Petition for Exemption – §135.156 (d) (4) Page 1 of 4 

Executive Jet Management, Inc. 

  

December 20, 2013

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12‐140

Washington, DC 20590

PETITION FOR EXEMPTION

Dear Sir or Madam:

In accordance with the requirements of 14 CFR §11.81(a)‐(g), Executive Jet Management, Inc. (EJM), Air 

Carrier Certificate Number CWQA061D, is requesting a temporary exemption for 1 airplane from the

requirements of §135.156 (d) (4), for a period of 18 months.     14 CFR 11.81 (b)

§135.156 Flight data recorders: filtered data

(d) Compliance. Compliance is required as follows:

(4) After April 21, 2014, no aircraft flight data recording system may filter any parameter listed

in paragraph (c) of this section that does not meet the requirements of Appendix D or F of this

part, unless the certificate holder possesses test and analysis procedures and the test results that

have been approved by the FAA. All records of tests, analysis and procedures used to comply

with this section must be maintained as part of the correlation documentation required by §

135.152 (f)(1)(iii) or (f)(2)(iii) of this part as applicable.

The primary contacts in this matter are:      14 CFR 11.81 (a)

Chris Poliak, Director of Maintenance

Executive Jet Management, Inc.

4556 Airport Road

Cincinnati, OH  45226

513.979.6671

cpoliak@ejmjets.com  

   

Regulatory Docket Number: FAA-2013-__________ 
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Petition for Exemption – §135.156 (d) (4) Page 3 of 4 

Executive Jet Management, Inc. 

TEMPORARY RELIEF REQUESTED:

Several aircraft in the EJM fleet were identified as requiring the upgraded avionics load.  EJM is planning

to obtain the required upgrades for all of the affected aircraft by the April 21, 2014 deadline with the

exception of the N265H.   Due to service and supply chain limitations and delay, this aircraft’s “EASY II”

avionics upgrade is planned for September of 2014; the soonest available schedule opening.  In order to

allow for potential uncontrollable slip due to procurement or engineering challenges, we request that

the temporary exemption period be granted for 18 months.1

PUBLIC INTEREST AND BENEFIT     14 CFR 11.81(d)

Executive Jet Management, Inc. (EJM) is a Part 135 Air Carrier certificated in accordance with 14 CFR

119.  EJM operated aircraft, to include N265H, are offered for charter services to the public.  EJM charter

clientele are primarily business leaders that find it necessary to charter an aircraft in order to maximize

their time and availability to operate their business.  Chartered aircraft allow business executives and

key personnel the flexibility to quickly react and meet obligations to advance their business, thereby

strengthening the company’s position and help to provide a stable job market, which in turn strengthens

the US economy.  Considering that a temporary exemption to allow operations with filtered parameters

has no direct impact on the safety of that individual aircraft, denial of service to these business leaders

to quickly react, grow their companies and provide much needed jobs, would be an undue burden on

the public as a whole.

EQUIVALENT SAFETY     14 CFR 11.81(e)

Only 4 out of the 8 parameters required by 14 CFR part 135.156 are temporarily filtered:  The recording

of pitch control surface position (parameter 15), lateral control surface position (parameter 16), yaw

control surface position (parameter 17) and cockpit flight control input forces (parameter 88);     

EJM recognizes the contribution of flight data recorders to accident and incident investigations, and

ultimately to the safety of the design and operation of aircraft.  However, this temporary configuration

has no direct safety impact for this individual aircraft.  Granting this temporary exemption would not

affect nor degrade the inherent safety of the airplane.  

FEDERAL REGISTER SUMMARY AND PUBLICATION      14 CFR 11.81(f)

(1) Petition for exemption to regulation: 14 CFR §135.156(d)(4)   

(2) Summary of Relief Sought: Executive Jet Management, Inc. seeks an exemption from section 14

CFR part 135.156 (d) (4) to allow N265H, Dassault Falcon 900EX EASy, serial number 139 to

operate with filtered data for a period of 18 months, effective April, 21, 2014.

   

 

1 The FAA has issued temporary exemption grants many circumstances similar in material respects to those presented in this

petition.  Reference Docket numbers 2011‐1185, Ryan International Airlines, 2011‐0620 CommutAir, 2011‐0188 American

Airlines, 2011‐0145 UPS, 2011‐0002 Alaska Airlines
Petition for Exe

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