1815 23 rd 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 7 th Street, SW Washington, DC 20591-001

Dear Sir; Madam,

Summary: Snakey Creek, LLC (dba Spectrum Aeromed) hereby petit ions 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 assi st with the transport of medical equipment for air ambulance operations. This exemption is to insta ll the Spectrum Aeromed equipment transport deck (ITS Deck) into the Agusta A109 series helicopter s as described in Type Certificate H7EU.

Contact Information: Spectrum Aeromed email: justin@spectrum-aeromed.com

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

1815 23 rd 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 additi onal 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”. Fo r 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 patie nt 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 a ffect 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 m edical patient to be secured to a stretcher that is in front of the left side cabin emergency exit. If ce rtain, 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 ex it in the Agusta A109 helicopter. This exemption will allow for transportation of critica lly 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 traini ng will be conducted annually by the operator. The unobstructed opening that will admit a 19-by 26-inch ellip se is required by FAR 27.807(b)(1) for standard

passenger carry ing operations. The typical passenger will not re ceive any specific emergency training other than the required safety briefing and passenger in formation 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 classroo m and drill training for this sp ecific aircraft configuration.

Another compensating factor is that the number of oc cupants is greatly reduced. The standard Agusta A109 is allowed to carry up to 6 passengers in the a ft 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 characte ristics of the medical crew as opposed to typical occupants. FAR 27.785(f) considers a 170 pound occup ant. 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) stat ing that the passageway and exit will be allowed to have “minor obstructions” is based upon the existi ng regulatory requirement from FAR 29.813(c)(2) for emergency exit access to Transport Category Helicopte rs 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 evacua tion” is based on the existing regulatory requirement from FAR 27.805(b) for flight crew emergency exits.

In summary, Spectrum Aeromed is requesting ex emption 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