Petition for'Exemption for Sport Parachute Operations. 

This exemption is being written by Philip Esdaile A&P IA,. 1 : l ~ 

(TOP] 

§ 11.81 What information 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) Your name and mailing address and, if you wish, other contact information such 

as a fax number, telephone number, or e-mail address; 

OPERATOR 

MAXIM Aviation 

:23490 Aviation Ave · 

Davis CA 95695 

.·530 753 2650 . '· 

MAINTENANCE PROVIDER 

Philip Esdaile 

Davis Air Repair, 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 of 14 CFR from which you seek an exemption; 

CFR91.409 (b) "100 hr" 

(c) The extent ofreliefyou seek, and the reason you seek the relief; 

The PT6A series engines (-114, -114A, -42A) are eligible to have 150 hour 

maintenance intervals. 

The Honeywell 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 operator can save 

needless over-maintenance ofthe engine to match the 100 hour requirement of the 

airframe. 

Hour history of extending the PT6A maintenance interval to 150 hours has had zero 

impact on the level of safety. 

(e) The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which.you seek the exemption; ----··-"" -·"' ,, ----~·-~-""-~' ·· · 

The FAA mandated maintenance requirements remain in place. Annual 

Inspections, Airworthiness Directive Compliance and FAA mandated Maintenance 

Manual Chapter 4 required items remain in force. Therefore there is no change to 

the FAA's requirements other than the extension from 100 to 150 hour maintenance 

interval. 

Over-maintenance is a safety hazard. Needless maintenance can not only wear out 

good parts, but comes with the added risk of caused by the maintenance event itself. 
(f) A summary we can publish in the FEDERAL REGISTER, stating: 

14CFR 91.409 needs to be re·written to reflect the range of single engine turbine 

airraft in the market. This rewrite will be complex and thoughtful. It is outside the 

scope of this request for exemption. 

( 1) The rule from which you seek the exemption; and 

14CFR 91.409 (b) the "100 hr" portion only. 

(2) A brief description of the nature of the exemption you seek; 

Extending the hourly maintenance interval from 100 to 150 hours. 

(g) Any additional information, views or arguments available to support your request; 

and 

Davis Air Repair maintains the Cessna 208 single engine turbine 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 hour program was generated by the 

factory, it is accepted by the FAA. This acceptance was granted to a new aircraft, 

with no FAA maintenance history. We have been maintaining this fleet P750 

aircraft under the 150 hour maintenance program for 10 year with no impact to 

safety. None. 

CESSNA208 

For Skydiving Operations want to extend this 150 hour interval to the Cessna 208 

because; 

1) the participants wear parachutes 

2) the aircraft, with the exception of the initial climb, is within gliding distance of 

the airport. 

3) the Cessna 208 as amassed hundreds of thousands of flight hours and is a known, 

safe aircraft. The few major mechanical issues it has suffered are flight into known 
........ -------------

ice and PT6 engine failures, none of which are related to the hourly maintenance 

interval. 

(h) If you want to exercise the privileges of your exemption outside the United States, 

the reason why you need to do so. 

Periodically our aircraft are leased to operators outside the USA. We would 

maintain the aircraft with the same exemption for the duration of the lease. 

______________ ......... ...... 
§ 11.61 

PETITIONS FOR RULEMAKING AND FOR 

EXEMPTION 

§ 11.61 May I ask FAA to adopt, amend, or repeal a regulation, or grant re- lief from 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 petition for 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~)Ortatiofi. 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 its purpose. 

(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) If we 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 of the 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 of your 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