### Petitionfor'Exemption for SportParachute Operations. This exemption is being written by

### Philip Esdaile A&P IA,. 1 : l**~** (TOP] 

### §11.81 Whatinformation must I include in my petition for an exemption? 

### You must include the following information in your petition for an exemption and submit it to FAA as soon as you know you need an exemption. · (a) Yourname and mailing address and, ifyou wish, other contact information such as a fax number, telephone number, or e-mail address;

OPERATOR
MAXIMAviation :23490 AviationAve · Davis CA 95695

.·530 753 2650

.'·
MAINTENANCE PROVIDER Philip Esdaile Davis AirRepair, Inc

Davis CA 95616 phil@davisairrepair.com 530 979 0893 AIRCRAFT N850SD (PT6A-42 powered)

### N412Z (Honeywell331-12JR powered)


### (b) The specific section or sections of14 CFR from which you seek an exemption; CFR91.409 (b) "100 hr" 

### (c) The extent ofreliefyou seek, and the reason you seek the relief; ThePT6A series engines (-114, -114A, -42A) areeligible to have 150 hour maintenance intervals. TheHoneywell TPE331-12JR maintenance schedule calls for a 150 hour maintenance interval;**-~** 

### -**----~ --~** 



### (d) The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a whole; The Cessna 208 airframe has proved to be robust and reliable. By synchronizing the Honeywell engine and airframe maintenance hourly interval, the operatorcan save needless over-maintenance ofthe engine to match the 100 hour requirement ofthe airframe.
Hourhistory ofextending thePT6A maintenance intervalto 150 hours has had zero impacton the level ofsafety.



### (e) The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level ofsafety at least equal to that provided by the rule from which.you seekthe exemption; ----··-"" -·"',,**----~·-~-""-~'**

### ·· · TheFAA mandated maintenance requirements remain in place. Annual Inspections, Airworthiness Directive Compliance and FAA mandatedMaintenance Manual Chapter4 required items remain in force. Therefore there is no change to the FAA's requirements otherthan the extension from 100 to 150 hourmaintenance interval.

Over-maintenance is a safety hazard. Needless maintenance can not only wearout good parts, butcomeswith the added riskofcaused by the maintenance eventitself.(f) A summary we canpublish in the FEDERAL REGISTER, stating: 

### 14CFR91.409 needs tobe re·written to reflect the range ofsingle engine turbine airraft in the market. This rewrite will be complexand thoughtful. It is outsidethe scope ofthis request for exemption. (1) The rule from which you seek the exemption; and 

### 14CFR91.409 (b) the "100 hr" portion only.

(2) A briefdescription ofthe nature ofthe exemption you seek; 

### Extending the hourly maintenance interval from 100 to 150 hours.

(g) Any additional information, views or arguments available to support yourrequest; and 

### Davis AirRepairmaintains the Cessna 208 single engineturbine and the Pacific Aerospace Limited P750 single engine turbine. PACIFIC AEROSPACE LTD Through the original TC process, Pacific Aerospace Ltd composed a 150 hour interval for its maintenance. Because this 150 hourprogram was generated by the factory, itis accepted by theFAA. This acceptancewas granted to a new aircraft, with no FAA maintenance history. We have been maintaining this fleet P750 aircraft underthe 150 hourmaintenance program for 10 yearwith no impactto safety. None. CESSNA208 ForSkydiving Operations wantto extend this 150 hour intervalto the Cessna 208 because; 1) the participantswearparachutes 2) the aircraft, with the exception oftheinitialclimb, is within gliding distance of the airport. 3) theCessna 208 as amassed hundreds ofthousands offlight hours and is a known, safe aircraft. The few majormechanical issues it has suffered are flight intoknown

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ice andPT6 engine failures, none ofwhich are related to the hourly maintenance interval.



### (h) Ifyou want to exercise the privileges ofyour exemption outside the United States, the reason why you need to do so. Periodically ouraircraft are leased to operators outsidethe USA. We would maintain the aircraftwith the same exemption fortheduration ofthelease.



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§ 11.61

PETITIONS FOR RULEMAKING AND FOR EXEMPTION § 11.61 May I askFAA to adopt, amend, or repeal a regulation, or grant re- lieffrom the requirements of a cur· rent regulation? (a) Using a petition for rulemaking, you may asl;: FAA to add a new regulation to title 14 of the Code of Federal**R~gulati()IJ:§** 114 J.:JFJ;t) or ask FAA to. amend or repeal a current regulation in 14 CFR.

(b) Using a petition for exemption, you may ask FAA to grant you relief from current regulations in 14 CFR. § 11.63 How and to whom do I submit my petition for rulemaking or petitionfor exemption? (a) For paper submissions, send the original signed copy of your petition for rulema.king or exemption to this address: U.s.**Departm~nt. oCJ;rans~)Or**  tatiofi. Docket Management System, 400 7th Street, sw:; J;toom PL' 401, :Washington, DC 20591-00iil:'

(b) For electronic submissions, submit your petition to FAA through the Internet using the Docket Ma.na.gement System web site a.t this Internet a.ddress: http://dms.dot.gov/.

(c) In the future, FAA may desig·nate other means by which you can submit petitions.

(d) Submit your petition for exemption 120 days before you need the ex- emption to take effect. § 11.71 What information must I in· elude in my petition for rule· making? (a) You must include the following information in your petition for rulemaking:

(1) Your name and mailing address ·and, if you wish, other contact infor-·· mation such as a fax number, telephone number, or e-mail address.

(2) An explanation of your proposed action and itspurpose.

(3) The language you propose for a new or amended rule, or the language you would remove from a current rule.

(4) An explanation of why your proposed a.ction would be in the pubUc interest.

(5) Information and arguments that support your proposed action, includ14 CFR Ch. I (1-1..02 Edition) ing relevant technical and scientific data available to you.

(6) Any specific facts or circumstances that support or demonstrate the need for the action you propose.

(b) In the process of considering your petition, we may ask that you provide information or data ava.ila.ble to you about the following:

(1) 'T'he costs-and•4Jenel'i1is-of-your pt>e------··

.. ·**··----~->----"'"'"'"-··**

## "··'·'-""'"-"""'• posed action to society in general, and identifia.ble groups within society in particular.

(2) The regulatory burden of your proposed action on small businesses, small organizations, small governmental jurisdictions, and Indian tribes.

(3) The recordkeeping and reporting burdens of your proposed action and whom the burdens would affect.

(4) The effect of your proposed action on the quality of the natural and social environments. § 11.73 How does FAA process peti· tions for rulemaking? After we have determined the disposition of your petition, we will conta.ct you in writing about our decision. The FAA may respond to your petition for rulemaking in one of the following ways:

(a) Ifwe det.ermine that. your peUtion justifies our taking the action you suggest, we may issue an NPRM or ANPRM. We will do so no later than 6 months after the date we receive your petition. In making our decision, we consider:

(1) The immediacy ofthe safety or security concerns you raise;

(2) The priority of other issues the FAA must deal with; and

(3) The resources we have available to

..**addrE)S"'.,.th(l!',e)~s;u!J~**.. ·**~···-~** .... "'"

.. "(b) If we have 1ssued an ANPRM or NPRM on the subject matter of your petition, we will consider your arguments for a rule change as a comment in connection with the rulemaking proceeding. We will not treat your petition as a separate action.

(c) If we have begun a rulemaking project in the subject area ofyour peti- · tion, we will consider your comments and arguments for a rule chang·e as part of that project. We will not treat your petition _as a sepa.rate action. 24

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