July 9,2012 Mr. Ian Wong Fed e ral Aviation Administration Transport Dire cto rate 1601 Lind Ave. SW Renton , WA 98057 FAA Project SA 7865CH -T Dear Mr

. Wong: Med-Pac, I nc . has h i red my company to act as their agent in the cert ification of the Med-Pac Air Am bulance Unit, Model 400 into Cessna Aircraft Company Model 680 Sove reign airplanes. As Med - Pac's agent, I am petit ioning for an exemption from 14CFR 25.562 and 25.78S{b) to the extent ne c essary to pe rmit th e certification of the Med-Pac Air Ambu l ance Unit Mod e l 400 for tran sport of persons w h ose m ed ical co ndit ion di c tates such accommodations. Section 25.785 {b) (Section 25.785(a) at Amendment 25-64) requires that each seat , berth, safety belt , harne ss, a nd adjacent part of the airplane at each station de signate d as occupiable during takeoff and l anding be design ed so that a person making proper use of those fa cilitie s will not suffer serious injury in an emergency l anding as a result of inertia forces specified in 25.561 a nd 25.562. Section 25.562 specifies dynamic test conditions for qualification of occupant injury criteria, as well as structura l retention criteria. M ed - Pa c owns supplemental type certificates (STCs) for installin g the Mod e l 400 Air Ambulance Unit in numerou s part 23 and part 25 aircraft. None of the previou s installations have been shown to meet the dyn a mi c criteri a. FAR part 23 specifically excludes litters from the dynamic criteria. All prev ious in s tallat io n s have m et the certification requirements for each aircraft with n o adverse experiences. The estimated cost of demonstrating compliance is quite h igh considering the l imited number of un i t s f or w h ich M ed -Pac (Qu i d amortize the cost. Since n o ne have bee n shown to co mply with the dynamic t est c rit e ria , th e air ambulance unit can not c urre ntly be u sed on airp l an es whose type ce rtificate basis i nclude s dynam ic requirements. Curre ntl y, a p erso n who needs to trave l for esse ntial medi ca l care c an ei th e r chart e r an airplane at a sig nificant cost, or fa i l to re ceive the r equ ired treatment if charte rin g an airp l ane i s cost prohibitive

. Another a lt ernative available would be to fly o n an aircraft whose ce rtifi ca tion basis does not require dynamic testing. Thi s would offer no i n crease in sa fety and may not be readily avai l able.Med - Pac believes th at g ranti ng the petiti on would be in the public in te rest fo r th e foll owing reasons: 

# + Th e level of sa f ety th at would be provided is an acceptable l eve l of safety given the limited use of th e ai r am bulance unit

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# + Th e exemp ti on would relieve an economic burd e n on a segme nt of the travel in g publi c a lready d ea ling w i t h adve rsity

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# + Sect i o n 25.562 is written for seats and would n ot be easily ap pli ed to a litter. Compliance wi th th e dynamic t est requirements would be difficult , very expens i ve an d wo uld n ot yie ld a mea surable sa f ety benefit. Med-Pa c i s requesting the FAA waive publi cation a nd public com m ent. Th e proj ect i s scheduled for co mpletion the e nd o f Jul y. Please contact me with any questions or concerns. R

e a rd s, 

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# aCkieGO**~W** Certification M a nage r (represe nting Med - Pa c, In c.)