AFS-12-018-E 

February 3, 2012 

 Exemption No. 10445 

 Regulatory Docket No. FAA-2011-1102 

Ms. Kerensa P. Moore 

Maintenance Compliance Technician 

Air Methods Corporation 

7301 South Peoria Street 

Englewood, CO 80112 

Dear Ms. Moore: 

This letter is to inform you that we have granted your request for exemption and 

explains the basis and conditions for the exemption. 

By letter dated October 6, 2011, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Air Methods Corporation (Air Methods), for an exemption from 

§ 43.3(g) of Title 14, Code of Federal Regulations (14 CFR). This exemption, if 

granted, would allow Air Methods’ properly trained pilots (under an approved training 

program) to perform updates of navigational data systems configured with a data loader 

permanently installed on the flight deck, as described below. 

Air Methods holds a part 135 operating certificate and provides air medical emergency 

transportation services with a fleet of 320 medically equipped aircraft, mainly 

helicopters. Air Methods is the largest provider of emergency medical airtransportation services in the U.S. and contracts with hospitals in 30 states to transport 

critically ill patients to trauma centers or tertiary care facilities. Air Methods seeks 

relief from § 43.3(g), and part 43, Appendix A, paragraph (c)(32), which categorizes as 

preventive maintenance the updating of “self-contained, front instrument panelmounted Air Traffic Control (ATC) navigational software data bases (excluding those 

of automatic flight control systems, transponders, and microwave frequency distance 

measuring equipment (DME)) provided no disassembly of the unit is required (hereafter 

“navigational database”)”. 
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Upon review of the petition, we noted that Air Methods did not request exemption from 

§ 135.443(b)(3), or part 43, Appendix A, paragraph (c)(32). In a prior exemption issued 

to NetJets, Exemption No. 10286A, we granted exemption to § 135.443(b)(3) which 

requires that the operator have the maintenance provider sign the airworthiness release 

and/or record performance of the update in the maintenance log. Relief from this 

requirement is needed in addition to exemption from § 43.3(g). In the second case, 

part 43, Appendix A, paragraph (c)(32) categorizes the type of equipment for which the 

exemption would apply as preventive maintenance. We are amending the petition to 

include a request for exemption from both part 43, Appendix A, paragraph (c)(32), and 

§ 135.443(b)(3) in order for this exemption to Air Methods to provide effective relief. 

The FAA has determined that good cause exists for not publishing a summary of the 

petition in the Federal Register because the requested exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Air Methods. 

The Basis for Our Decision 

We have reviewed this petition and determined that Air Methods has demonstrated a 

public interest that justifies exemption from the stated regulations. Air Methods 

conducts operations almost exclusively for medical emergencies. Some medical 

emergencies take place in remote areas or away from airports such that the Petitioner's 

aircraft may arrive at the scene while the database is current, but by the time flight is 

initiated to return to the medical center the database may have expired, which would 

require the pilot to fly an indirect route at the cost of critical time to the patient. In all 

emergency medical flights, time is of the essence. For this reason, we conclude that 

granting exemption to Air Methods for the relief sought is in the public interest. 

In the exemption issued to NetJets, Exemption No. 10286, the FAA concluded that 

technology has sufficiently simplified the process of updating navigational databases to 

allow pilots to perform the updates and still maintain the equivalent level of safety 

achieved under current regulations that require a certificated mechanic to perform the 

task. Using current technology, database loading of front panel and pedestal mounted 

navigational systems does not require special training, tools, special access, or removal 

of the system. Further, most navigational systems perform automatic update 

verification. Properly trained pilots can readily load the current software databases and 

confirm the upload was successful. If the upload is unsuccessful, as indicated by 

automated report, minimum equipment list procedures exist to safely operate the 

aircraft with an inoperative navigational system to the closest next place where the 

updating can be performed. 

As a condition to the NetJets exemptions, we required that pilots must include a record 

of each update in the maintenance log providing the name of the person performing the 

upload, the date of the upload, the database revision number uploaded, and the aircraft 

location at the time of the upload, which is similar to current requirements for 
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certificated mechanics performing uploads. This exemption to Air Methods is similar 

to that of NetJets in that it grants relief from §§ 43.3(g), part 43 Appendix A, paragraph 

(c)(32), and 135.443(b)(3), and is contingent upon the pilot’s compliance with the 

condition to record all updates in the maintenance logbook. 

Having reviewed your reasons for requesting an exemption, I find that— 

 conducting medical emergency operations is in the public interest, 

 for the reasons stated by the FAA in granting the attached Grants of Exemption 

Nos. 10286 and 10286A, an equivalent level of safety will exist as that provided 

by regulation. 

Our Decision 

Under the authority contained in 49 U.S.C. §§ 40113 and 44701(f), which the FAA 

Administrator has delegated to me, I hereby grant Air Methods Corporation an 

exemption from 14 CFR §§ 43.3(g), part 43, Appendix A, paragraph (c)(32), and 

135.443(b)(3), to the extent necessary to allow its properly trained pilots (under an 

approved training program) to accomplish updates of navigational software database 

updating, subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. Pilots will be trained on all specific makes and models or navigational 

system databases meeting the description above to which they will be 

uploading navigational software databases. Training on one make and 

model will not enable the pilot to update databases in other makes and 

models. 

2. Upon successful completion of training, each pilot will be authorized, in 

writing, by the director of maintenance or authorized designee to perform 

navigational software database uploads on systems for which he or she has 

received training. 

3. The software being uploaded cannot contain system operating software. The 

upload must include the navigational database only. The director of 

maintenance is responsible for ensuring the software being uploaded does 

not contain operating system software. 

4. Air Methods must have written procedures available to the pilot to perform 

the task and to evaluate the accomplishment of the task, including those 

tasks that require a decision concerning the airworthiness of the aircraft. 

5. Maintenance log entries must be made each time the task is completed 

including the name of the person performing the upload, the date of the 

upload, the database revision number uploaded, and the aircraft location at 

the time of upload. 
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6. This grant of exemption from § 43.3(g) applies only to uploading 

navigational software databases, as provided by Appendix A to part 43, 

paragraph (c)(32), using a data loader that is permanently installed in the 

flight deck. It does not extend to other preventive maintenance tasks 

identified in Appendix A to part 43. 

This exemption terminates on February 28, 2014, unless sooner superseded or 

rescinded. 

Sincerely, 

/s/ 

John M. Allen 

Director, Flight Standards Service 

Enclosures