A irMethods 

US Department of Transportation 

1200 New Jersey 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 exclusively to 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 applies to 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 for holders of a sport pilot certificate, the holder of a pilot certificate issued under part 61 may 

perform preventive maintenance on any aircraft owned or operated by that pilot which is not used under 

part 121, 129, or 135 of this 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 navigational software databases· as a 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 of the aircraft is permitted by the FAA approved Minimum 

Equipment List (MEL), but only under VFR 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: 

"For many carriers, locating a mechanic each time a request for service occurs creates lengthy delays that 

are costly and could be potentially life threatening to injured or ill passengers. Similarly, providing a 

maintenance crew on 24-hour call is cost prohibitive for many carriers." 

730 I South PCllria . Englcwolld. Colorado, USA ~(J I 12 . 303-7'.>2-7400 . FAX 303-790-0-1'.>9 
Community 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 to the 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 databases will increase availability of aircraft for life-saving missions 

without unnecessarily increasing the cost of service. In seeking this exemption Air Methods Corporation asserts that 

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