Jet Select, LLC 

4130 East Fifth Avenue 

Columbus, Ohio 43219 

bbroom@jetselectaviation.com 

US Department of Transportation 

1200 New Jersey Ave. SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Submitted via: www.regulations.gov 

Subject: Request for Temporary Exemption to CFR 135.152 Parameter 5 "Normal 

Acceleration" 

Dear Sir or Madam, 

It was brought to the attention of Jet Select, LLC, Air Carrier Certificate Number 

U5QA550L, by Bombardier Aerospace (BA) that certain Digital Flight Data Recorder 

(DFDR) systems certified and installed by BA on certain aircraft are not recording a 

specific parameter listed in 14 CFR 135 Appendix F- "Airplane Flight Recorder 

Specification" to the full stated specifications listed for this specified parameter. 

Therefore, in anticipation of suitable rectification by BA, Jet Select, LLC is requesting 

exemption from the requirements of 14 CFR 135 Appendix F - "Airplane Flight Recorder 

Specification", specifically "5. Normal Acceleration (Vertical)" only. This request applies 

to Bombardier Challenger CL-600-2B 16 (CL-604 Variant) manufactured after August 

18, 2000 and with a DFDR system installed per Bombardier Aerospace SB604-31-010 

operating under 14 CFR 135 by Jet Select, LLC domestically and abroad, currently 2 

affected aircraft (N529KF, 5477; N604MC, 5581 ). 
In accordance with 14 CFR 11, Jet Select, LLC requests an exemption from the "5. 

Normal Acceleration (Vertical)" parameter requirements in Appendix F of 14 CFR 

135.152 to permit sampling 5 times (0.2 seconds per sampling interval) per second until 

the Data Concentrator Unit (DCU), a subsystem of the affected DFDR system, is 

updated to provide 8 times per second (0.125 seconds per sampling interval) per 

second. 

An exemption will have no adverse impact on the safe operation of the aircraft. 

The DFDR and its recorded parameters are not required for the safe operation of the 

aircraft. The DFDR's primary purpose is to support investigations in case of accidents. 

The affected Normal Acceleration parameter is provided through the DCU. Jet Select, 

LLC's CL604 variant aircraft has/have 2 DCUs. Except for the affected Normal 

Acceleration sampling rate, all data is being collected as required by 14 CFR 135 

Appendix F (e.g. range -3g to +6g, resolution 0.004). The effect is that the normal 

acceleration parameter can be correlated to the appropriate recording rate, as 

described and illustrated below, with no substantive loss of information. 

--glto•<tHcl•.•ol 

- p,Suloullll•••l 

Given that the information can be effectively correlated with no substantive degradation 

in information, we respectfully submit that this compliance issue does not affect the safe 
availability and all affected operators downtime requirements, for a complete retrofit 

within two (2) years of the grant of the exemption. Jet Select, LLC is committed to 

working with Bombardier Aerospace to effect the final rectification to this issue 

concerning our affected aircraft as soon as practical. 

In many cases our affected aircraft are outside the United States for an extended 

period. The public benefit and equivalent level of safety addressed below supporting 

this exemption request have equal applicability to Jet Select, LLC's international flights. 

The exemption is in the public interest 

The problem identified above was found by the aircraft manufacturer (Bombardier), and 

is a systems design problem which CL604 operators have no way to correct at this time. 

Granting this time limited exemption would be in the public interest because it would 

allow U.S. Part 135 operators the ability to continue to provide the unique services that 

support US public, business and industrial leaders while the aircraft manufacturer 

develops and certifies, and the affected CL604 operators incorporate, the modifications 

necessary to bring these aircraft into compliance. This request is substantially similar to 

the Exemption No. 11052 granted to Jet Solutions. L.L.C. in FAA Docket No. 2014-0542 

on September 11, 2014. 

Conditions and Implementation 

Jet Select, LLC requests that the FAA allows continued operation of our aircraft subject 

to the conditions specified below: 

1. This exemption is valid until the incorporation of the modification correcting the 

deficiency described herein or 24 months from the date of this exemption, 

whichever occurs first, unless previously superseded, rescinded or terminated by 

action of Jet Select, LLC 

2. Copies of this exemption to be retained by Jet Select, LLC, and the requirement 

that a copy be provided to the NTSB and FAA in connection with any accident or 

incident where DFDR data is requested or required to be provided; and 

3. Within 90 days of receipt of the Bombardier Aerospace Service Bulletin that 

rectifies the Normal Acceleration parameter issue; Jet Select, LLC must provide a 

1 As indicated by Bombardier and based on the following: "The development schedule takes into account 

current Bombardier and its suppliers resource capacities. The FAA is involved in some of the joint projects, 

including but not limited to the Challenger Avionics upgrade as well as Steep Approach certification and 
Federal Register Summary and Publication 

Jet Select, LLC, Air Carrier Certificate number U5QA550L, is requesting exemption 

from the requirements of 14 CFR Appendix F of 135.152 to permit the sampling rate of 

5 times (0.2 seconds per sampling interval) per second2 until Bombardier Aerospace 

issues a Service Bulletin that corrects the issue, and in accordance with the conditions 

specified in this exemption request. 

This applies to all its CL604 aircraft used in operations under 14 CFR 135. Jet Select, 

LLC also requests to utilize the exemption outside the United States. It is Jet Select, 

LLC's position that safety would not be jeopardized by issuance of this exemption as 

the DFDR is used solely as a recording device in accidents and incidents and the 

affected parameter will still provide useful data in such cases. This exemption will 

benefit the public by allowing U.S. Part 135 operators the ability to continue to provide 

the unique services that support US public, business and industrial leaders while the 

aircraft manufacturer develops and certifies, and the affected CL604 operators 

incorporate, the modifications necessary to bring these aircraft into compliance. 

Due to the immediate and future impact and because this request does not establish 

new agency precedent as it is consistent with the scope of Exemption 11052, Jet 

Select, LLC requests a waiver to the 120 day filing requirements and the publishing of a 

summary of the petition in the Federal Register. 

If there are any questions, please do not hesitate to contact this office at any time. 

Thank you, 

2 Bombardier Aerospace tests and examination have shown that affected aircraft are sampling the "Normal 

Acceleration" parameter at this rate.