PLANE ANTENNAS & SEcuRITY SrsTEMS Robert Wagner 

Vice President 

3020 Rockbridge Rd 

McGregor TX, 76657 

P-13-00001 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Avenue, S.E. 

Room W12-140, West Bldg. Ground Floor 

Washington, DC 20590-0001 

Subject: 

Modei: 

Request the existing 12 month exemption from 

25.571 related to "Normal Flight Envelope" for 

Birdstrike be revised to a 24 month exemption 737-

900 

FAA Project No.: ST09645SC-T 

Reference( s ): N/A 

Special Instructions: N/A · 

This letter submits: 

(X) Request for Exemption 

This letter is sent for: 

(X) Review and Approval 

As one of the large antenna installation projects that is currently on a 12 month 

exemption being based on previously approved aircraft, Plane Antennas and Security 

Systems Inc (P.A.S.S.) respectfully requests that the public comment period be waved. 

Please contact me if you have further questions: 

Sincerely, 

Robert Wagner 

(812) 204-4616 

Enclosure: Petition for Exemption from 14 CFR25.571(e)(1) at Amendment 25-132 

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A. Name and Address of the Petitioner 

Robert W agnei 

3020 Rockbridge Rd 

McGregor TX 76657 

B. Section of the Code of Federal Regulations (CFRs) that are Affected 

As provided for in §11.61(b), Boeing hereby petitions for exemption from the following 14 

CFR for the model 737-900: 

Regulation I Amendment Requirement 

25.571(e)(l) 25-132 the airplane is capable of successfully completing 

a flight following the impact with a 4---pound bird 

when the velocity of the airplane relative to the 

bird along the airplane's flight path is equal to Vc 

I at sea level or .85Vc at 8,000 feet, whichever is I 

more critical. However, this requirement need I I not be considered if it can be demonstrated that 

1 I a bird cannot strike the radome within the normal I flight envelope up to the design speeds required I 

by § 25.571(e)(l). I 

C. The Extent of Relief Being Sought 

Regulation Requirement Why reliefis necessary 

25.571 Per the federal regulation 91,117(a) aircraft are not to fly 

(e)(l) beyond 250 knots at an altitude below 10,000 feet and 

this project expected to use the "normal flight envelope" 

enlisting the 250 knot limit. It has recently been clarified 

by the FAA that the cruise velocity should be used for 

the normal flight envelope when looking at the potential 

for bird strike. This clarification takes the radome from a 

worst case condition where the aircraft would fly with a 

nose up attitude, thereby shielding the radome from a 

bird strike, to a 0 degree alpha in which the radome and 

antenna would be exposed to the bird. This antenna and 

radome are scheduled to be completed by the end of 

May, 2013, and therefore may not have the changes 

required to satisfy the bird strike 

The proposed configuration will therefore not comply 

with the requirement of 14 CFR 25.571(e)(l). 
C. The Extent of Relief Being Sough 

Regulation Requirement Why relief is necessary 

DescriQtion of relief sought: P.A.S.S respectfully 

requests that the FAA grant a 24 month exemption for 

the bird strike clarification to ensure P.A.S.S has time to 

continue to work toward compliance with the regulation. 

This time period also allows the aircraft to return to the 

United States for routine scheduled maintenance at 

which time any modifications needed will be 

accomplished. 

D. Description of the Issue 

14CFR 25.571(e)(l) states "The airplane must be capable of successfully completing a flight 

during which likely structural damage occurs as a result of-

(1) Impact with a 4-pound bird when the velocity of the airplane relative to the bird along the 

airplane's flight path is equal to Vc at sea level or 0.85Vc at 8,000 feet, whichever is more 

critical" 

The original FAA issue paper template stated the following: 

"To meet this requirement, the applicant must show that a bird strike of the radome will not 

result in a catastrophic condition. However, this requirement need not be considered if it can 

be demonstrated that a bird cannot strike the radome within the normal flight envelope." 

14 CFR 91.117(a) states "no person may operate an aircraft below 10,000 feet MSL at an 

indicated airspeed of mote than 250 knots (288 m.p.h.)." 

Therefore 250 knots was used to generate a "normal flight envelope" which resulted in a nose 

up attitude sufficient to ensure the bird could not strike the radome. 

Recently the FAA became aware of the industry interpretation and notified this applicant of 

the clarification on the issue paper that requires the "normal flight envelope" consider 

velocities up to V c. 
D. Description of the Issue 

The revised issue paper template now states the following: 

"The applicant must show that the airplane is capable of successfully completing a flight 

following the impact with a 4-pound bird when the velocity of the airplane relative to the 

bird along the airplane's flight path is equal to Vc at sea level or .85Vc at 8,000 feet, 

whichever is more critical. However, this requirement need not be considered if it can be 

demonstrated that a bird cannot strike the radome within the normal flight envelope up to 

the design speeds required by § 25.57l(e)(l). The applicant must consider all phases of 

climb-out, cruise, descent and approach, from sea level to 8000 ft, at the full range of 

certified design weights and CG limits. 

Section 91.117 is not applicable to the bird strike requirement of§ 25.571 (e)(!), and may 

not be used as a means of altering the requirement of§ 25.571(e)(1)." 

At cruise velocity the aircraft will be flying at a zero degree angle of attack and 

therefore not shield the radome from a bird strike. P.A.S.S. is working diligently With 

Delta G Design to provide design changes to ensure the regulation is met 

The notification of this change to the issue paper was provided on March 4th , 2014, 

The current exemption ends on 7/2/2014. This may not allow time for the 

applicant to institute changes to the design that can be instituted prior to the 

expected certification date. Therefore P.A.S.S. respectfully requests the exemption 

be extended from 12 months to 24 months. 

E. Statement of Public Interest 

Timely completion of the STC ensured delivery of a head of state aircraft to the 

nation of Kuwait and maintained harmonious relations, and have a positive impact on 

the trade balance with this nation thereby enhancing the social balance, the gross 

domestic product, and the economic health of the United States. 

Granting of this revisions to existing petitions/exemptions serves the public interest by 

ensuring continued sales within the United States for this nations aircraft as well as the 

modifications performed after the initial sale. 

This serves the public interest by serving economic interests of the United States in general, 

and welfare of residents, employment and improved tax revenues. 
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F. Statement of No Adverse EffeCt on Safety 

The current design wiH have no adverse effect on safety and is designed to the same standaras a& 

previously certified antennas. At the FAA regulated speed of 250 knots, the antenna can not be hit 

with a bird due to the nose up attitude of the aircraft and will pose no additional risk. 

The FAA has indicated that aircraft currently certified to the original is.sue paper, will not currently 

be subject to an Airworthiness Directive, which supports the applicant position that an no adverse 

effect on safety exists. · 

G. Summary of Petition 

In response to a customer request, P.A.S.S requests a revision t9 the existing 

exemption of 12 months to 24 months from 14 CFR 25.57l(e)(i), Amendment 25-132, for 

the ability to complete a flight after a bird strlke under a "norlnal flight envelope" that 

includes V c at sea level. 

It is not envisioned taat the aircraft will fly beyond 250 knots below 10,000 feet and will 

therefore not have any increase in risk from. a bird strike. 

I,. 

H. Request for Reduced Public,Comment Period . · 

The aircraft has delivered under the existing exemption, and with no increased risk to ·; 

the public, P.A.S.S fbspectfully req~ests that the public comment period be waived. 

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1. Privileges of thls Exemptibn Outside the United States 

Per § 11.81 (h), P.A.S.S. requests that the privileges of this Exemption be extended outside 

of the United States. This extension of privileges is necessary for operations based *ithin 

foreign countries having bilateral agreements with the United States accepting FAA 1 CFR 

Part 25 as their airworthiness standards for transport category aircraft. This aircraft is 

intended for the global market place.