# ~~-~~irMethodsfy

April27,2012

U.S. Department ofTransportation Docket Management System 400 

## ih Street, SW RoomPL401 Washington, DC 20591-0001 W.MGray Vice President ofAviation Support Services AirMethods Corporation 7301 SouthPeoria Englewood, CO 80112-4133

Dear Sir/Madame, The ExclusiveAirborneHealthcare Company

...Since 1980

Air Methods Corporation Denver/Centennial Airport NASDAQ/NMS: AIRM

AirMethods Corporation requests an exemption from FAA Order 8300.10 Appendix 3 Section 3.C to the extent necessary to permit Air Methods Corporation to operate and maintainpressure cylinders under Section 3D. AirMethods requests relieffrom the following requirements:
(1) Section 3.C. states, in pertinent part, for Title 14CFR Part 135 Aircraft with Passenger Seating Configuration ofNine Seats or Less will maintain the applicable cylinders in accordance with 49 CFR 180.205.
Priorto publication ofthe FAA Order 8300.10, there were no specific 14 CFR regulations for certification, manufacture, and maintenance ofpressure cylinders used aboard aircraft. In addition rules on inspection and testing pressure cylinders used aboard aircraft were also not specified in 14 CFR Part 135. This FAA Order 8300.10 was published to provide specific guidance on cylinder aging, internal corrosion, external pressure changes, cycles, and extreme temperature changes. These standards are addressed in 49 CFR 180.205.
Section 3.D which has sincebeen incorporated into FAA Order 8900.1 volume 3 Chapter 57, allows Part 135 aircraft type-certificated for passenger seating configuration often or more seats with scheduledheavy maintenance checks to accomplish maintenance and inspection ofpressure cylinders during scheduled heavy (phases or "C" or "D") checks through the operators Continuous Airworthiness Maintenance Program (CAMP). Air Methods Corporation maintains a similarprogram through the FAA. Approved Aircraft Inspection Program (AAIP). This program contains scheduled maintenance checks from daily checks through heavymaintenance checks such as 12 month, 600 hour, 800 hour,

7301 South Peoria. Englewood, Colorado, USA 80112. 303-792-7400. FAX 303-790-0499I I.

1200 hour, 6 year, etc. which are equivalent to many CAMP operatorheavy maintenance check intervals. AMC already incorporates into the AAIP maintenance ofthe pressure cylinders, to include condition (inspection for cracks, wear, corrosion, etc.), weight checks, life limit tracking and hydro static testing requirements at regular scheduled intervals. From the aspect ofpressure cylinder maintenance the AMC AAIP is equal to the programs operatedbyotherPart 135 and Part 121 operators utilizing CAMP's therefore providing an equivalent level ofinspection, tracking and safety. Accordingly, Air Methods Corporation requests theybe granted an exemption to FAA Order 8300.10 Appendix 3 Section 3.C to allow AMC to maintain pressure cylinders installed as aircraft equipment in accordance with Section 3.D (Reference FAA Order 8900.1 Volume 3 Chapter 57) and the following procedures:
(1) AMC will ensure a written maintenance/inspectionprogram is established specifically for the cylinders covered in 49 CFR 175. AMC will comply with the aircraft or cylindermanufacturer's lifelimit recommendations. (2) Each cylinder will beinspected at a regularinterval to ensure that the required internal pressure orweight ofcontents is maintained. Each cylinder will also be inspected to ensure that the valving, safetyrelief devices, mountingbrackets, and associated instrumentation are secure and acceptable for continued safe flight. (3) Any cylinderremoved from an aircraft for anyreason mustbe inspected to determine that the required internal pressure orweight of contents is within acceptable limits. There canbe no visible evidence ofdegradation ofthe cylinder or attached accessories. Any cylinders showing degradation orloss ofcontents must be retested and requalified (orrejected and condemned) as prescribed in 49 CFR 180.205. (4) Any cylinder that is part ofa supplementary oxygen system, that in the
course ofits normal operation is gradually depleted, mayremain in service ifit meets the operational requirements in Part 91.211, Supplemental oxygen.

- (5) Any cylinder (except supplemental oxygen) that is part ofan aircraft system, which hasbeen discharged for anyreason mustbe requalified and visually inspected in accordance with 49 CFR 180.205. (6) Cylinders mayremain in service without the required periodic retesting, reinspection, and marking as prescribed in 49 CFR 180.205 ifthey meet the criteria ofitems (1), (2), (3) and (4) above and have not been discharged.

AirMethods is confident that granting ofthe requested exemption would not reduce the level ofsafety, and it will not have adverse impact on the interests ofthe aircraft owners oron government agencies. Granting ofthis exemption is in the public interest since it will allow Air Methods to continue to provide reliable and timely service to support themedical needs ofthe public whilereducing operating costs and increasing revenues by reducing aircraft out ofservicetime.

Ifyou have anyquestions concerning this request for exemption please contact me at (303)792-7558 or e-mail me at agray@airmethods.com. Sincerely,

W.M. "Archie" Gra Vice President ofAviation Support Services AirMethods Corporation