March 23,2015 

U.S. Department ofTransportation, Docket Operations 

West Building Ground Floor, 

Room Wl2-140 

1200 New Jersey A venue, SE., 

Washington, DC 20590 

-- , ; . , . 'l ...., , ~ 2: n ? L,i. '.···• .. 0 . , ·-·-

Subject: Petition for Exemption from compliance to 14 CFR 23.562(a)(b)(c), Arndt. 23-36, for 

installation of Aviation Fabricator's 62-0428 Stretcher Assembly in Pi latus PC-12, PC12/45, PC-12/4 7 and PC-12/4 7E aircraft 

To Whom It May Concern, 

This Petition for Exemption is requested by: ../ 

Aviation Fabricators, Inc. 

CEO, G. R. Lowe III 

805 North Fourth Street 

Clinton, Missouri 64735 

Phone: (660) 885-7531 

Fax: (660) 885-3 743 

Reference: 

1) Type Certificate Data Sheet no. A78EU, Pilatus PC-12, PC-12/45, PC-12/47, PC-12/47E 

Extent of Relief Sought by the Applicant: 

This action requests a grant of exemption to 14 CFR 23.562(a)(b)(c) for the Aviation Fabricators 

PIN 62-0428 Stretcher Assembly in Pilatus PC-12 series aircraft. The aircraft modification 

consists of a novel or unusual design feature(s) associated with the installation ofthe PIN 62-

0428 stretcher assembly, with shoulder harness and lap belts. The applicable airworthiness 

regulations, as written, do not contain adequately define safety standards for berths; and as such, 

specific dynamic requirements concerning berths are open to interpretation. The requested 

exemption will maintain all static loads requirements for gust and emergency landing conditions 

as specified in 14 CFR 23.561 and 23.785. 

Avia~ion Fabricators, as part of the FAA certification process to pursue issuance of an FAA 

Supplementary Type Certificate for the installation of PIN 62-0428 stretcher assembly (berth or 

litter) for a horizontal passenger (medical patient). An illustration of the stetcher, its restraint 

systems, and installation into existing seat tracks is provided in Figure 1 below. 

Page 1 of4 
~IVI?!J§2~ AVIATION fABRICATORS 

PLACARDS~ 

INSTALLEDON ~ 

AIRCRAFT SIDEWALL ·l::::J~ 

Letter No. AF031815-5999 

FERNO 12-1 PORTABLE 

LITTER W/ MATTRESS PAD 

SEAT BELTS 

STRETCHER ASSEMBLY 

Figure 1 - Stretcher and Installation 

Page 2 of4 

MATTRESS ASSEMBLY 

VELCROES TO 

STRETCHER COVER 

ASSEMBLY 

ALUMINUM TOP COVER 

REF 

STRETCHER COVER 

ASSEMBLY 
AVIA'I'IOPJ fABRICATORS Letter No. AF031815-5999 

As the STC applicant, Aviation Fabricators, requests the grant of an FAA Exemption from: 

14 CFR 23.562 (a) Amendment 23-36 

14 CFR 23.562 (b) Amendment 23-36 

14 CFR 23.562 (c) Amendment 23-36 

Benefit to the Public Interest: 

The public interest is benefited with the grant of this exemption because it allows the installation 

of a stretcher in an aircraft operated as an air ambulance. Persons who have undergone traumatic 

injuries are not always within driving distance to medical care or medical specialists, especially 

in rural areas. The use of medical transport aircraft serve that means, and is available to anyone 

in need. While aircraft safety is paramount to the public good, so is the transport of individuals 

in need to medical facilities that are deemed best to provide medical treatment. As such, the 

transport of such individuals in stretchers, in which their position or orientation in the aircraft 

may not be optimized as provided in standard aircraft seating. 

Aviation Fabricators believe that the transport of persons in need of immediate medical treatment 

is more important than strict adherence to FAA regulations designed for typical forward- and aftfacing seats. 

Reasons Exemption \Vould Not Significantly Impact Safety: 

An interpretation of the applicable FAA Part 23 could lead one to believe that the original FAA 

intent of dynamic testing requirements was not meant to be applied to air medical stretchers, or 

berths. 14 CFR 23.561 is a regulation concerning dynamic testing requirements, but 23.785 also 

is a regulation concerning seat requirements. 

23.561 (a) is a generic requirement for all aircraft seats, and specifically defines the requirements 

as applicable to "seats/restraint system for use in ... " It could be argued that a berth is not a seat 

in the conventional way. To determine is berths are seats, let us tum to 23.785 where seats are 

more specifically defined. If a berth is considered a seat, then one would expect that 23.785, like 

23.562, discuss all seats generically as a single term. However, a review of23.785 shows that 

seats and berths are defined and discussed separately. While most of23.785 discuss "seats", 

berths are discussed in 23.785(m) as a stand along component. Furthermore, while 23.785 (b), 

which begins "Each forward-facing or aft-facing seat/restraint. .. ", specifically requires 

compliance to 23.562. 23.785(i), which also requires compliance to 23.562, also starts out with 

"the cabin area surrounding each seat. .. ", there is no reference or requirement in the only subparagraph discussing berths to 23.562. Therefore, one could easily interpret these requirements 

and lack thereof as proof that berths were not intended to be included in the dynamic test 

requirements of23.562. 

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AVIAriON 

~~ fABRICATORS Letter No. AF031815-5999 

Summary 

Granting this request for exemption will allow Aviation Fabricators to produce PIN 62-0428 

Stretcher Assembly for operators to install into Pi latus PC-12, PC-12/45, PC-12/4 7 and PC12/47E aircraft. These aircraft have a rear cargo door suitable for the PIN 62-0428 Stretcher 

Assembly, used as a medical litter, to provide safe, economical, and fast air ambulance 

transportation. Access to the PIN 62-0428 Stretcher Assembly by medical patients needing 

transportation from inaccessible areas or time sensitive medical treatment would benefit the 

public as a whole. The installation of the PIN 62-0428 Stretcher Assembly would continue to 

show compliance to 14 CFR 23.785{m), Arndt 23-36, concerning berth and litter requirements 

for the emergency landing load factors of23.56l(b)(2) Arndt 23-36. 

As Pilatus Aircraft Ltd. is a Switzerland based company, Aviation Fabricators would like to 

exercise the privileges of this exemption outside of the United States and pending foreign civil 

aviation authority approval to provide installation of Aviation Fabricators PIN 62-0428 Stretcher 

Assembly in aircraft used in remote or inaccessible locations outside of the United States. 

The Wichita Aircraft Certification Office has already issued Aviation Fabricators the FAA STC 

Project No. SA5999WI-A as part of the application process for this STC. 

Sincerely, 

G.R. Lowe III 

CEO 

Aviation Fabricators, Inc. 

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