J 

May 10,2012 

US Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

To Whom It May Concern, 

p 1:41 

Enclosed is a petition to Federal Aviation Administration (FAA) for an extension of exemption 

from; Sections 91.41l(b) and 91.413(c) of Title 14, Code of Federal Regulations. Reference 

existing docket# FAA-2008-0994. 

The Center for Emergency Medicine, d/b/a STAT MedEvac is an emergency medical services 

(EMS) operator, with over 28 years of experience in our operational area. The petition would 

authorize the Center for Emergency Medicine to perform altimeter systems, altitude reporting 

equipment and ATC transponder test and inspections on company aircraft by company 

employee's that hold an airframe and powerplant rating, FCC rating and factory training by the 

manufacture of the aircraft being inspected and tested under the current authorized Center for 

Emergency Medicine of Western Pa, Inc. Approved Aircraft Inspection Program. (AAIP). 

Thank you in advance for your consideration. Should you have any questions, I may be reached 

at 412-460-3000 Ext. 268. 

Chuck Horgan 

Director of Maintenance 

Center for Emergency Medicine of Western Pennsylvania, Inc. 

STAT MedEvac 

Enclosure ( 1) 
Center for Emergency Medicine 

D/b/a STAT MedEvac 

Certificate#: E3MA774L 

',, 

10 Allegheny County Airport 

West Mifflin, PA 15122 

Contact: Chuck Horgan, Director of Maintenance 

Phone: 412-460-3000, Fax: 412-466-8963 

't •. 

Petitions for an extension of exemption from Sections 91.411 (b) and 91.413(c )'of 

Title 14, Code _of Federal Regulations 

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This is a; petition to the Federal Aviation Administration (FAA) for ail extebsion of exemption from: 

Sections 91.4ll(b) and 9L413(c) of Title 14, Code of Federal regulations. Reference docket# FAA2008~0994 ; 

The Center for Emergency Medicine, d/b/a STAT MedEvac is an emergency medical services (EMS) 

operatbr, with over 30 years of experience on our operational area. This petition would authorize the 

Center for Emergency Medicine to perform altimeter systems, altitude reporting equipment and ATC 

transponder tests and inspections on company aircraft by company employee's that: hold an airframe and 

powerplant rating, FCC rating and factory training by the manufacture of the aircraft being inspected and 

tested under the current authorized Center for Emergency Medicine of Western Pa, Inc. Approved 

Aircraft -Inspection Program (AAIP). ' ~ · · · · · · ·· 

The Center for Emergency Medicine requests the relief from the following sections: •.• !' ' 

A. Section· 91:411(b) states,· in pertinent part, that-the tests required by paragraph (a) ofthis section must 

be COndUCted by- I r_ ' 

(1) The manufacture of the airplane, or helicopter, on which the tests and inspection· . 

are to be performed; 

• · (2) A certificated repair station properly equipped to perform those functions holding-

: ·· · '(i) An instrument rating, Class I; · 

~ · · (ii) A limited insti"hment rating appropri'ate to make·and model of appliance to be-tested; 

(iii) A limited rating appropriate to the test to be performed; · · ; -· · 

(iv) An airframe rating appropriate to the airplane, or helicopter, to be tested; or 

(3) A certified mechanic with an airframe rating (static pressure system tests and inspections 

only) ., ' 

B. Section 91.413(c) states, in pertinent part that the tests and inspections specified in this section must 

be conducted by-

(1) A certificated repair station properly equipped to perform those functions and ·hoidirig-

(i) A radio rating, Class ill; . 

(ii) A limited radio rating appropriate to the make and model transponder to be.tested;- ' ~ 

(iii) A limited rating appropriate to the test to be performed; · · · ~-' > · (2) A holder of a continuous airworthiness maintenance program as provided in pahj 121 or 

§ 135.4ll(a)(2) of this chapter; or · 

(3) The manufacturer of the aircraft on which the transponder to be tested is installed, if the 

transponder was installed by the manufacturer. 

f 
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C. The Center for Emergency Medicine supports this request for extension of exemption of docket # 

FAA-2008-0994 with the following information: 

In the interest of public safety the Center for Emergency Medicine qf \)'est~m Pennsylvania, Inc. 

believes that the granting of this exemption request is clearly aligned }Vith the FAA and Mission 

Statement: "To provide the safest, .mo~t efficient,aero~pace system \n,the,wc;>,rld". _: ... 

The Center for Emergency Medicine is dedicated to the safety of its employee's and the general 

public. By supporting this request, the Center for Emergency Medicine shall serve the public in a 

saf~r manner 'Vith a eyen tighter operational contrql then the.basic r~uirements.,Allo~ing the Center 

for Emergency Medicine to perfor,m its p~n in house 9 ~A 11, and 91.~ 13 testes ,and, inspections by its 

qualified, trained employee's shall reduce delays in aircraft availability that serve the public in the tristate area. 

I I •. ,.': : 

The Center for Emergency Medicine'.~ tr~~ned pef~onnel already Stre.performing 91.411-~nd 91.4p 

tests and inspectic;>ns prior to)ocal a~iOJ;Ji~ repair facilities tests and inspec;:tion on company. a\rcraft. 

the Center for Emergency Me<;licine's trained personnelhas,.over,30.years ~xper,i_ence,wit\191.4~ 1 , 

., and91.413testsandinspections .. _,,,;,.·,:: ~· ,. ,;t • , .. , .,., 

I · ' i ~~ • · ~ • , ·• • ' ! .. , 

Ex~mpti~~ .from (FAR), section 9.1.4l3(c) and 9l.411(b) wodld p~oyide a high~r: level o.f. s.afety -~~-:. 

under the current rule. 

, • I i: I r: r' 

The Center for Emergency Medicine is currently one of the largest private air medical providers in 

. ~he United,States of America. Cunently, we perf9~ over 11,000 patient fligb.ts per yeru;,_.tl)is is 

already public interest. This exemption would allow us to utilize our current trained staff, 

improving the reli.ability pf our s~rv~ce ro,ollr customers. ,, . ·. · ... 

,. 

The Centet; for Emergency Medi<;ine: s ~ychnjcal ~.taff pp~rates 24; hours a day, seven 4ays a week, 

365 days per year, outside vendors that can perform the checks are in many· case~~ only;~vailable 

during th~ day, Current a,vailability of these outside, yendors require us,to hol,d ain;:ra,f~ out of service 

for additional days to fit their schedule. . ,, . l 

'., r - ,., :·~· 

Thank you for your consideration. If you should have any questions I can be reached at 

chorgan@statmedevac.com. . .. 

Sinqerely;·. 

ChuckHo_rgan · 

Director of Maintenance ' 

Center for Emergency Me<;licine ofWe~tem Pennsylvania, Inc. 

Office: 412-460-3000 (ext. 268) 

Cell: 412-418-1002 

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