# A irMethods

US Department of Transportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 October 6, 2011 Submitted via: www.requlations
.gov Dear Sir or Madam: 

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

Air Methods Corporation is a 135 operator providing air medical emergency transportation services
.The company is dedicated exclusivelyto air medical transport, focusing on the quality of care to patients, and safety in aviation operations. Air Methods is requesting exemption from the requirements of 14 CFR 43
.3(g) to allow its properly trained pilots, under an approved training program, to accomplish updates of navigational software databases of installed flight management systems
.This appliesto all Air Methods aircraft used in operations under 14 CFR 135. We believe a precedent was set June of 2011 when NetJets Aviation, Inc was granted an exemption from this regulation allowing the same procedure
. 14 CFR 43.3(g) states: " Except forholders ofa sportpilotcertificate, the holderofa pilotcertificate issued underpart61 may performpreventive maintenance on anyaircraftownedoroperatedbythatpilot which is notused under part121, 129, or135 ofthis chapter." 14 CFR 43.3(a) refers to Appendix A to part 43 as containing the items that are considered to be preventive maintenance and thus subject to provisions in 14 CFR 43
.3(g)
. Specifically, paragraph (c)(32) of Appendix A identifies " updating self-contained , .. . ATC navigationalsoftware databases· asa preventive maintenance item
. In essence, the current rule prevents a pilot who operates an aircraft used under part 135 from accomplishing navigational database updates and requires those updates to be accomplished by authorized maintenance personnel. Air Methods is the largest provider of air medical transportation services in the U.S market transporting approximately 100,000 patients annually and operating over 300 aircraft in 39 states. The nature of our business is to serve the public on demand for emergency care. The possibility exists that a lifesaving mission could be taken while the navigational database is effective and by the time the return flight is initiated the database has expired. As an alternate, flight may be made, indirectly, by flying from VOR station to VOR station until the destination is reached
. However, in many cases, if a direct route cannot be made to non-airport locations i.e
. an accident scene or hospital, we cannot respond with the urgency expected for an emergency situation and the needs of the patient will be compromised. Knowing this, the pilot may decline the flight, resulting in a loss of revenue for Air Methods as well as diminished care at a most critical time for the intended patient. When the navigational database has expired operation ofthe aircraft is permitted by the FAA approved Minimum Equipment List (MEL), but only underVFR operations
.The interests of AMC's customers and the general public are not served if flight routes cannot be used because the navigational database is no longer current. The following observation was made in the Statement of the Problem for consideration of the final ruling for Amendment No. 43-36: "Formanycarriers, locating

### a mechanic each time 

### a request forservice occurs creates lengthy delays that are costlyandcouldbepotentiallylife threatening to injuredor

### illpassengers. Similarly ,providing

### a maintenance crewon 24-hourcallis costprohibitive formanycarriers. "



### 730 I South 

### PCllria
. Englcwolld. Colorado, USA**~(J** I 

### 12
. 

### 303-7'.>2-7400
. FAX 

### 303-790-0-1'.>9Community needs cannot fully be met without the availability of aircraft any time, day or night. Employing 24-hour maintenance on-call could cause an increase in the cost of operation and would result in an economic burden to Air Methods' customers and the public. When the current rule defining database updates as "preventive maintenance" was issued in May, 1996, updating of navigational databases often required removal of the navigation unit from the instrument panel and, in some cases, disassembly of the unit itself
.The rule intended to adapt federal regulations tothe state of modern technology in use at that time. In the ensuing fifteen years, technological advances have led to simple, user-friendly procedures for updating navigational databases. In no case does the navigational database updating procedure prescribed for any of Air Methods aircraft require parts removal, disassembly of a panel-mounted unit, or use of any special tools. Instead, all flight management systems have simple data loaders that obtain navigational database updates via commonly used digital media similar to a memory card for a digital camera. Air Methods believes that allowing its trained pilots to accomplish updates of navigational software databases in their assigned aircraft, provides an equivalent level of safety to that achieved by having authorized maintenance personnel accomplish the update. • AMC's pilots use the flight management system in their assigned aircraft on a daily basis and are thoroughly trained in all aspects of its normal operation and non-normal operating characteristics, to include the installed navigational software database. • Updating the navigational database is simple and does not require any special tools or removal/disassembly of any components
. • AMC's pilots will be specifically trained in all aspects of the updating procedure, including non-normal indications, any required operational check, and the requirement to contact maintenance personnel if any abnormalities are encountered while accomplishing the update. In summary, Air Methods Corporation seeks an exemption to 14 CFR 43.3(g) to allow its pilots that are properly trained and qualified under an approved training program, to perform updating of the ATC navigational software databases on its aircraft used in operations under 14 CFR 135. Granting of the requested exemption will benefit the public because pilot updating of navigational databaseswill increase availability of aircraft for life-saving missions without unnecessarily increasing the cost of service. In seeking this exemption Air Methods Corporation assertsthat an equivalent level of safety, as provided by the current rule, is achieved and maintained by use of its properly trained pilots and approved maintenance procedures. Respectfully,

Kerensa P Moore Maintenance Compliance Technician Air Medical Services Division Air Methods Corporation 303-792-7442