### 09/15/2010 14:03 8153294105

September 14,2010
William D. Holder Park CQunty Sheriffs Office

- Search & Rescue Dept. I 131 II III Street Cody, WY 82414-3536 Docket Management Facility U.S. Department ofTransportation 1200 NewJersey Avenue, SE West Building Ground Floor Room W12-l40 Washington, DC 20590 SAD

Re: Exemption from Code ofRegulations Title 14 Part 23.25 Weight Limits
To Whom It May ConCf;m: 

## ':t:P IS 

# P 3: Sb

Iam petitioning for exemprion 

### from Code ofRegulations Title 

### 14 Pan 23.25 Weight Limits, 

### We currently operate an Avia. AI-B Husky aircraft used for 

### search and rescue operations in the Park County area of Wyoming. In addition; t.his aircraft is also uscd 

### to provide aerial guidance and support

### toground crews, helicopter, and air ambulance helicopters during**~scue** operations.
This aircraft is equipped with the optional 180hp Lycoming 0-360-AIPengine and has demonstrated the ability to operate above the current weight'limit'of-wol)lbrin 3evem}-ctiffereut vemJes: 

### ·The request to 

### openrte slightly 

### above the 

### weight limit 

### of2000100. isa

### result ofthe necessityto

### carry a fulllQad offuel, survival gear, and 2 pllots (1 pilot in command and I observer). Much oftbeequipment we cany is survival gear, which is dropIX'd [I) the groWld to aid victims until help 

### mives. In addition.. in order to utilize as much daylight as possible during an operation and keep 

### the aircraft and**i~** occupants safe, it is essentiallhat we commence each 

### mIssion with full fuel. Funhermore, reduced fuel equates intQ increased take-offand landing cycles. dramatically increasing the c03t ofeach mission to the public. We have calculated the weightand balance in several configurations and have always been within the centerof gravity envelope, As configured the aircraft always comcs above the stated limit of2000lbs to 20851bs.
Ihalte included a list ofselVice bulletins and infonnation documenting the ability ofthe Aviat AI-Bto operate above this weight limit. We are requesting an increased weight limit without modifications in order to comply with regUlations and reduce 

### n.nanciaJ Implications tothe Sheriffsdepanment. You will find in Aviat Service Bulletin No.3 and No. 14 as well as Note 15 ofType Certificate A22NM that the 

### aiRnrfi can be increased to 2200lbs. This would more than adequately cover our loading profile and 

## rbelieve the safety ofthe flight would not be a factor, The requested 2200lbs would be our**takc~ffweigh[** and the aircraft would then**~tum** to smndard weight limits within 1hour offlight due to fuel consumption, Should you decide [0 grant the depanrnenr tl1is relieffrom the weight restriction of2000to 2200 Ibs, I believe it would provide the public a more able searc:h and rescue team and would benefit the department 

### by allowing us to usc the aircraft currently 

### owned to its full potential. Ifinnl)' believe that safety would nOI 

### be compromised by this minor increase.
Thank you fur your time and consideration. Ilook forward to hearing from you. Sincerely,

### ~'

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# ~jam D. Holder '/ Search & Rescue Pilot 307/899-1638
Enclosure 

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