STATE OF MARYLAND I C ^ " P ^" ' ' C ' ' ) 

MARYLAND STATE POUCE 

Aviation Command - i - - jq .• r. TQ 

MAR^o-H^tLEY 3023 StrawbcrTy Point Road 

GOVERNOR Baltimore, M D 21220 COLONEL 

..._.' . o _ „ . „ MARCUS I. BROWN 

ANTHONY G. BROWN (410 ) 2 3 8-5 8UU SUPERIMTtNDEfiT 

LT. GOVERNOR 

September 12, 2011 

Document Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor 

Room W-12-140 

Washington D.C. 20590 

Dear Sir: 

The following is a petition for exemption for aircraft registration; 

a. Name and address : Maryland State Police Aviation Command 

3023 Strawberry Point Road 

Baltimore, Maryland 21220 

Phone number 410-238-5800 

E-mail: wsbemardfol.mdsp.org 

b. Sections for exemption: Title 14 CFR Section 47.15b 

c. The extent of relief: The Maryland State Police Aviation Command is requesting 

"N" numbers for the new AW139 fleet to be "NIMSP" through "Nl IMSP". This 

request will make it easier to track aircraft, maintenance, and the MSP has gone to 

great lengths in the design and appearance of the new aircraft which will visibly be 

marked with "Maryland State Police." The requested "N" numbers will enhance the 

appearance and make it obvious as to the identity of the aircraft operator. 

d. The public - Maryland citizens ftind this program through a transportation 

surcharge added to their registration fees. When the citizens see a Maryland State 

Police helicopter they identify with their support and an understanding of the multi 

mission profile to include over 140,000 medevacs in the program's history. 

e. Reasons it would not adversely affect safety - This request deals strictly with the 

registration of the aircraft and not how they are operated. The Aviation Command is 

currently in the application process for Part 135 certification for the aircraft that 

would not be affected by this exception request. 

"Maryland's Finest' 
STATE OF MARYLAND 

MARYLAND STATE POLICE 

f Description of the exemption you seek; The Maryland State pohce Aviation 

Command is seeking an exemption under Title 14 that would allow 11 multi 

mission aircraft to be registered with an N number and 1 through 11 followed by the 

letters of "MSP". Current regulations allow for only two letters. 

g. Additional information: The Maryland State Police Aviation Command (MSPAC) 

was the first state government run medevac operation in the United States. Since the 

first medevac in March of 1970, the program has performed medevac, search and 

rescue. Jaw enforcement. Homeland Security, and damage assessment missions. 

The MSPAC even responds into neighboring States to provide life savings 

medevacs and assistance to law enforcement agencies whose officers are in peril. 

The MSPAC also provides services to the federal Government which includes: 

• Assists the NCRCC and the FAA with Flight Restriction Zone violations in the 

Washington D.C. area 

• Assists the United States Secret Service with violations of P-40 at Camp David 

• Makes available the use of our Frederick Hangar when Marine 1 cannot land at 

Camp David 

• Is a signatory of an agreement to participate in providing Aviation assets to the 

U.S. Department of Homeland Security in the event of a national terrorism 

instance in Washington D.C. outside of Maryland 

• Provides Aviation assets to the United States Park Police Aviation when needed 

in Washington D.C. or on U.S Property 

The attached letter from Mr. John Bent states: "Controls have been programmed into the 

computer system to prevent the acceptance of data containing incorrect or impossible 

elements, such as a registration number with six symbols or a registration number with 

three letters, such as you have requested." I have attached the two inquiries I made to the 

FAA website for N-Number inquiries and both "NIMSP" and "Nl IMSP" responses are 

"Not Assigned/Reserved. The response does not indicate "incorrect or impossible 

elements." 

I have attached previous correspondence on this issue from me to Administrator Babbitt 

and a return letter from Manager John Bent of the FAA Office of Civil Aviation Registry. 

The MSPAC is not your normal civil operator of aircraft. I can appreciate the rules that 

are set in place to readily identify aircraft to their registered owner especially those that 

are not conspicuously marked such as ours. I know that law enforcement "black ops" 

have aircraft that have N numbers not identified to the operators, so obviously exceptions 

are made. 
STATE OF MARYLAND 

^ XA 1 J O r. y ' MAHYLAND. STATE POLICE . 

The Maryland State Police is seeking consideration of our request for exemption that may 

be beyond normal day to day considerations. However, the MSPAC responds to assist 

our federal partners who are often not in our normal operations, yet we respond to 

provide assistance with a spirit of cooperation. In that same spirit, the Maryland State 

Police Aviation Command is requesting this registration exemption. 

Sincerely, 

William S. Bernard 

Director - Flight Operations 

Maryland State Police 

Aviation Command 

410-238-5800 

410-960-4469 

Attachments 
STATE OF MARYLAND ;; vw^wy-J/ ' 

MARYLAND STATE POLICE 

Aviation Command 

3023 Strawberry Point Road 

Baltimore, MD 21220 

MARTIN O'MALLEY /^iA\m o con n COLONEL 

GOVERNOR (410) 238-5800 TERRENCE B. SHERIDAN 

SUPERINTENDENT 

ANTHONY G. BROWN 

LT GOVERNOR J^^Q 17,2011 

J. Randolph Babbitt 

Administrator 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Washington, D.C. 20591 

Dear Administrator Babbitt: 

The Maryland State Police Aviation Command currently operates 11 Eurocopter 

Dauphins from 7 bases across the State of Maryland providing citizens with multimission capabilities to include medevac, law enforcement, search and rescue, homeland 

security and damage assessment. In support of this statewide mission to include services 

to surrounding states, the State of Maryland has entered into contract with the Agusta 

Aerospace Corporation in the purchase of 11 AW 139's to provide this mission. It is 

anticipated that delivery will occur sometime in mid 2012. In recognition of the purchase 

of the new aircraft, the Aviation Command will seek to register the new aircraft. 

The purpose of this letter is to request an exemption to Title 14 Pari 47 section 47.15 

Identification Number. That section on page 878 paragraph (b) A U.S. Identification 

number,.. lists the number of letter and number combinations that follow the United 

Slates designated "N" number. That regulation limits to five characters with a maximum 

of two letters. It is the petitioners request that an exemption be allowed that would allow 

for two numbers and three letters. It would be the petitioners request to register the new 

aircraft with the first being "NIMSP" through "Nl IMSP" This registration indexing 

would be beneficial to the petitioner for a variety of reasons and should be considered for 

the following reasons; 

• All Maryland State Police helicopters are evidently marked as to the organization 

to include coloring, shields, wording such as "Maryland State Police", 'State 

Trooper", etc. 

• The call signs used by Aviation Command helicopters with ATC are not the 

registered "N" numbers but the word "Trooper" followed by the section of 

assignment. 

• Any formal inquiries for incidents would be addressed by the obvious 

identification of the operator on the aircraft and section number in the window. 

• The Maryland State Police Aviation Command provides protection and intrusion 

support to Camp David, P-40, P-56, the Flight Restricted Zones, etc. 

• The Maryland State Police is a signatory of a multi-agency airborne support to the 

Office of Homeland Security for response to the Nations Capital during events of 

terrorism even if general aviation is grounded. This support could include 

"Marvland's Finest" 
STATE OF MARYLAND 

MARYLAND STATE POLICE 

medevac, surveillance, personnel transports of high ranking government officials, 

etc. 

Unfortunately, the availability of 11 consecutive "N" numbers ending with "MD" is 

not available due to the members of the medical community owning aircraft. There is 

absolutely no way that a granting of this exemption would adversely affect safely. 

The Maryland State Police is not a business but an aviation organization dedicated to 

the service of the citizens of Maryland..The petitioner feels that based on missions and 

Support of other agencies to include the federal government should provide a basis for 

favorable consideration of the petitioner's request. 

Thank you for the consideration of this request and I am prepared to provide any 

information or answer questions in regards to this petitioner. 

Sincerely, 

William S. Bernard 

Director- Flight Operations 

Maryland State Police 

Aviation Command 
^ -

< & 

U.S. Department Flight Standards Service P.O. Box 25504 

of Transportation Aircraft Registration Branch, AFS-750 Oklahoma City, Oklahoma 73125-0504 

(405)954-3116 

Foderal Aviation WEB Address: http://registry.faa.gov 

Administration 

June 28, 2011 

MARYLAND STATE POLICE 

AVIATION COMMAND 

3023 STRAWBERRY POINT RD 

BALTIMORE MD 21220 

IMI.I.,.II..I.I..I.III Il.l 

Dear Sirs: 

Your letter of June 17, 2011, to Mr. J. Randolph Babbitt, Adminstrator, of the Federal Aviation 

Administration, has been forwarded to the Civil Aviation Registry Division for response. 

Your letter stated that the State of Maryland has entered into a contract with Augusta Aerospace 

Corp., in the purchase of 11 AW 139 aircraft with an expected delivery date in niid-2012. You 

requested an exemption to Title M, Code of Federal Regulations, section 47.15(b), that would 

allow you to register these aircraft with registration numbers "NI MSP" through "N11 MSP." It 

was also stated that the availability of 11 consecutive registration numbers ending in "MD" is not 

possible due to members of the medical community owning aircraft. Various reasons were given 

to support how this allowance would be beneficial to the Maryland State Police. 

All aircraft records in the Civil Aviation Registry Aircraft Registration Branch (Registry) are 

maintained in registration number sequence. All records in the aircraft registration computer 

system are also controlled by registration number. Controls have been programmed into the 

computer system to prevent the acceptance of data containing incorrect or impossible elements, 

such as a registration number with six symbols or a registration number with three letters, such as 

you have requested. 

Reprogramming the computer system to accept registration numbers with three letters, such as 

"MSP," would be costly and time consuming. Additionally, relaxing the controls on the present 

system would open the way for error in subsequent entries. 

Section 47.15(b) states, "A U.S. registration number may not exceed five symbols in addition to 

the prefix letter "N". These symbols may be all numbers (N10000), one to four numbers and one 

suffix letter (NIOOOA), or one to three numbers and two suffix letters (N1OOAB). The letters "I" 

and "O" may not be used. The first zero in a number must always be preceded by at least one of 

the numbers 1 through 9." This section of part 47 defines the configuration of a United States 

Registration number. It is notice to other countries, law enforcement agencies, governments, and 

any other party reading the regulation as to what constitutes a United States aircraft registration 

number. A registration number ending in three suffix letters would not meet this definition. 

After researching the aircraft registration database, the Registry found registration numbers, 

N376MD through N389MD, N759MD through N769MD, and N860MD through N881 MD, 

appeared to be available. The Registry contacted Mr. William Bernard, Director-Flight 

Operations, of the Maryland State Police, by phone on June 24, to notify the Maryland State 

Police that these groups of 11 consecutive registration numbers ending in "MD"appeared to be 

AFS-700-LTR-1 (07/04) 
available, and to offer them the opportunity to request reservation. On June 27, Mr. Bernard 

contacted the Registry and conveyed that they had decided not to reserve any numbers at this time 

and wanted to go forward with applying for a petition for exemption. 

To file a petition for exemption you must send it 120 days before you need the exemption to take 

effect. Your petition for exemption must include: 

a. Your name and mailing address. You may include other contact information such as a 

fax number, telephone number, or e-mail address. 

b. The specific section or sections of title 14 of the Code of Federal Regulations (CFR) from 

which you seek an exemption. 

c. The extent of relief you seek and the reason you seek it. 

d. How your request would benefit the public as a whole. 

e. Reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at lease equal to the existing rule. 

f. A summary that can be published in the Federal Register stating the Rule from which you 

seek the exemption and a brief description of the exemption you seek. 

g. Any additional information, views, or arguments available to support your request. 

Send the original signed copy of your petition to Docket Management Facility, US Department of 

Transportation, 1200 New Jersey Avenue, SE, West Building Ground Floor, Room W12-140, 

Washington, DC 20590, or for instructions to file the petition electronically visit the website: 

http://www.faa.gov/regulations_j)olicies/rulemaking/petition/. 

If you require further assistance, please contact the Aircraft Registration Branch at 

(405) 954-3116 or toll free 1 -866-762-9434. 

Sincerely, 

John G. Bent 

Manager, Civil Aviation Registry 
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