Creek, LLC (dba Spectrum Aeromed) hereby petitions for an exemption from 27.807(b)(1) of Title 

14 of the Code of Federal Regulations (CFR) Federal Aviation Regulations (FAR) to the extent necessary 

to permit certification of medical systems to assist with the transport of medical equipment for air 

ambulance operations. This exemption is to install the Spectrum Aeromed equipment transport deck (ITS 

Deck) into the Agusta A109 series helicopters as described in Type Certificate H7EU. 

Contact Information: 

Spectrum Aeromed email: justin@spectrum-aeromed.com 

Attention: Justin Mahler Phone: 1-800-753-4340 

1815 23rd Avenue North Fax: (701) 235-5486 

Fargo, ND 58102 

Sections of the FAR affected: 

FAR 27.807 - Emergency exits. 

(b) Type and operation. Each emergency exit prescribed by paragraph (a) of this section must-- 

(1) Consist of a movable window or panel, or additional external door, providing an unobstructed opening 

that will admit a 19-by 26-inch ellipse; 

Extent of relief from FAR 27.807: 

FAR 27.807(b)(1) requires that each emergency exit must provide “an unobstructed opening that will 

admit a 19-by 26-inch ellipse”. For specific air ambulance operations with the Spectrum Aeromed ITS 

Deck, we are requesting that the above indicated portion of FAR 27.807(b)(1) under the requested 

exemption to be “a passageway and an opening with minor obstructions that will be of sufficient size and 

must be located so as to allow rapid evacuation”. 

 

This exemption will allow for medical crews to use life-saving equipment such as an incubator for critical ill 

infant transportation. The medical crew and patient in the passenger cabin will have access to the 

existing aft right side cabin exit and also the forward left side exit via a short egress passageway. Also, 

the aft left door is operable from the inside while the ITS Deck is installed and the Incubator can be 

jettisoned. The usage of the ITS Deck will not affect the remaining emergency exits and doors. 
 

May 18, 2010 Spectrum Aeromed Document 7010L 

 Revision: Original 

(Continued from page 1) 

How this exemption benefits the public as a whole: 

The currently approved medical interior will allow for a medical patient to be secured to a stretcher that is 

in front of the left side cabin emergency exit. If certain, life-saving equipment is needed, such as an 

incubator for infant transports, the only usable position for the equipment is mounted on the Spectrum 

Aeromed ITS Deck in the vicinity of the aft cabin exit in the Agusta A109 helicopter. This exemption will 

allow for transportation of critically ill infants in out-lying areas that would otherwise have no practical 

means of rapid transportation to hospitals with neonatal or pediatric intensive care. Each aircraft with the 

ITS Deck configuration will potentially carry dozens of critically ill infants every year and this modification 

will not increase the probability of an accident or incident. 

Reasons why this exemption will not adversely affect safety: 

One compensating factor is that emergency training will be conducted annually by the operator. The 

unobstructed opening that will admit a 19-by 26-inch ellipse is required by FAR 27.807(b)(1) for standard 

passenger carrying operations. The typical passenger will not receive any specific emergency training 

other than the required safety briefing and passenger information cards. The air ambulance operator will 

be required to have specific emergency training for the medical crew and the pilot. This emergency 

training will include annual classroom and drill training for this specific aircraft configuration. 

Another compensating factor is that the number of occupants is greatly reduced. The standard Agusta 

A109 is allowed to carry up to 6 passengers in the aft cabin. The aircraft with the ITS Deck configuration 

will only be allowed to operate with a maximum of 3 trained medical crew and one patient in the aft cabin. 

This will reduce the cabin capacity by 33%. 

A third compensating factor is the physical characteristics of the medical crew as opposed to typical 

occupants. FAR 27.785(f) considers a 170 pound occupant. The typical passenger will vary greatly in 

height, weight, age and mobility. The medical crew will need to demonstrate a minimum agility and 

physical size to perform their function and complete the annual emergency drill training. The aircraft with 

the ITS Deck configuration will only be allowed to operate with the medical crew and patient and not be 

for general passenger carriage. 

The requested exemption to FAR 27.807(b)(1) stating that the passageway and exit will be allowed to 

have “minor obstructions” is based upon the existing regulatory requirement from FAR 29.813(c)(2) for 

emergency exit access to Transport Category Helicopters for a passenger seating configuration of 19 or 

less, if there are compensating factors to maintain the effectiveness of the exit. 

The requested exemption to FAR 27.807(b)(1) stating that the passageway and exit will “be of sufficient 

size and must be located so as to allow rapid evacuation” is based on the existing regulatory requirement 

from FAR 27.805(b) for flight crew emergency exits. 

In summary, Spectrum Aeromed is requesting exemption from portions of the emergency egress 

provisions of FAR 27.807(b)(1) to install an ITS Deck to allow for infant transportation in Agusta A109 

series helicopters. 

Sincerely, 

Justin Mahler, Certification Engineer 

Spectrum Aeromed