05/19/2010 09:07 FAX 2024935142 FAA DMS 121001/018 

O ••P'S 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

[n Reply Refer To: ACC-7 

Office ofKcgionsl Counsel 

yOl Locust, Room SfX» 

Kansas City, MO Ml06-2641 

ii'..^ : 

Area Code: 816-329-3765 

May 10,2010 

The Honorable Richard C Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. _. 

Fast Building Ground Floor, Room E12-320 

Washington, DC 20590 ~ ' 

Re: Amendmenl - In the Matter of Air Evac RMS. Inc.. FAA Docket No. CPlOCEOOOl, DMS No. I-AAAmendmem - In the Matter of Air livac EMS. Inc. FA A Doci<ei No. CPIOCli0002, DMS No. FAARequest for Consolidation of Ca.ses 

Dear Judge Goodwin: 

Pursuant to 14 CI'R §13.2l4(bXl), enclosed herewith please find a copy of the Amended Complaint in each of the 

two referenced ca.>;es. 

; — I 

2010-0022 

-2010-0024 

At the time the original complainLs were filed, the undersigned erroneously believed in good faith that two similarly 

named corporations existed, each the holder of a different certificate. Since that lime the undersigned ha.'! learned 

ihai there is, in fact, only one corporation. Air Evac EMS, Inc., that holds two separate cenificates. 

In addition, please be advised that legal counsel for the parties have discussed the logistical practicalities, and 

efficiency, of consolidating the referenced cases forbearing purposes. We have agreed it would be in the best 

interest ofall concerned that the cases be consolidated. Accordingly, request is hereby made for the is.suajice of an 

order consolidating these cases for hearing purposes. 

Sincerely, 

A- Lester Haizlip 

Regionaj^Counse! 

By; 

-yl,'-::j-'--i-L' 

MaTk G Camacho 

Senior Enforcement Aliomey 

Federal Aviation Administration 

901 Locu.st Street, Room 506 

Kansa!5 City, MO 64106-2641 

(816)329-3765; Fax (816) 329-3771 

Attorney for Complainant 

Enclosures 

cc: Hearing Docket Clerk (original w/onc copy) 

James E. Ramsey, Esq. 

Air Evac EMS, Inc. 
05/19/201 0 09:0 7 FAX 2024935142 FAA + DMS 0002/01 9 

U.S. DEPARTMENT OF TRANSPOR'IATION 

FEDERAL AVIATION ADMINISTRATION 

In the Matter of: 

Air Evac tMS, Inc. 

Served: May 10, 2010 

FAA Docket No. 

FAA Case No. 2007CE030008 

Judge: Richard C. Goodwin 

Administrative Law .ludge 

AMENDED COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its 

Complaint, pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states 

as follows: 

1. 

1. On February 27, 2007, Respondent Air Fvac EMS, Inc. (AREMS) was advised 

through a Notice of Proposed Civil Penalty that the FAA proposed to assess a civil 

penalty in the amount of $25,000. On February 8, 2010, Respondent submitted a written 

request for a hearing. 

II. 

1. At all times hereinafter mentioned, AEEMS, a Missouri corporation, was the 

holder of Aircrall Repair Station Certificate No. QF.VR436K. 

2. At all times hereinafter mentioned, AEEMS was the holder of Air Carrier 

Certificate No. EVCA731D, an FAA approved on-demand Part 135 operator under the 

Federal Aviation Regulations (FAR). 
05/19/201 0 09:0 7 FAX 2024935142 FAA + DMS @1003/013 

3. At all times hereinafter mentioned Aaron D. Rogers (Rogers), the holder of 

Airman Certificate Number 494941510 with mechanic privileges, airframe and 

powerplant ratings, worked as an AEEMS employee at the West Plains Municipal airport. 

West Plains, Missouri (UNO) for AEHMS's repair station as its Quality Manager (QM). 

4. As AEEMS 's QM, Rogers had the authority and responsibility for ensuring that 

aircraft worked on by AEEMS 's repair station were in an airworthy condition before 

being retuned to service. 

5- As AEEMS 's QM, Rogers had the authority and responsibility for ensuring that 

aircraft returned to service had all required inspections and maintenance items 

accomplished by AEEMS s' repair station. 

6. On or about October 18, 2006, Civil Aircraft N267AE, a Bell Helicopter Model 

206L1, owned and operated by AEEMS, was involved in a repositioning flight from 

West Plains, Missouri, to Sikeston, Missouri, to be put into active Part 135 passengercarrying operations for AEEMS. 

7. Incident to the above operation the crew discovered, upon arrival at Sikeston, that 

there was no key for the narcotics box and retumed to West Plains to retrieve the missing 

key. 

8. On approach to AEEMS' West Plains downtown heliport N267AE experienced a 

mechanical failure consisting of the loss of the tail rotor control system. N267AE was 

able to divert and make a run-on landing at the West Plains Municipal Airport without a 

fatality. 

9. A follow-up inspection of N267AE's tail rotor control system disclosed that a bolt 

that connected adjustable tube PN206-001-002-087 to bcllcrank PN206-001-705-005 had 

come out of the aircraft's tail rotor control/anti-iorque system causing a total break in the 

system while N267AE was in flight. 
05/19/201 0 09:0 7 FAX 2024935142 FAA ^ DMS 21004/018 

10. Incident to N267AE'S mechanical failure an investigation was conducted by 

personnel from the Flight Standards District Office, St. Louis, Missouri (STL FSDO) 

resulting in the following findings: 

a) Prior to the noted operation, AEEMS's repair station perfomied extensive 

modifications and inspection of N267AE pursuant to Work Order (WO) 

#6418. 

b) The noted modifications included replacing the exi.stiiig Detroit Diesel 

Allison-C28 engine with a more powerful Allison 250-C30P engine through 

the application of STC SH296NM, Installation of Detroit Diesel Allison 250-

C30P turbo shaft engine, along with associated airframe and tail rotor control 

modifications. 

c) The noted S'fC modified the tail rotor control/anti-torque system to 

compensate for the increased power and torque. 

d) The subject tail rotor control modification was to be accomplished by 

adjusting the rigging of the anti-torque controls as detailed in Installation 

Instruction No. ASI-206L-30P, Rigging Anti-Torque Controls, Section IIII. 

e) Following modifications and inspection, AEEMS's repair station released 

N267AE for return to service and closed out WO #6418 without 

accomplishing, among other requirements, the noted anti-torque controls 

rigging. 

0 After AEEMS's repair station released N267AE for return to service and 

closed out WO #6418, but prior to the flight operation described in paragraph 

6 above, AEEMS's QM performed maintenance test flights. 
05/19/2010 09:07 FAX 2024935142 FAA + DMS 12005/018 

g) AEEMS's QM also performed additional maintenance on N267AE consisting 

of rigging the rotor control system/anti-torque system discussed above. 

h) The rigging of the anti-torque controls as detailed in Installation Instruction 

No. ASI-206L, Section IIII, required AEEMS's QM to disconnect three 

separate adjustable control tubes from three separate bellcranks followed by a 

series of adjustments. 

i) Detail "A" of Figure 3-1, Anti-Torque Controls, Rigging Dimensions (Sheet 2 

of 2), of the noted installation in-structions, speeifieally identifies the removal 

of the nut, cotter pin, and connecting boll (that came out of the tail rotor 

control system, as described in paragraph 9 above) in order to disconnect 

adjustable tube PN206-001-002-087 from 

bellcrank PN206-001 -705-005. 

j) AEEMS's mechanic Keith Collins (CoUins) started the rigging process, went 

home, and returned the next day to discover that AEEMS's QM had 

completed the rigging and the aircraft was flying. Collins did not reinstall 

adjustable tube PN206-001-002-087 to bcllcrank PN206-001-705-005; that 

task was performed by AEEMS's QM. 

k) Following his performance of maintenance on N267AE's rotor control 

systcm/anri-torque system, AEEMS's QM signed off the maintenance in the 

aircraft's maintenance log certifying that the aircraft was airworthy, and 

returned N267AE to service. 

1) AEEMS's QM sign-off noted above, was the last maintenance entry made in 

N267AE's maintenance log before the occurrence of the mechanical failure 

noted in paragraph 8 above. 
05/19/201 0 09:0 7 FAX 2024935142 FAA + DMS IgjOOB/OIS 

a) Failure to complete required Phase 1 items noted in Blocks 25 and 30. 

b) Failure to provide a Phase 1 inspection sign-off 

c) Permitting the sign-off of all phases (8 total) of the AAIP, except Phase 1 and 

the 12 month inspection portion, to be accomplished by Keith Collins, a 

person who was not a repair station inspector and who did not have return to 

service authority for the repair station. 

d) Failure to provide a 12 month inspection sign-off. 

e) Failure to have the names entered of all mechanics that initialed each phase of 

the AAIP. 

t) Failure to complete the Skyirac ISAT, Intcllicast and Avionics Manual, 

Cables & Computer in.spections found on the Avionics Final 

Inspection/Acceptance checklist, 

g) Failure to audit the records package to detennine that all work had been 

inspected as required for compliance by AEEMS's Quality Control Manual, 

page 8. 

15. Further investigation and inspection of N267AE's maintenance records di.<!clo.sed 

that following the work performed by AEEMS's repair station the aircraft was recertified 

by a Designated Airworthiness Representative (DAR) and a Standard Airworthiness 

Certificate (SAC) wa.<; issued. The reccrtification process required AEEMS to submit a 

listing ofall modifications done to the aircraft at the time in order for the SAC. to be 

properly issued by the DAR. The following items were not listed, as required, thjtt is, 

they were omitted on the application that AEEMS made for the issuance of a SAC: 

a) Reference to installation of STC#SR09442RC, MRL Mount. 

b) Reference to installation of S rC#SR09361RC, High Bar Mod. 

c) Reference to installation of STC#SR09441 RC, Litter Kit. 
05/19/201 0 09:0 8 FAX 2024935142 FAA + DMS g|007/01 8 

d) Reference to installation of STC#SH3887NM, Cabin Heater System. 

e) Reference to installation of STC#SH227WE, Baggage Compartment 

Extension. 

16. AEEMS failed to complete a FAA Form 337, required for all major repairs or 

alterations performed on an aircraft, after the following alterations were performed on 

N267AE: 

a) Installation of STC#SH311OSO, Composite Baggage Door. 

b) Installation of STC#SR01358AT, Baggage Door Retention Strap, 

e) Installation of STC#SROO044AT, Battery Door. 

d) Installation of STC#SR01494AT, Cyclic Support Safety Cover. 

c) Installation of STC#SH3289SO, Cabin Floor Protectors. 

0 Installation of STC#SH200GL, Facet Filter Installation. 

g) Installation of SrC#SH296NM, Installation of Detroit Diesel Allison 250-

C30P turbo shaft engine, 

111. 

1. By reason of the foregoing facts and circumstances, AEEMS violated the following 

sections of the Federal Aviation Regulations: 

a) §43.5(b), which states in relevant part that no person may approve for return 

to service any aircraft that has undergone maintenance, preventative 

maintenance, rebuilding, or alteration, unless the repair or alteration form 

authori/ied by or furnished by the Administrator has been executed in a 

manner prescribed by the Administrator. 

b) §43.13(a). which states in relevant part that each person performing 

maintenance, alteration, or preventive maintenance on an aircrall, engine, or 

appliance shall use the methods, techniques, and practices prescribed in the 
05/19/2010 09:08 FAX 2024935142 FAA * DMS 0008/01 8 

current manufacturer's maintenance manual. 

c) §43.13(b), which states in relevant part that each person maintaining or 

altering an aircraft shall do the work in such a manner that the condition of the 

aircraft or airframe worked on will be at least equal to its original or properly 

altered condition. 

d) §43.15(a)( 1), which states in relevant part that each person performing an 

inspection required by Part 135 of this chapter, shall perform the inspection so 

as to determine whether the aircrall, or portions thereof under inspection, 

meets all applicable airworthiness requirements. 

e) §43.15(a)(2), which states in relevant part that each person performing an 

inspection required by Part 135 of this chapter, shall perform the inspection in 

accordance with the instructions and procedures set forth in the inspection 

program for the aircraft being inspected. 

f) § 145.207(a), which states in relevant part that a certificated repair station must 

follow a repair station manual acceptable to the FAA. 

g) §145.211(b), which states in relevant part that repair station personnel must 

follow the quality control system when performing maintenance, preventative 

maintenance, or alterations under the repair station certificate and operations 

.specifications. 

2. Pursuant to Title 49 U.S.C. 46301, Respondent is subject to a civil penalt^^ not to 

exceed $11,000 for each of the violations alleged. 

3. Under the facts and circumstances of this case, a civil penalty of S25,000 is 

appropriate. 
05/19/201 0 09:0 8 FAX 2024935142 FAA * DMS @]009/018 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that Respondent be assessed a civil penalty in the amount of 

$25,000. 

Dated this 10th day of May 2010. 

Respectfully submitted, 

A. Lester Haizlip 

Regional Counsel 

By: , 

•^L'l I Mark Camacho 

^ - Senior Enforcement Attorney 

Federal Aviation Administration 

901 Locu.st Street, Room 506 

Kansas City, MO 64106-2641 

(816) 329-3765; Fax (816) 329-3771 

Attorney for Complainant 

Answer 

Section 13.209(a) of the Rules of Practice in FAA Civil Penalty Proceedings states, "A 

respondent shall file a written answer to the complaint, or may file a written motion pursuant to 

Section 13.208(d) or Section 13.218(0(1-4) instead of filing an answer, not later than 30 days 

after service of the complaint. 

Section 13,209(f) stales, "A person's failure to file an answer without good cause shall be 

deemed an admission of the truth of each allegation contained in the complaint. 
05/19/201 0 09:0 8 FAX 2024935142 FAA + DMS glOIO/01 8 

10 

Air Evac EMS. Inc . FAA Ca.sc No. 2007CE030008 

CERTIFICATE OF SKRVTCE 

r hereby certify that I have this date providedo a copy of the Agency's Amended Complaint via 

facsimile transmission to the below named addresees as noted, and also placed in the United States mail, 

via regular mail, po.stage prepaid, a copy of the, addressed to: 

Mr. Colin Collins 

President and CFO 

Air Evac EMS, Inc. 

P.O. Box 768-.306 Davis Drive 

West Plains, MO 65775 

Mr. James B. Ramsey, E.sq. 

Cooling & Herbers PC. 

2400 City Center Square 

1100 Main .Street 

Kansas City, MO 64105 

FAX; 816-472-0790 

The Honorable Richard C Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

US. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room £12-320 

Washington, DC 20590 

FAX: 202-366-75-^6 

in addition, I hereby certify that 1 have this date providcde a copy of the Agency's Amended 

Complaint via facsimile iransmission to the below named addresee, and also placed in the United Stales 

mail, via regular mail, postage prepaid, the original and one copy, addressed to: 

Federal Aviation Admini.siralion 

800 Independence Avenue, SW. 

Washington, DC 20591 

Attention; Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Room 2014 

FAX: 202-493-5142 

Dated this 10th day of May 2010. 

Alisa Gausc 

Paralegal Specialist 
05/19/201 0 09:0 8 FAX 2024935142 FAA + DMS 0011/01 8 

U.S. DEPARTMEN'l OF IRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

In the Matter of; 

Air Evac EMS, Inc. 

Served: May 10, 2010 

FAA Docket No, 

FAA Case No. 2007CE030026 

Judge: Richard C. Goodwin 

Administrative Law Judge 

AMENDED COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as follows: 

I. 

1. On February 27, 2007, Re.spondent Air Evac EMS, Inc. (AEEMS) was advised 

through a Notice of Proposed Civil Penalty that the FAA proposed to assess a civil penalty in the 

amount of $15,000. On February 8, 2010, Respondent submitted a written request for a hearing. 

II. 

1. At all times hereinafter mentioned AEEMS was the holder of Air Carrier Certificate 

No. EVCA731D, an FAA approved on-demand Part 135 operator tmder the Federal Aviation 

Regulations (FAR). 

2. At all times hereinafter mentioned AEEMS, a Missouri corporation, was the holder of 

Aircraft Repair Station Certificate No. QEVR436K. 

3. At all times hereinafter mentioned Aaron D. Rogers (Rogers), the holder of Airman 

Certificate Number 494941510 with mechanic privileges, airframe and powerplant ratings, 

worked as an AEEMS employee at the West Plains Municipal airport. West Plains, Missouri 

(UNO) for AEEMS's repair station as its Quality Manager (QM). 

4. As AEEMS's QM, Rogers had the authority and responsibility for ensuring that 

aircraft worked on by AEEMS's repair station were in an airworthy condition before being 

retuned to service. 
05/19/201 0 09:0 8 FAX 2024935142 FAA + DMS 1012/01 8 

5. As AEEMS's QM, Rogers had the authority and responsibility for ensuring that 

aircraft returned to service had all required in.spections and maintenance items accomplished by 

AEEMS's repair station. 

6. On or about October 18, 2006, Civil Aircraft N267AE, a Bell Helicopter Model 

206L1, owned and operated by AEEMS, was involved in a repositioning flight from West Plains, 

Missouri, to Sikeston , Mis-souri, to be put into active Part 135 passenger-carrying operations for 

AEEMS. 

7. incident to the above operation the crew discovered, upon arrival at Sikeston, that 

there was no key for the narcotics box and returned to West Plains to retrieve the missing key. 

8. On approach to AEEMS' West Plains downtown heliport N267AE experienced a 

mechanical failure consisting of the loss of the tail rotor control system. N267AF. was able to 

divert and make a run-on landing at the West Plains Municipal Airport without a fatalit>. 

9. A follow-up inspection of N267AE'S tail rotor control system disclosed that a bolt that 

connected adjustable tube PN206-001-002-087 to bellcrank PN206-001-705-005 had come out 

of tiie aircraft's tail rotor control/anti-torque system causing a total break in the system while 

N267AE was in flight. 

10. Incident to N267AE's mechanical failure an investigation was conducted by 

personnel from the Flight Standards District Office, St. Louis, Missouri (STL FSDO) resulting in 

the following findings: 

a) Prior to the noted operation, AEEMS's repair station performed extensive 

modifications and inspection of N267AE pursuant to Work Order (WO) #6418. 

b) The noted modifications included replacing the existing Detroit Diesel Allison-C28 

engine with a more powerful Alli.son 250-C30P engine through the application of 

STC SH296NM, Installation of Detroit Diesel Allison 250-C30P turbo shaft engine, 

along with associated airframe and tail rotor control modifications. 

c) ITie noted STC modified the tail rotor control/anti-torque system to compensate for 

the increased power and torque. 
05/19/201 0 09:0 8 FAX 202493514 2 FAA •>• DMS 0013/01 8 

d) The subject tail rotor control modification was to be accomplished by adjusting the 

rigging of the anti-torque controls as detailed in Installation Instruction No. ASI2061 .-30P, Rigging Anti-Torque Controls, Section Till. 

e) Following modifications and inspection, AEEMS's repair station released N267AE 

for return to service and closed out WO #6418 without accomplishing, among other 

requirements, the noted anti-torque controls rigging. 

f) After AEEMS's repair station relea.sed N267AE for return to service and closed out 

WO #6418, but prior to the flight operation described in paragraph 6 above, 

AEEMS's QM performed maintenance test flights. 

g) AEEMS's QM also performed additional maintenance on N267AE con.sisting 

of rigging the rotor control system/anti-torque system di.scu5sed above. 

h) The rigging of the anti-torque controls as detailed in Installation Instruction No. ASI206L, Section IIII, required AEEMS's QM to disconnect three separate adju.stable 

control tubes from three separate bellcranks followed by a series of adjustme:nts. 

i) Detail "A" of Figure 3-1, Anti-Torque Controls, Rigging Dimensions (Sheet 2 of 2), 

of the noted installation instructions, specifically identifies the removal of the nut, 

cotter pin, and cormecling bolt (that came out of the tail rotor control system, as 

described in paragraph 9 above) in order to discoimect adjustable tube PN206-001-

002-087 from bellcrank PN206-001-705-005. 

j) AEEMS's mechanic Keith Collins (Collins) started the rigging process, went home, 

and returned the next day to discover that AEEMS's QM had completed the rigging 

and the aircraft was flying. Collins did not reinstall adjustable tube PN206-001-002-

087 to bellcrank PN206-001-705-005; that task was performed by AEEMS's QM. 

k) I'ollowing his performance of maintenance on N267AE's rotor control sy.5tem/antitorque system, AEEMS's QM signed off the maintenance in the aircraft's 

maintenance log certifying that the aircraft was airworthy, and returned N267AE to 

service. 
05/19/2010 09:08 FAX 2024935142 FAA ^ DMS 01014/018 

I) AEEMS's QM sign-o(T, noted above, was the last maintenance entry made in 

N267AE's maintenance log before tlie occurrence of the mechanical failure noted in 

paragraph 8 above. 

m) A visual inspection ofN267AE's rotor control sysiem/anti-torque system after the 

mechanical failure (noted in paragraph 8 above) revealed the subject connecting bolt 

was lying in the belly of the aircraft; no nut or cotter pin was found. 

11. The foregoing maintenance performed by AEEMS's QM on N267AE was not 

accomplished pursuant to the provisions of Installation Instruction No. AS1-206L, Section IIII in 

that he failed to ensure that the subject adjustable tube PN206-001-002-087 connecting bolt was 

properly secured in place following reassembly of the adjustable tube to its designated bellcrank. 

12. Accordingly, N267AE was not in an airworthy condition at the time AEEMS's QM 

returned the aircraft to service after his October 18, 2006, maintenance and sign off on the rotor 

control system/anti-lorque system. 

13. ITie foregoing maintenance performed on N267AE's rotor control system/anti-torque 

sy.stem was not accomplished pursuant to the provisions of AEEMS' Quality Control Manual, 

Pages 4 and 7, which require that the discrepancy sheet be supplemented with detailed 

instructions for work and inspection, and that a work card be issued for a discrepancy, if the 

overall task is divided between more than one technician. No such supplemental detail or work 

card was prepared for the rigging started by Collins on one day and completed by AEEMS's QM 

the next day. 

14. Further investigation and inspection of AEEMS's repair station records pertaining 

to maintenance work performed on N267AE prior to the closing out of WO #6418 disclosed 

that AEEMS's failed to follow its quality control system by approving N267AE for return to 

service and closing out WO #6418 without complying w\\h AEEMS' Approved Aircraft 

Inspection Program (AAIP) final inspection requirements and without complying with its 

Quality Control Manual, to include: 

a) Failure to complete required Phase I items noted in Blocks 25 and 30. 
05/19/201 0 09:0 9 FAX 2024935142 FAA + DMS 0015/01 8 

b) Failure to provide a Phase 1 inspection sign-off. 

c) Permitting the sign-off of all phases (8 total) of the AAIP, except Phase 1 and the 12 

month inspection portion, to be accomplished by Keith Collins, a person who was not 

a repair station inspector and who did not have return to service authority fo.r the 

repair station. 

d) Failure to provide a 12 month inspection sign-off. 

e) Failure to have the names entered ofall mechanics that irutialed each phase of the 

AAIP. 

f) Failure to complete the Skytrac ISAT, Intellicast and Avionics Manual, Cables & 

Computer inspections found on the Avionics Final Inspection/Acceptance checklist. 

g) Failure to audit the records package to determine that all work had been inspected as 

required for compliance by AEEMS's Quality Control Manual, page 8. 

15. Further investigation and inspection of N267AE's maintenance records disclosed that 

following the work performed by AEEMS's repair station the aircraft was recertified by a 

Designated Airworthiness Representative (DAR) and a Standard Airworthiness Certificate 

(SAC) was issued. The recertification process required AEEMS to submit a li.sting ofall 

modifications done to the aircraft at the time in order for the SAC to be properly issued by the 

DAR. The following items were not listed, as required, that is, they were omitted on the 

application that AEI made for the issuance of a SAC: 

a) Reference to installation of STC#SR09442RC, MR). Mount. 

b) Reference to installation of STC#SR09361RC, High Bar Mod. 

c) Reference to installation of STC#SR09441 RC, Litter Ki t. 

d) Reference to in.stallation of STC#SH3887NM, Cabin Heater System. 

e) Reference to installation of STC#S1-I227WE, Baggage Compartment Extension. 

16. AEEMS failed to complete a FAA Form 337, required for all major repairs or 

alterations performed on an aircraft, after the following ahcrations were performed on 

N267AE: 
05/19/201 0 09:0 9 FAX 202493514 2 FAA •*• DMS 0016/01 ! 

a) Installation of STC#SH311 OSO, Composite Baggage Door. 

b) Installation of STC#SR01358AT, Baggage Door Retention Strap, 

c) Installation of STC#SROO044AT, Battery Door. 

d) Installation of Sl'C#SR0l494AT, Cyclic Support Safety Cover. 

e) Installation of STC#SH3289SO, Cabin Floor Protectors. 

f) Installation of STC#SH200GL, Facet Filter Installation. 

g) Installation of STC#SH296NM, Installation of Detroit Diesel Allison 250-C30P turbo 

shaft engine. 

17. Based on the foregoing AEEMS operated N267AE at a time when said aircraft was 

not in an unairworthy condition. 

III. 

1. By reason of the foregoing facts and circumstances, AEEMS violated the following 

sections of the Federal Aviation Regulations: 

a. §91.7(a), which states that no person may operate a civil aircraft unless .it is in an 

airworthy condition. 

b. §135.21(a), which states in relevant part that each certificate holder's flight, ground 

and maintenance personnel must use the certificate holder's current procedures 

manual in conducting its operations. 

c. §135.419(g), which stales that each certificate holder who has an approved aircraft 

inspection program shall have each aircraft that is subject to the program inspected in 

accordance with the program. 

2. Pursuant to Title 49 U.S.C. 46301, Respondent is .subject to a civil penalty not to 

exceed $\ 1,000 for each of the violations alleged. 

3 Under the facts and circumstances of this case, a civil penalty of $ 15,000 is appropriate. 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that Respondent be asses.<5ed a civil penalty in the amount of $15,000. 
05/19/2010 09:09 FAX 2024935142 FAA DMS 0017/01 8 

Dated this 10th day of May 2010. 

pi--'^-

Respectfully submitted, 

A. Lester Haizlip 

Regional Counsel 

By: 

.•^/>''^ ' 

Mark Camacho 

"Senior Enforcement Attorney 

Federal Aviation Administration 

901 Locust Street, Room 506 

Kansas City, MO 64106-2641 

(816) 329-3765; Fax (816) 329-3771 

Attorney for Complainant 

Answer 

Section 13.209(a) of the Rules of Practice in FAA Civil Penalty Proceedings states, 'A 

respondent shall file a written answer to the complaint, or may file a written motion pursuant to 

Section 13.208(d) or Section 13.218(f)(]-4) instead of filing an answer, not later than 30 days 

after service of the complaint. 

Section 13.209(f) states, "A person's failure to file an answer without good cause shall be 

deemed an admission of the truth of each allegation contained in the complaint. 
05/19/201 0 09:0 9 FAX 2024935142 FAA + DMS 0018/01 8 

Air Evac EMS. Inc.. FAA Case No. 2007CE030026 

CERTIFICATE OF SERVICE 

1 hereby certify that I have this date provided a copy of the Agency's Amended Complaint via 

facsimile transmission to the below named addressees as noicd, and also placed in the United Stales mail, 

via regular mail, postage prepaid, a copy of the, addressed to; 

Mr. Colin Collins 

President and CEO 

Air Evac EMS, Inc. 

P.O. Box 768-306 Davis Drive 

West Plains, MO 65775 

Mr. James E. Ram.sey, Esq. 

Cooling & Herbers P.C. 

2400 City Center Square 

1100 Main Street 

Kansas Cit>'. MO 64105 

FAX: 816-472-0790 

The Honorable Richard C Goodwin 

Administrative Law Judge 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

East Building Ground Floor, Room E12-320 

Wa.shington, DC 20590 

FAX: 202-366-7536 

In addition, T hereby certify that I have this dale provided a copy of the Agency's Amended 

Complaint via facsimile transmission to the below named addressee, and also placed in the United States 

mail, via regular mail, postage prepaid, the original and one copy, addressed to: 

Federal Aviation Administration 

800 Independence Avenue, SW. 

Washington, DC 20591 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building, Room 2014 

FAX: 202-493-5142 

Dated this 10th day of May 2010. 

• ^/•J-ifU^<t< _ 

Alisa Gause 

Paralegal Specialist