March 23,2015 U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, SE., Washington, DC 20590 -- ,; .,.'l ...., ,**~** 

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Subject: Petition for Exemption from compliance to 14 CFR 23.562(a)(b)(c), Arndt. 23-36, for installation ofAviation Fabricator's 62-0428 Stretcher Assembly in Pilatus PC-12, PC12/45, PC-12/47 and PC-12/47E 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) 885-3743 Reference: 1) Type Certificate Data Sheet no. A78EU, Pilatus PC-12, PC-12/45, PC-12/47, PC-12/47E
Extent ofReliefSought by the Applicant: This action requests a grant ofexemption to 14 CFR 23.562(a)(b)(c) for the Aviation Fabricators PIN 62-0428 StretcherAssembly in Pilatus PC-12 series aircraft. The aircraft modification consists ofa novel or unusual design feature(s) associated with the installation ofthe PIN 62- 0428 stretcher assembly, with shoulderharness and lap belts. The applicable airworthiness regulations, as written, do not contain adequately define safety standards for berths; and as such, specific dynamic requirements concerningberths 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 ofthe FAA certification process to pursue issuance ofan FAA SupplementaryType Certificate for the installation of

### PIN 62-0428 stretcher assembly (berth or litter) for a horizontal passenger (medical patient). An illustration ofthe stetcher, its restraint systems, and installation into existing seat tracks is provided in Figure 1below.
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# ~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 ASSEMBLYAVIA'I'IOPJ fABRICATORS 

### LetterNo. AF031815-5999 As the STC applicant, Aviation Fabricators, requests the grant ofan 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 

### Benefitto the Public Interest: The public interest is benefited with the grant ofthis exemptionbecause it allows the installation ofa stretcher in an aircraft operated as an air ambulance. Persons who have undergone traumatic injuries are not always within driving distance to medical care ormedical specialists, especially in rural areas. The use ofmedical 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 ofindividuals in need to medical facilities that are deemed best to provide medical treatment. As such, the transport ofsuch individuals in stretchers, in which their position ororientation in the aircraft may not be optimized as provided in standard aircraft seating. Aviation Fabricators believethat the transport ofpersons in need ofimmediatemedical 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 ofthe applicable FAA Part 23 could lead oneto believethat the original FAA intent ofdynamic 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 specificallydefined. Ifa 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.
..", specificallyrequires complianceto 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 orrequirement in the only subparagraph discussingberths to 23.562. Therefore, one could easilyinterpret these requirements and lack thereofas proofthat 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 StretcherAssembly for operators to install into Pilatus PC-12, PC-12/45, PC-12/47 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 StretcherAssemblybymedical patients needing transportation from inaccessible areas ortime sensitive medical treatment wouldbenefit the public as a whole. The installation ofthe 

### PIN 62-0428 StretcherAssembly would continueto show compliance to 14 CFR 23.785{m), Arndt 23-36, concerningberth and litterrequirements 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 exercisethe privileges ofthis exemption outside ofthe United States and pending foreign civil aviation authority approval to provide installation ofAviation Fabricators 

### PIN 62-0428 Stretcher Assembly in aircraft used in remote or inaccessible locations outside ofthe United States. The Wichita Aircraft Certification Officehas already issued Aviation Fabricators the FAA STC Project No. SA5999WI-A as part ofthe application process for this STC. Sincerely,

G.R. Lowe III CEO Aviation Fabricators, Inc.

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