### BEFORE THE FEDERAL AVIATION ADMINISTRATION WASHINGTON, D.C.


## * In the Matter ofthe Petition of 

## * 

# * CHAMPLAIN ENTERPRISES, INC. 

## * d/b/a COMMUTAIRIUNITED EXPRESS

## * Regulatory Docket No. 

# * for an exemption from FAR 121.344(e) 

## * 

# *

PETITION FOR EXEMPTION

Communications withrespectto this document should be sentto: James W. Tello LAW OFFICES OF JAMES W. TELLO 1025 Connecticut Avenue, N.W., Suite 1000 Washington, D.C. 20006 Phone: (202) 399-1918 Fax: (202) 478-0244 E-mail:jamestello@earthlink.net Attorney for CHAMPLAIN ENTERPRISES, INC. d/b/a COMMUTAIRIUNITED EXPRESS

June 8, 2011

### BEFORE THE FEDERAL AVIATION ADMINISTRATION WASHINGTON,D.C. 

# * Inthe Matterofthe Petition of 

## * * CHAMPLAIN ENTERPRISES,INC. 

# * d/b/a COMMUTAIRIDNITED EXPRESS

## * Regulatory DocketNo. 

## * for an exemption from FAR 121.344(e) 

## * *

PETITIONFOREXEMPTION

Pursuant to 14 C.F.R. Section 11.25, Champlain Enterprises, Inc. d/b/a CommutAirlUnited Express ("CommutAir" orthe "Petitioner") hereby petitions for exemption from 14 C.F.R. 121.344(e), to the extentrequired to permitthe operation ofBombardier Q-300 aircraftN839CA and N837CA (both manufactured between August 18,2000, and August 19, 2002) using 34 parameter digital flight datarecorder, orfor such alternative reliefas otherwise requested here. In accordance with 14 C.F.R. Section I1.8I(f), a summary ofthatrequest is attached as Exhibit 1to this application.

PRIMARY RELIEF REQUESTED
1. The Company is an air carrier certificated bythe FAA pursuantto FAR 119 and holding operations specifications issued pursuant to FAR 121 which permit domestic, flag and supplemental operations.
2. FAR 121.344requires the installation ofa digital flight datarecorderfor turbine-engine powered transport category airplanes thatrecords a varying list ofparameters

### depending upon when the airplane was manufactured, providing that in certain noted instances,
no change ininstalled equipmentis required to obtainthe specified parameter. The Bombardier Q300 aircraft is subject to this rule, and theparameters specified for the DFDR systemrequired
are set forth in 121.344(d) (34 parameters for aircraft manufactured after October 11, 

### 1991); (e) (57 parameters for aircraft manufactured after August 18,2000); and (t) 

### (88 parameters for aircraft manufactured after August 19, 2002).

3. There are a total of 14 Dash 8, Series 300, airplanes in FAR 121 service, all ofwhich have manufacturing dates consistent with a DFDRhaving no morethan 34 parameters

- dates priorto August 18,2000. There were 33 Series 300 airplanes built by Bombardier after August 18,2000and before August 19,2002, and, therefore, subjectto 121.344(e). However, none
were sold for air carrier service in the United States.! Forthatreason, Bombardiernever designed a Series 300 aircraft for the 57 parameter installation required for these aircraft to be operated inthe United States. (Some Q300 aircraft were manufactured after August 19,2002, with an 88 parameter DFDR. None are at issue here.)

4. CommutAir signed a contractto acquire the two aircraft that are the subject ofthis application from TyroleanAirways earlier this year. (The second is subjectto a closing estimatedto be atthe end ofJune 2011.) The conformity inspection was commenced on the first aircraft and in May 2011 the discovery was made that the aircraft did not conform to the DFDR requirement at issue here and could not be readily upgraded to the 57 parameter DFDR required. The aircraft were operated previouslyunderEuropean standards with a DFDR recording 31 parameters. However, they could be upgraded to 34parameterinstallations in accordance with Timco STC No. STOI929AT-D. See also Exhibit 2. Thus, these two aircraft
canreadily be modifiedto conform to the standards ofall ofthe other Q300 aircraft now operating in the United States (all with 34 parameterDFDRs) and CommutAirplans to do so

! Source: Bombardier. 

## 2

### priorto operating these aircraft. Three other Q300 aircraft were acquired contemporaneously, but those aircraft were manufactured priorto August 18, 2000, and conformity to the appropriate 34 parameter standard is readily achieved through use oftheTimco STC. Thus, the 57 parameterrequirement applies to only two Q300 aircraft, the two at issue here, and Bombardier has no plans to manufacture any more Q300 aircraft.

5. All ofthe Q300 aircraft that were acquiredby CommutAir are intended to fly under contract with United Airlines, Inc., C"United") as United Express. The air service offered by CommutAir will provide unsubsidized service in small to medium sized cities throughoutthe upper Midwest andNortheastern United States to United's hubs. The serviceperformedbythe Q300 will replace flights on routes that otherwise would be uneconomical to serve using less fuel- efficient aircraft with similar seating capacity, thus affording the public in those market
areas additional airtransportation support for their local businesses.

6. Withoutthe reliefrequested here, CommutAirwill notbe able to fully implement its contract with United and those additional transportation services may not be available to those communities. By contract, CommutAiris obligatedto commence service no laterthan June 29, 2011. Thus, ourprimary request for reliefis to permitthe operation ofthose two airplanes with the 34 parameter DFDRs used by all other Q300 airplanes now inFAR 121 operation in the United States. ALTERNATE RELIEF REQUESTED

7. Ifthe FAA is notpreparedto grant the primary reliefrequested and permit thesetwo aircraft to operate with 34 parameter DFDR's, the Company will berequired to apply for a supplemental type certificate for the installation ofa 57 parameter DFDR for installation solely in two aircraft, all ofwhich will require the expenditure ofabout $500,000.00 for the two aircraft and a time period ofabout 12 months. That sum andthat effort would be a significant financial 

## 3

### burden to CommutAir, which now operates a fleet comprised ofonly 16 Q200 airplanes. If those two aircraft could not operate in revenue service during the intervening period when the STC is developed and implemented, lower revenue levels and some concomitantreductions in both service and employment must be expected. In the eventthatthe primary request for relief is denied, CommutAir asks the alternative reliefdescribed in the following paragraphs on the grounds stated.

8. CommutAirhas contracted with a designated engineering representative and certification managerto assess what mightbe required to develop such an STC? The elements ofthe STC proposed would include the same flight dataacquisitionunit (FDAU) as installed on the Q300s manufactured to accommodate 88 parameters and a newDFDRthat could accommodate the 57 parameters required. A more complete description is presented in the attached summaryprepared by the DER. Exhibit 2. Inany case, the equipment and installation would conformto all requirements ofFAR 121.344( e) inthe process ofapproval ofthe STC by the FAA.3



### 9. Ifthe preparation and implementation ofthis STC is required, thatprocess is estimated to take a minimum oftwelve months after commencement in accordance withthe schedule

2 Rick Veronan (DERT955 1 I8NE), Design Maintenance Analysis, inc., P.O. Box 570, Georgetown, DE 19947. 3 An exemption from parameters 37 (drift angle), 47 (selected barometric reading), 50 (selected Mach), and 57 (thrust command) as specified by FAR 121.344(e) and Appendix M to thatrule is not really necessary because installation ofa DFDRwith those parameters is not necessary when to do so would "require a change in installed equipment." Information sources for those parameters are not installed in the Q300 aircraft. FAR 121.344{a). Parameter42 (throttle/power lever position) is not required for aircraft like the Q300, an aircraft with mechanically linked cockpit engine controls. Parameter 43 is already present. FAR 344(e), Appendix M. Parameter41 (windshear detection) is not required since the DHC-8 as a turbo-propeller powered aircraft does not have a windshear detection system. Parameter 56 (Multi-Function Engine Alerts) is not required as the aircraft doesnot havemultifunction engine displays. Accordingly, the exemption may be limited to parameters 35 (GPWS), 36 (landing gearposition orlanding gear cockpit control selection), 38 (wind speed and direction), 39 (latitude and longitude from GPS), 40 (stick pusher and shaker activation), 44 (TeAS), 45 (DME 1and 2 distance), 46 (Nav land 2 selected frequency), 48 (selected altitude), 49 (selected speed), 51 Selected Vertical Speed, 52 (selected heading), 53 Selected Flight Path, 54 (selected decision height), and 55 (EFIS display format).


### 4

### attached as Exhibit 3. Thatis a very aggressive schedule that we are assured is possible with the cooperation ofthe relevant FAA offices.
10. No reduction in operational functionality will be experienced during the period that the exemption will be in force for those two aircraft. The aircraft will also have a fully equivalent level ofsafety to every other Q300 operating in FAR 121 revenue service in the country

- all ofwhich use 34 parameter DFDRs. Thus, this exemption will not adversely affect safety.
11. Anexemption from the parameters specified by FAR 121.344(e) numbered from 35 to 57 in, as referenced and specified in Appendix M, is requested for the duration oftheperiod of development and implementation ofan STC to the extentnecessary to permit continued operation ofaircraftN839CA and N837CA in air carrier service.

DISCUSSION

As the overview ofthe history ofthe development ofthis rule describes,4 

### the rule was not intended to force the retrofit ofaircraftthat are out ofproduction orofaircraft the number of which is "small and declining, such that any safety return from expended FDRs would be minimal." Revisions to Digital Flight DataRecorder Rules; Proposed Rule, 61 FR37144 at 37153 (July 16, 1996) (discussing the exclusion ofcertain aircraft from the rule). That consideration also rested explicitly upon the unjustified cost ofthat retrofit. Id. Moreover, it appears that anticipated retrofits focused onthe 34 parameters required for aircraft manufactured before 1991. Id., 61 FRatp. 37152. See also discussion in Exhibit 2. Accordingly, the policy ofthe rule should allow consideration ofan exemption that is applicable to the only two aircraft in this position (Le., otherwise requiredto upgrade) that will be in air carrier service inthe U.S.

4 Exhibit 2. 

## 5

### The FAAhas readily granted exemptions from FAR 121.344. Continental Airlines. Inc., Exemption No. 7323 (August 21, 2000); American Eagle Airlines, Inc., ExemptionNo. 7319 (August 18,2000);MesaAirlines, Inc., ExemptionNo. 7324 (August 21,2000); Chautauqua Airlines, Inc., ExemptionNo. 30171 (August 21, 2000); DeltaAirlines. Inc., ExemptionNo. 8709 (April 17, 2006); DeltaAirlines, Inc., ExemptionNo. 8709A (November 29,2007). Exemptions have been granted for multiple parameters, multiple airplanes, and, particularly, for the period needed to update the aircraft. This is not a case where the manufacturer had notice of
a required change inthe installation ofa DFDRand did not implement a timely design change for aircraft to be operated in the United States. No non-compliant Q300 aircraft were manufactured for air carrier service intheUnited States. They were all manufacturedto be off-shore or for private orgovernmentuse. Moreover, the FAA has recognized thatpermitting
an aircraftto be operated while upgrading the DFDRis in the public interest. "Theresult of grounding the airplanes wouldbe cancelled flights, disrupted schedules, and significant financial loss, inconvenience, and losttime costto the travelling public, withno discernable safety benefit." Delta Airlines, Exemption No. 8709, supra.

The issuance ofanexemption for eitherthe primary requested relief, which would relieve CommutAir ofan expenditure of$500,000 for an STC only applicable to two aircraft, orfor the alternative relieffor aninterim period ofone year inwhichthe airplanes could operatewhile an appropriate STC is developed, are bothin the public interest. Both would continue a comparable level ofsafety experienced by every air carriernow operating the Q300 in the United States and would notadversely affect safety.

CommutAir further requests thatthe FAAwaive publication and commentonthis petition. Good cause is shown by this petition for such action because the delay that mayresult from publication would frustrate its purposes. The need for this exemption was not apparent until 

### 6

### a conformity inspection inMay 20111 and this application is filed as soon as it could be prepared with fully descriptive data. It

### would also not set a precedent.

CONCLUSION

WHEREFORE, onthe basis ofthe foregoing, ChamplainEnterprises, Inc., d/b/a CommutAirlUnited Express, requests issuance ofan exemption from FAR 344(e), 14 C.F.R. 344(e) to the extent necessary to permit the operationofaircraft N839CA andN837CA, Bombardier Q300 series aircraft in aircarrier service, without conformity withthe parameters 35 through 57 as described inFAR 121, Appendix M either, (a) for the duration oftheir operation by the Petitioner or, (b) for a period oftwelve (12) months from issuance while an appropriate STC is developed and a DFDRthat conforms to the cited requirements is installed inthose aircraft.

# s~dr1/**f~** ames W. Tello CES OF JAMES W. TELLO 1025 Connecticut Avenue, NW Suite 1000 Washington, DC 20036

Phone: 202-399-1918 E-Mail: jamestello@earthlink.net Counsel for CHAMPLAIN ENTERPRISES, INC. d/b/a COMMUTAIRIUNITED EXPRESS June 8, 2011



## 7

# EXHIBIT 1FEDERAL REGISTER SUMMARY

Champlain Enterprises, Inc., d/b/a CommutAir/United Express ("Petitioner'), requests issuance ofan exemption from FAR 344(e), 14C.F.R. 344(e) to the extent necessary to permit the operation ofaircraft N839CA and N837CA, Bombardier Q300 series aircraft in air carrier service, without conformitywith the parameters 35 through 57 as described in FAR 121, Appendix M either, (a) forthe duration oftheir operation by the Petitioneror, (b) for a period oftwelve (12) monthsfrom issuance while an appropriate STC is developed and a DFDR that conforms to the cited requirements is installed in those aircraft.

# EXHIBIT 2

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 

### 19947 June 7, 2011 James W. Tello Law Offices ofJames W. Tello 

### 1025 Connecticut Avenue, NW Suite 1000 Washington, DC 20036 

### Dear Mr. Tello: Enclosed is a brief history of FAR 121.344 and the Timco alteration to result in compliance to FAR 121.344(d). Some ofthe information is based on my participation ofthe Aviation Rulemaking Advisory Committee assembled to assist in the development ofthe rule, while other information is public record. Additionally there is a description ofthe physical changes required to the DHC-8-311 aircraft under contract to CommutAir in orderto comply with FAR 121.344(e). The current operating rule, FAR 121.344, on flight data recorders for US scheduled airlines is the result ofan Aviation Rulemaking Advisory Committee (ARAC) assembled in the late 1990's. This committee included personnel from the National Transportation Safety Board (NTSB) the FAA, aircraft manufacturers and airline operators representing the AirTransport Association (ATA) and the Regional Airline Association (RAA). I participated on theARAC as a representative ofthe RAA. Accordingly this is a first person history. The goal ofthis group was to develop a requirement to upgrade flight data recorder systems on all aircraft thatwere currently being produced or thatwere in Part 121 service in significant numbers. The result of this upgrade would be that except for a small number ofaircraft operated in very small numbers all aircraft would have a minimum standard thatwould include the position ofthe flight control and the pOSition ofthe flight control surface. The actual number of parameters that would be required varied depending on the architecture ofthe original flight data recording system. The intent was to reach a minimum standard within the capacity ofthe existing recorder architecture, yet use all existing capacity according to a standard developed by the NTSB. The final number of parameters required ranged from 18 parameters for aircraft without a Flight Data Acquisition Unit (FDAU) to up to 34 parameters for more current aircraft. The rule recognized the difficulty in developing a retrofit system that would record more than 34 parameters so the rule as written did not intend to require any retrofit beyond the 34 parameter system. To support the conclusion thatthe neitherthe FAA northe ARAC intended for retrofitsto require more than the initial 34 parameters I have provided the following excerpt from the Revisions to Digital Flight Data Recorder Rules: Proposed Rule, 61 FR 37144 at 37153 (July 16, 1996), addressing the potential rule change. I have made a portion ofthe excerpt bold for amplification. Taking into account the NTSB concern that all new airplanes be able to record the maximum number ofparameters, balanced against the knowledgethat airplanes in production carmotbe re-engineered without sufficient lead time, the FAAhas determined thatFDR requirements for future airplane production will be based on the date ofmanufacture, but that the dates suggested by the NTSB cannot realistically be met without incurring overwhelming costs and unacceptable delays in production. Accordingly, the proposed rule would place the following requirements onnewly manufactured airplanes. The first group ofairplanes, addressed in proposed § 121.344(d)(I), are those manufactured after October II, 1991,

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 19947 but on orbefore [insert date three years from effective date, i.e. 2000) to record the parameters listed in paragraphs (a)(l)through (a)(34), and do so in accordance with Appendix M. Similarto the requirements for olderairplanes, the parameters listed in paragraphs (a)(12) through (a)(l4) could be recorded from a single source. Proposed § 121.344(d)(2) carries forward the requirementsthatall additional parametersthatare within the capacity ofthe recording system must also be installed to take advantage ofthe latest advancements in technology and the capabilities ofindividual airplanes. Because this requirementwill applyto airplanes recently produced, itis a retrofitrequirement, butthe effect ofthe retrofitis softened by limiting the requirementto the first 34 parameters.
The ARAC, the NTSB and the FAA also considered the cost benefit ofaircraft that were not in production. While at that time the DHC-8 Series 300 was in production, Bombardier no longer actively produces this model. An additional excerpt from the same Federal Register publication shows the following. Paragraph (1)(2) lists those airplanes that are out ofproduction. After considering analysis ofdatapresented by aircraft operators and manufacturers, the ARAC working group determined thattheremainingeconomic life ofthese airplanes is insufficient to justifythe cost associated with extensive DFDRretrofit. Further,the number ofthese airplanes in operation is sufficiently small and is declining, such that any safety return from expanded FDR's would be minimal. The rule was never intended to require a significant retrofit to only two aircraft, particularly when there are limited numbers ofaircraft to benefit from any possible accumulated data. Beyond the requirements for addressing the existing fleet, the group prescribed standards to be met by aircraftto be manufactured in thefuture, since future aircraft were not constrained by existing system architecture. These requirements were for recorder systems to record 57 parameters on a datethree years after the effective date ofthe rule and for them to record 88 parameters five years afterthe effective date ofthe rule. In order to comply with the rule, all Part 121 operators of DHC-8 aircraft formed a group and developed a means ofcompliance and submitted itto various alteration agencies for proposals. Timco was awarded the contract. There weretwo versions ofalterations developed by Timco. One modification addressed older DHC-8 Aircraftthat had been recording 17 parameters and a second STC ST01929AT-D, was developed for newer DHC-8 aircraftthat were recording 31 parameters. This second STC added sensors and changed FDAU software to add the parameters of Roll, Pitch and Yaw control input positions. All DHC-8 Series 100 and 300 aircraft in Part 121 operations in the United States have flight recorder systems upgraded by one ofthese two STCs. It should be noted that these STCs were not issued until nearlytwo years after the effective date ofthe rule, even though the operators had been actively engaged in compliance plans prior to the final rule. The aircraft acquired by CommutAir were previously operating in Europe and were not required to meet the requirements of FAR 121.344. They currently comply with FAR 121.343 (f). These aircraft can be upgraded to a 34 parameter system by accomplishingTIMCO STC ST01929AT-D. This would result in compliance to FAR 121.344(d) by installing sensors for the roll, pitch and yaw control positions and a discrete sensor for control column separation. However, there is currently no existing retrofit available to upgrade this aircraftfor compliance tothe 57 parameter system required by FAR 121.344(e). Bombardier has never developed a recorder system for a 57 parameter flight recorder system for any model ofthe DHC-8. Bombardier has developed a system for recording 88 parameters on late model DHC-8 aircraft. This modification installs a 256 word per second flight data recorder (FOR) in lieu ofthe 64 word per second recorder found on the earlier aircraft. A new model PN 2244000-511 FDAU capable ofthe increased number of parameters is installed. These newer aircraft have the additional sensors

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 19947 installed and additional wire harnesses fortransmitting data from the new sensors and from other data sources to the FDAU and to the FOR. The wiring forthese changes was initiated in production approximately at production serial number 595. However, there were aircraft produced well after this point that did not have the sensors installed or the new FDAU and FOR. Bombardier has provided service bulletins 8-31-24 and 8-31-25 to install the new sensors, OFAU and FOR's on two aircraft serial numbers 619 and 635. These aircraft were required to have the additional parameters by the Japanese Civil Aviation Bureau (JCAB). This is the only known retrofit ofaircraft with an older 31 parameter system to a system capable ofcompliance to FAR 121.344{e). While these service bulletins provide a system more capable and complex than that required by FAR 121.344(e), adapting this data provides the most expedient method ofcompliance. However, these bulletins addressed aircraft with aircraft wiring developed forthe additional parameters already installed. While this Ifcompliance to FAR 121.344(e) is required for aircraft Serial Numbers 553 and 554 the following changes to the aircraft must be developed by CommutAir and approved by the FAA. Replacing the existing 64 word per second recorder with a 256 word per second recorder. Replacing the existing FOAU with a Part Number 2244000-511 FOAU. Installing two each sensors one at each end ofthe elevator layshaft under the flight deckfloor. Installing two sensors, one on each roll control sprocket under the flight deck floor. Installing one sensor on the rudder quadrant under theflight deck floor As previously stated Service Bulletins 8-31-24-and 8-31-25 provide data that may be available for accomplishing some or all ofthe above steps. This data may be able to be adapted and reduce the time required to develop a retrofit. FAA approval would still be required, since the Service Bulletins are not being accomplished as written. The service bulletins assumed the aircraft already had the advanced wiring to support these installations. This wiring would have to be developed to retrofit an older aircraft. Additionally the wire harnesses and wire routing would have to be developed to support a retrofit application rather than a production installation as often production wire routing is cannot be duplicated once the aircraft is built. In addition tothe above sensors wiring must be installed between the existing Flight Management System (FMS) and the FDAU. This will allow recording ofthe latitude and longitude, wind speed and wind direction and ground speed. The service bulletin data includes wiring and sensors for many additional parameters beyond the 57 required by FAR 121.344(e). It is recommended thatthese be installed only ifnecessary for operation of the FOAU to Simplify data development and reduce retrofit complexity. As stated earlier, this system was never intended to be installed as a retrofit on aircraft notfactory provisioned. I have outlined atime table for accomplishment ofthe retrofit upgrade to the 57 parameter system, but it is avery aggressive schedule. This is enclosed with this letter. The original STC to go from 31 to 34 parameters did not require atotal replacement ofthe FOAU, but only an upgrade, yet it took nearly 2 years. Additionally the cost to develop the data was spread out over all OHC-8 aircraft in operation at thattime, rather than the two aircraft involved in the current project.

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 19947

I hope this assists you in developing a course ofaction for CommutAir. Ifyou have any additional questions, please contact me. Regards,

R. W. Veronen President DMA Inc.

CC: James Page CommutAir Joel Raymond CommutAir Enclosed: Timeline

# EXHIBIT 3

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 19947 TIMETABLE FOR SUPPLEMENTALTYPE CERTIFICATE FOR Q300 AIRCRAFT WITH 57 PARAMETER DIGITAL FLIGHT DATA RECORDER Explanation oftable: Items with bold italics are critical path items. Predecessors are noted. For example, obtaining FAA approval ofthe Certification Plan (PSCP) normallywould precede issuing requests for conformity (RFCs).

I Research on Best This step is collapsed since the choice ofthe No additional time expended

approach Bombardier system has been made. Develop Project Four weeks after program launch 

### i Specific Certification

Plan (PSCP) Submit STC Application form 8110-12 • Obtain Project Typically 30 days after submittal I Notification Letter ofapplication.

PNL Obtain approval on 

### This is normallyrequiredpriortoany Typicallyfaurtosixmonths PSCP from FAA 

### requestsfor conformity(RFCs). aftersubmittalof pSCP. Procure FDAU for Assume 30 days to coordinate with Teledyne 150 days after start Project and Bombardier on dash number and procurement details. I Purchase sensors 180 days after start I and other Line i replaceable units I LRUs

Developwiring This assumes we can find a team with 

### 180days afterstart diagrams and immediate availabilityfor data development. drawings We will need to prioritize items and will take time for manufacture and getthose drawings I released first.

Develop Kits and Can start manufacturing long lead items after 

### Can Finish within 90

### days of manufacture parts those specific drawings are complete. 

### drawing release. 270days not procured in 

### i Ifwork is accomplished at CommutAir, the 

### elapsedafterstart. i steps above applicant will have to appoint a CommutAir person to act as an agent in completing 8130-9 tags • Obtain FAA approval 2 weeks afterdrawing release

· of manufacturing I drawings

Conform Parts and 

### 2 weeksafterkits arecompleted I kits 

### 284elapsed daysfrom start.

Develop Instructions These must be submitted to the FAA at least 60 days after drawing release for continued 30 days priorto STC issuance. 60 days is airworthiness ICAs much safer. I

# DMA INC POST OFFICE 

### Box 570 GEORGETOWN 

### DE 19947 Installation of kits Allowthree weeks forfirst aircraft as the installation is subject to conformity. Ifwork is accomplished at CommutAir, the applicant will have to appoint a CommutAir person to act as an agent in completing 8130-9 tags. 

### 3 weeksafterkits are conformed. 315

### totaldays elapsed.

Installation Conformity 

### 7days afterinstallation is complete. 322

### totaldays elapsed. Ground test 

### 7days afterinstallconformity. 329 totaldays elapsed. Prepare final reports for submittal 

### 6daysaftergroundtest. 335 totaldays elapsed. STC issuance This is a normal quickturn forthe FAA. 

### 3 weeksafter final report submittal. 356

### totaldays elapsed.