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 of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-l40 

Washington, DC 20590 

SAD 

Re: Exemption from Code of Regulations Title 14 Part 23.25 Weight Limits 

To Whom It May ConCf;m: 

':t:P IS P 3: Sb 

I am petitioning for exemprion from Code of Regulations 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 to ground crews, 

helicopter, and air ambulance helicopters during ~scue operations. 

This aircraft is equipped with the optional 180hp Lycoming 0-360-A I P engine 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 of 2000100. isa result of the necessity to carry a fulllQad of fuel, 

survival gear, and 2 pllots (1 pilot in command and I observer). Much oftbe equipment 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-off and landing cycles. dramatically increasing the c03t of each mission to the public. We have 

calculated the weight and balance in several configurations and have always been within the center of 

gravity envelope, As configured the aircraft always comcs above the stated limit of2000lbs to 20851bs. 

I halte included a list ofselVice bulletins and infonnation documenting the ability of the Aviat AI-B to 

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 to the Sheriffs depanment. You will find in 

Aviat Service Bulletin No.3 and No. 14 as well as Note 15 of Type Certificate A22NM that the aiRnrfi can 

be increased to 2200lbs. This would more than adequately cover our loading profile and r believe the safety 

of the 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 1 hour of flight due to fuel consumption, 

Should you decide [0 grant the depanrnenr tl1is relief from the weight restriction of2000 to 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. I finnl)' believe that safety would nOI 

be compromised by this minor increase. 

Thank you fur your time and consideration. I look forward to hearing from you. 

Sincerely, ~' 

~ •.. ,/'.. I ( , ,: " .', 

'" - .. I1f?/~,·,~ ~. . ~ ~jam D. Holder '/ 

Search & Rescue Pilot 

307/899-1638 

Enclosure 

PAGE 02/03