pp, 

•V.T\t 

, 'ARTMENT OF 

NSPORTATION 

•^T OPERATIONS The Avsaurce Groups 

WORLDWIDEAVIATIOI^SERVICES " ^ ^'^^ 3 ' A 10 21 

8901 US Highway 6 Parachute, CO 81635-9730 USA 

Phone (970) 285-1002 1-800-684-1002 Fax (970) 285-1003 

26 August 2010 

U.S. Department of Transportation Fi^A -2oio - oS«»o 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 N«v Jers^Awnue, SE 

Washington, DC 20590 

Subject: PETITION FOR RULEMAKING 

AMENDMENT TO TITLE 14 CFR PART 21.197(aX5) 

Explanation: There is currently no provision authorizing the issuance of a special flight permit for the 

purpose of customer demonstration flights on used aircraft. The subject rule only 

provides for customer demonstration flights on new production ah'craft. 

Proposed Action: This petition proposes that Title 14 CFR Part 21.197(aX5) be amended to include "•used 

aircraft." TTie FAA has the responsibility to "foster and promote" aviation. This 

proposed amendment, if implemented, will help promote aviation. 

Proposed Language: 21.197 (a) A special flight permit may be issued for an aircraft that may not 

currently meet applicable airworthiness requirements but is capable of safe 

flight, for the following purposes: (5) Conducting customer demonstration 

flights in used aircraft or new production aircraft that have satisfactorily 

completed production flight tests. 

Public Interest: It is standard practice in the air transport industry for purchase and/or lease agreements to 

include a two-hour demonstration flight prior to purchase, lease, or lease return of a used 

aircraft. The current rule only provides for customer demonstration flights on new 

pro<^ti^affrai^ Hus^ascaused^umamis^pHtbkms for banks and leasing 

companies when trying to remaricet tbdr used aircrcfi. It is also a problem for ttae 

customers if they are unable to witness a demonstration flight prior to a purchase or lease 

or lease return of a used aircraft. If one were buying a used car, it is standard practice 

and common sense to personally witness the operation of the vehicle before the purchase. 

It is probably more important to do this on a used vehicle than on a brand new vehicle 

because of the wear and tear that normally occurs over time. 

Supporting Data: Here is a hypothetical example. A leasing company has several used aircraft in storage 

in the U.S. They wish to remarket the used aircraft by obtaining a special flight permit 

and conducting a customer demonstration flight. The leasmg company needs this rule 

amended to include '''^used aircraft'' for purposes of customer demonstration flight/s or 

they risk losing the sale or lease. The customer does not want to invest in a multi-million 

dollar asset Avithout first witnessing a demonstration flight, and e^>ecia]ly because it is a 

used aircraft. Although this is a hypothetical example, this scenario happens on a daily 

basis in the real world. 
Specific Supporting Facts: The current rule only provides for customer demonstration flints on new 

production aircraft. 

There is currently no provision authorizing the issuance of a special flight 

permit for the purpose of customer demonstration flights on used aircraft. 

The customer does not want to invest in a multi-million dollar asset without 

first witnessing a demonstration flight, and especially because it is a used 

aircraft. 

The current rule is a hindrance to the business opportunities for the remarketing 

of used aircraft. 

For further information or clarification, please contact me by phone or email. 

Respectfully, 

'^^g.,^:^^ 

Gary R. Loyd 

DART505005NM (SLC-FSDO-NM) 

garvrlovd(S)avsource.com 

+1-719-331-2169 mobile 

cc: Robert Lesitsky, Aviation Safety Inspector, SLC FSDO