AFS-11-202-E 

August 12, 2011 

 Exemption No. 10328 

 Regulatory Docket No. FAA-2011-0182 

Mr. Michael Daigneault 

Director, Flight Standards 

CitationShares Management, LLC 

5 American Lane 

Greenwich, CT 06831 

Dear Mr. Daigneault: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision: 

By letter dated February 28, 2011, you petitioned the Federal Aviation Administration (FAA) 

on behalf of CitationShares Management, LLC (CitationShares), for an exemption from 

§ 43.3(g) of Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted, 

would allow CitationShares’ properly trained pilots (under an approved training program) to 

accomplish supervised updates of navigational software databases of installed flight 

management systems. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to CitationShares. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 10286 (copy enclosed), the FAA 

found that the flight management computer (FMC) technology has evolved sufficiently to 

support the granting of the applicant’s request for exemption based on an equivalent level of 

safety being attained by pilots loading navigational software databases as currently exists with 
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certificated mechanics performing uploads. Database loading of front panel and pedestal 

mounted FMCs does not require special tools, special access, or removal of the FMC. 

Further, FMCs perform an internal check and confirm proper loading of navigational 

databases in most cases. Properly trained pilots can load the software databases and confirm 

the upload was successful. Should the upload attempt be unsuccessful, minimum equipment 

list procedures already exist to safely operate the aircraft with an inoperative FMC. 

Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption No. 10286; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 10286 

apply to the situation you present; and 

 for the reasons stated in Grant of Exemption No. 10286, a grant of exemption is in the 

public interest. 

Our Decision: 

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant CitationShares Management, LLC, an exemption from 

14 CFR § 43.3(g) to the extent necessary to allow properly trained pilots (under an approved 

training program) to accomplish supervised updates of navigational software databases of 

installed flight management systems, subject to the conditions and limitations listed below. 

Conditions and Limitations: 

1. Pilots will be trained on all specific makes and models of the FMC to which they 

will be uploading navigational software databases. Training on one make and 

model will not enable the pilot to update databases in other makes and models. 

2. Upon successful completion of training, each pilot will be authorized, in writing, 

by the director of maintenance or authorized designee to perform navigational 

software database uploads on systems for which he or she has received training. 

3. The software being uploaded cannot contain system operating software. The 

upload must include the navigational database only. The director of maintenance 

is responsible for ensuring the software being uploaded does not contain operating 

system software. 

4. CitationShares must have written procedures available to the pilot to perform the 

task and to evaluate the accomplishment of the task, including those tasks that 

require a decision concerning the airworthiness of the aircraft. 

5. Each completed task must include the maintenance log entries, including the name 

of the person performing the upload, the date of the upload, the database revision 

number uploaded, and the aircraft location at the time of upload. 
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6. This grant of exemption from § 43.3(g) includes only the uploading of 

navigational software databases as listed in Appendix A to part 43, paragraph 

(c)(32), and does not extend to other preventive maintenance tasks identified in 

Appendix A to part 43. 

This exemption terminates on August 31, 2013 unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Acting Deputy Director, Flight Standards 

 Service 

Enclosure