U.S. Department 

of Transportation 

Federal Aviation 

Administration 

March 12,2014 

Northwest Mountain Region 

Office of Regional Counsel 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue s.w. 

Renton, Washington 98057 

Tel: (4~5) 221'-184.7 --

Fax: (425)227-1007 

kyle.lomazow@faa.gov 

VIA EMAlL AND CERTIFIED MAlL- RETURN RECEIPT REQUESTED 

Attn: Hearing Docket Clerk, AGC-430 

Hearing Docket 

Federal Aviation Administration 

(Wilbur Wright Bldg.) 

800 Independence Avenue S.W. 

Washington, D.C. 20591 

Re: In the Matter of JETTECH, LLC, FAA Case No. 2012NM030058 

Enclosed is an Amended Complaint in the above-referenced proceeding. 

No. 9 of the Complaint stated that aircraft Nl50BV was operated on a flight from Broomfield, 

Colorado to Oakland, California. This was in error the aircraft's destination was not Oakland 

California, but Hartford, Connecticut. 

Sincerely, 

lCyle~~ow FAA Attorney 

leE Limas 

Enclosures: Amended Complaint 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

KYLE E. LOMAZOW 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE., SW 

RENTON, WASHINGTON 98057 

TELEPHONE: (425) 227-1847 

FACSIMILE: (425) 227-1007 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

FAA Case No. 2012NM030058 

JETTECH, LLC 

Judge Not Assigned 

JUDGE NOT ASSIGNED: 

AMENDED COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Amended 

Complaint, pursuant to Rule 208 of the Rules of Practice (14 Code of Federal Regulations 

(C.P.R.) Section 13.208), and states as follows: 

I. 

On January 8, 2014, JETTECH, LLC, was advised through a Final Notice of Proposed 

Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $27,500. On 

42 January 25, 2014, JETTECH, LLC, through its legal counsel, submitted a written request for a 

43 

44 hearing. 

45 

46 

47 

48 

49 

50 

51 

52 

53 

II. 

1. JETTECH is now, and at all times mentioned herein was, the holder of Approved 

Repair Station Certificate No. ZYJR157B. 

AMENDED COMPLAINT 

FAA v. JETl'ECH, LLC. 

FAA Case No. 2012NM030058 

Page2of8 

KYLE E. LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

JETTECH is required to conduct its operations pursuant to its FAA approved Repair 

Station Manual (RSM). 

Paragraph A003 of JETTECH's Operations Specifications (OpSpecs) authorizes 

JETTECH to conduct maintenance and alterations on airframes, radios and 

instruments listed on its Capabilities List. 

JETTECH is required to conduct its operations in accordance with its RSM prepared 

pursuant to 14 C.F.R. Section 145.207(a) and 14 C.F.R. Section 145.21l(b). 

Section I. 7 of JETTECH' s RSM authorizes JETTECH to perform maintenance, 

preventative maintenance, or alterations on articles listed on its Capabilities List. 

Section 5.4 of JETTECH's RSM states that JETTECH must use only FAA approved 

technical data when it accomplishes a major repair or alteration. 

On April!O, 2012, JETTECH performed a major alteration on N150BV, a Cessna 

Model 525 civil aircraft, by installing a Garmin GTN 750 Series, avionics system, and 

a GARMIN GDL satellite receiver. 

On AprillO, 2012, JETTECH approved N150BV for return to service after 

performing the major alterations in accordance with data that was not approved by the 

Administrator. 

On April13, 2012, Nl50BV was operated on a flight from Broomfield, Colorado to 

Hartford, Connecticut. 

N150BV was operated on Aprill3, 2012 after the major alterations mentioned in 

paragraph 7 were completed in accordance with data that was not approved by the 

Administrator. 

When JETTECH performed the major alterations, the Cessna Model 525 was not 

listed on JETTECH's current Capabilities List and therefore JETTECH performed 

maintenance on an article for which it was not rated. 

The above-mentioned Garmin GTN installation did not use FAA approved technical 

data for the following reasons: 

AMENDED COMPLAINT 

FAA v.JETTECH, LLC. 

KYLE E. LOMAZOW, F AAArrORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 

FAA Case No. 2012NM030058 

Page 3 of8 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

13. 

14. 

15. 

16. 

Installation of the Garmin GDL Satellite Receiver: 

a. This installation was performed pursuant to Supplemental Type Certificate (STC) 

SAOI487SE-D. 

b. This particular installation deviated from the STC data in that the installation 

included an antenna and it was interfaced with the GTN installation. 

c. As a result, FAA approval was required for the modified data, which JETTECH 

failed to obtain. 

Installation of the Garmin GTN 750 Series Avionics System: 

d. This installation was performed referencing STC Number SA02019SE-D as a 

basis for the installation data. 

e. The Cessna Model525 is not on this STC's approved aircraft list. 

f. JETTECH failed to gain approval for this installation and failed to revise the 

aircraft operating limitations by seeking approval for the issuance of an FAA 

approved Airplane Flight Manual (AFM) supplement as required by the STC. 

In performing the maintenance referenced in paragraph I 0, JETTECH failed to 

comply with its RSM in that it did not use FAA approved technical data in 

performing a major alteration. 

On Aprill6, 2012, five (5) days after the above-mentioned installation of the GTN 

avionics system had already been completed and Nl50BV had been approved for 

return to service, JETTECH sent the Denver Flight Standards District Office (FSDO) 

a data package requesting field approval for the Garmin GDL satellite receiver and the 

Garmin GTN 750 Series avionics installation. 

This data package included duplicate copies of three (3) FAA Form 337's, which 

identified the alterations described above, and sought approval for the technical data 

used, and a request for approval of the associated AFM. 

Additionally, since JETTECH had already performed the installation without first 

receiving field approval from the FAA, the above-mentioned Form 337's did not 

include a stamped statement indicating FAA field approval as required by 

JETTECH' s RSM. 

AMENDED COMPLAINT 

FAA v. JETTECH, LLC. 

KYLE E. LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 

FAA Case No. 2012NM030058 

Page 4 of 8 
1 

2 

3 

4 

5 

6 

7 

8 

9 

2. 

III. 

1. By reason of the foregoing facts and circumstances, JETTECH, LLC. violated the 

following sections of the Federal Aviation Regulations (14 C.F.R.): 

a. 

b. 

c. 

d. 

e. 

f. 

Section 43.5(b), in that in that it approved for retnrn to service an aircraft which 

had undergone maintenance and alteration and for which it failed to execute, in a 

manner prescribed by the Administrator, an alteration form authorized by or 

furnished by the Administrator. 

Section 43 .5( c), in that it approved for return to service an aircraft that had an 

alteration that resulted in a change in the aircraft operating limitations or flight 

data contained in the approved aircraft flight manual, and it failed to ensure that 

those operating limitations or flight data were appropriately revised and set forth 

as prescribed in Section 91.9 of this Chapter 1 of Title 14 C.F.R. 

Section 145.20l(b), in that it maintained or altered an article for which it is not 

rated. 

Section 145.201(c)(l), in that it approved an article for return to service when the 

maintenance, preventative maintenance, or alteration was not performed in 

accordance with the applicable approved technical data or data acceptable to the 

FAA. 

Section 145.201(c)(2), in that it approved for return to service an article after a 

major repair or major alteration when the major repair or major alteration was not 

performed in accordance with applicable approved technical data. 

Section !45.207(a), in that it failed to follow the FAA-accepted repair station 

manual it prepared. 

In accordance with Sections 46301(a) and (d) of Title 49 of the United States Code 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

(U.S.C.) (Transportation) [49 U.S.C. Sections 46301(a) and (d)], JETTECH, LLC. is liable for a 

civil penalty not to exceed $1, I 00 for each of the violations noted. 

45 

46 3. 

47 

48 

49 

50 

51 

52 

53 

Under the facts and circumstances of this case, a civil penalty of$27,500 is appropriate. 

AMENDED COMPLAINT 

FAA v.JETTECH, LLC. 

FAA Case No. 2012NM030058 

Page 5 of8 

KYLE E. LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that JETTECH, LLC. be assessed a civil penalty in the amount of 

$27,500. 

Respectfully submitted ·s 12th day ofMarch, 2014. 

Kyle E. Lorn 

FAAAtto 

7 

AMENDED COMPLAINT 

FAA v. JETTECH, LLC. 

FAA Case No. 2012NM030058 

Page6of8 

KYLE E. LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 ANSWER 

2 

3 In accordance with Section 13 .209 of the Federal Aviation Regulations, JETTECH, LLC, must 

4 answer this Amended Complaint not later than thirty (30) days from the time it is served on it. 

5 Failure to file an Answer within thirty (30) days without good cause shall be deemed an 

6 admission of the truth of each allegation contained in the Amended Complaint [14.C.F.R. 

7 Section 13.209(±)]. 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 AMENDED COMPLAINT 

FAA v.JETTECH, LLC. 

FAA Case No. 2012NM030058 

Page7of8 

KYLE E. LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

CERTIFICATE OF SERVICE 

3 I hereby certify that the foregoing Amended Complaint has been served via Email and Certified 

4 Mail - Return Receipt Requested this date, to the following: 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

Federal Aviation Administration (Original and one copy) 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building -

800 Independence Avenue SW 

Washington, D.C. 20591 

Email: Richard.Goodwin@dot.gov 

Patricia.Matthews@dot.gov 

Michael L. Poindexter, Esq. 

Law Offices of Michael L. Poindexter 

2132 Montane Drive E. 

Golden, CO 80401 

TEL: (303) 526-1980 

Email: poinlaw@aol.com 

Dated this 1ih day of March, 2014. 

Office of Regional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

AMENDED COMPLAINT 

FAA v.JETTECH, LLC. 

FAA Case No. 2012NM030058 

Page 8 of8 

Renton, WA 98057 

(425) 227-2925 

KYLE E. LOMAZOW, F AAATIORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007