AFS-12-391-E 

August 20, 2012 

 Exemption No. 10604 

 Regulatory Docket No. FAA-2012-0555 

Mr. Christopher Page 

Director of Maintenance 

Jet Solutions, LLC 

3400 Waterview Parkway, Suite 102 

Richardson, TX 75080 

Dear Mr. Page: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated May 18, 2012, you petitioned the Federal Aviation Administration (FAA) on 

behalf Jet Solutions, LLC (Jet Solutions), for an exemption from §§ 43.3(g) and 135.443(b)(3) of 

Title 14, Code of Federal Regulations (14 CFR). This exemption, if granted, would allow 

Jet Solutions’ properly trained pilots (under an approved training program) to accomplish 

updates of navigational software databases of installed flight management systems (FMS). 

Jet Solutions is a part 135 Air Carrier certificated in accordance with 14 CFR 119. Jet Solutions 

operates 78 business jet aircraft serving more than 1,000 customers annually in the United States 

and abroad. Several airports that Jet Solutions serves, have limited scheduled air service. Jet 

Solutions’ aircraft do not necessarily make it to a base at any regular interval to routinely have 

their FMS database updated. In order to update the FMS, the FMS can be updated from the 

flight deck without using tools. An FMS database must be updated every 28 days. Once an 

update is published by the manufacturer, it typically allows only a few days to update the 

database before that previous database expires. Without the requested regulatory relief, when an 

FMS database expires, Jet Solutions can continue to operate the aircraft under the authority of an 

FAA approved minimum equipment list. However, the aircraft must have the current database 

information to utilize area navigation (RNAV) based enroute and approach capabilities. Due to 

the limitation of operating with an expired database, Jet Solutions would eventually have to 
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reposition the aircraft (flown empty) to a maintenance facility or transport a mechanic to the 

aircraft. During this time when an FMS database is expired, Jet Solutions may not be able to 

access certain airports that already have limited air service because the navigational database is 

no longer current. 

The FAA has determined that good cause exists for not publishing a summary of the petition in 

the Federal Register because the requested exemption would not set a precedent, and any delay 

in acting on this petition would be detrimental to Jet Solutions. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption Nos. 10286 and 10286A (copies 

enclosed), the FAA found that the FMS technology has evolved sufficiently to support the 

granting of the applicant’s request for exemption based on an equivalent level of safety being 

attained by pilots loading navigational software databases as currently exists with certificated 

mechanics performing uploads. Database loading of front panel and pedestal mounted FMCs 

does not require special tools, special access, or removal of the FMS. Further, Flight Solution’s 

FMS performs an internal check and confirms proper loading of navigational databases. 

Properly trained pilots can therefore load the software databases and confirm the upload was 

successful. Should the upload attempt be unsuccessful, minimum equipment list procedures 

already exist to safely operate the aircraft with an inoperative FMS. 

In a subsequent action, the FAA amended Exemption No. 10286 to include relief from 

§§ 91.1443(b)(3) and 135.443(b)(3) as they apply to the requirement that the maintenance log be 

signed by a certificated mechanic or repairman. The task must include the maintenance log 

entries, including the name of the person performing the upload, the date of the upload, the 

database revision number uploaded, and the aircraft location at the time of the upload -- similar 

to requirements for certificated mechanics performing uploads. The Jet Solutions exemption 

includes this same relief from §§ 91.1443(b)(3) and 135.443(b)(3) and additional condition 

relating to requirements for the logbook entry. 

Having reviewed your reasons for requesting an exemption, I find that— 

 the reasons you cite are similar in all material respects to those used to justify granting relief 

previously requested in the enclosed Grant of Exemption Nos. 10286 and 10286A; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption Nos. 10286 and 

10286A apply to the situation you present; and 

 for the reasons stated in Grant of Exemption Nos. 10286 and 10286A, a grant of exemption 

is in the public interest. 
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Our Decision 

Under the authority contained in 49 U.S.C. §§ 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby grant Jet Solutions, LLC, an exemption from 14 CFR §§ 43.3(g), 

91.1443(b)(3) and 135.443(b)(3) to the extent necessary to allow its properly trained pilots 

(under an approved training program) to accomplish updates of navigational software databases 

of installed flight management systems, subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. Pilots will be trained on all specific makes and models of the FMC to which they will be 

uploading navigational software databases. Training on one make and model will not 

enable the pilot to update databases in other makes and models. 

2. Upon successful completion of training, each pilot will be authorized, in writing, by the 

director of maintenance or authorized designee, to perform navigational software 

database uploads on systems for which he has received training. 

3. The pilot must be able to access the FMS from the flight deck and perform the update 

without using tools. 

4. The software being uploaded will not contain system operating software. The upload 

must include the navigational database only. The director of maintenance is responsible 

for ensuring the software being uploaded does not contain operating system software. 

5. Jet Solutions must have written procedures available to the pilot to perform the task and 

to evaluate the accomplishment of the task, including those tasks that require a decision 

concerning the airworthiness of the aircraft. 

6. Each completed task must include the maintenance log entries, including the name of the 

person performing the upload, the date of the upload, the database revision number 

uploaded, and the aircraft location at the time of upload. 

7. This grant of exemption from § 43.3(g) includes only the uploading of navigational 

software databases as listed in Appendix A to part 43, paragraph (c)(32), and does not 

extend to other preventive maintenance tasks identified in Appendix A to part 43. 
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8. Jet Solutions may operate outside the United States under this exemption, unless 

otherwise prohibited by a foreign country. 

This exemption terminates on August 31, 2014, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Deputy Director, Flight Standards 

 Service 

Enclosures