22 November 2013

US Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.

WASHINGTON, D.C. 20590 USA

Please contact:

Greg Paxson

Director of Maintenance

TWC Aviation, Inc

16700C Roscoe Blve.

Van Nuys, CA 91406

O 818.815.3136

C 805.501.5408

gpaxson@twcaviation.com

SUBJECT: Dassault Falcon 2000EX Easy, N57AL (S/N: 055)

Dassault Falcon 2000LX, N157AL (S/N: 110)

Dassault Falcon 2000LX N257AL (S/N: 151)

Dassault Falcon 2000LX, N741SP (S/N: 207)

- Petition for Exemption Applicable to: Flight data recorders: filtered data Regulation

Reference: Docket No FAA-2006-26135- Flight data recorders: filtered data Regulation, Final Rule

Dear Sir or Madam:

In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) §11.61, TWC

Aviation, Inc, for Dassault Falcon 2000EX Easy, N57AL (S/N: 055); Dassault Falcon 2000LX, N157AL

(S/N: 110); Dassault Falcon 2000LX N257AL (S/N: 151); Dassault Falcon 2000LX, N741SP (S/N: 207),

we submit a petition for an exemption from a section of 14 CFR Part 135.156.

Should you have any question, please do not hesitate to contact us at the following address:

Greg Paxson

Director of Maintenance

TWC Aviation, Inc

16700C Roscoe Blve.

Van Nuys, CA 91406

O 818.815.3136

C 805.501.5408

gpaxson@twcaviation.com
Petition For Exemption

In accordance with the requirements of 14 CFR §11.81(a)-(g), we provide the following detailed

information in support of our petition:

14 CFR 11.81(a) - Contact information:

Greg Paxson

Director of Maintenance

TWC Aviation, Inc

16700C Roscoe Blve.

Van Nuys, CA 91406

O 818.815.3136

C 805.501.5408

gpaxson@twcaviation.com

14 CFR 11.81(b) - Specific section from which relief is sought:

For Dassault Falcon 2000EX Easy, N57AL (S/N: 055); Dassault Falcon 2000LX, N157AL (S/N: 110);

Dassault Falcon 2000LX N257AL (S/N: 151); Dassault Falcon 2000LX, N741SP (S/N: 207), we request

relief from the following portion of 14 CFR:

§135.156, Amdt 135-120, 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.

14 CFR 11.81(c) - Extent and reason for seeking relief:

For Dassault Falcon 2000EX Easy, N57AL (S/N: 055); Dassault Falcon 2000LX, N157AL (S/N: 110);

Dassault Falcon 2000LX N257AL (S/N: 151); Dassault Falcon 2000LX, N741SP (S/N: 207), we are

requesting an exemption from compliance with the above listed portion of the flight data recorders.

Compliance with the regulations requires retrofit with EASy II upgraded avionics Load. Considering the

large amount of Falcon aircraft being retrofitted with EASy II upgraded avionics, there is a significant

waiting time before being accepted in a Service Center for retrofit. The amount of aircraft retrofitted

monthly is limited worldwide, by the large amount of equipments to supply. Finally, this retrofit requires a

significant downtime to adapt to scheduled maintenance checks in a way to maintain reasonable

operational use of our aircraft. After review, we plan to retrofit our aircraft with EASY II upgraded

avionics and have been given the following date by Honeywell (the manufacturer of the upgraded

avionics) N257AL - July 2014, N157AL - September 2014, N57AL - October 2014 and N741SP -

January 2015.

14 CFR 11.81(d) - Public interest / benefit:

TWC Aviation is a Part 135 Air Carrier certificated in accordance with 14 CFR 135. TWC Aviation’s

Falcon 2000 aircraft are offered for charter services to the public. TWC Aviation’s 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."

For the period in which the exemption would be in effect, there would not be any safety degradation.

14 CFR 11.81(e) - Information supporting this petition:

This petition for exemption is related to the Flight Data recorder: data filtering to be removed, as

mandated by 14 CFR §§135.156 Amendment 135-120. This exemption, if granted, would allow us to

benefit from the commercial use of Dassault Falcon 2000EX Easy, N57AL (S/N: 055); Dassault Falcon

2000LX, N157AL (S/N: 110); Dassault Falcon 2000LX N257AL (S/N: 151); Dassault Falcon 2000LX,

N741SP (S/N: 207) between April, 21, 2014 and the retrofit dates noted above.

If this petition is denied, then commercial flight operations of Dassault Falcon 2000EX Easy, N57AL

(S/N: 055); Dassault Falcon 2000LX, N157AL (S/N: 110); Dassault Falcon 2000LX N257AL (S/N: 151);

Dassault Falcon 2000LX, N741SP (S/N: 207)will have to be interrupted until EASy II upgraded avionics

retrofit is applied.

Granting this exemption would not affect nor degrade the inherent safety of the airplane. This

exemption deals only with 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); it therefore has no impact on operational safety.

14 CFR 11.81(f) - Federal Register summary:

Petitioner: TWC Aviation, Inc.

Affected Regulations: 14 CFR §135.156(d)(4), Amdt 135-120.

Summary of Relief Sought: TWC Aviation, Inc., seek exemption from section 14 CFR part 135.156 to

allow Dassault Falcon 2000EX Easy, N57AL (S/N: 055); Dassault Falcon 2000LX, N157AL (S/N: 110);

Dassault Falcon 2000LX N257AL (S/N: 151); Dassault Falcon 2000LX, N741SP (S/N: 207) to operate

with filtered data from April, 21, 2014 to the dates of retrofit noted above.

14 CFR 11.81(g) - Additional information:

Granting this petition would have no effect on the regulatory burden of small businesses, small

organizations, small governmental jurisdictions.

Granting of this petition would have no effect on the recordkeeping and reporting burdens for any

involved parties.