Petition forextension of FAA Exemption Number 10444A, Regulatory Docket Number, FAA-2012-0030 Aero Contractors, Ltd. (ACL) is requesting an extension to FAA Exemption Number 10444Aforthe requirements for recording certain Flight Data Recorder (FDR) parameters identified in §125.226(e) and (f), as applicable. Afterdiscussions with FAA AFS-360 and assigned FAA Aviation Safety Inspectorsfrom the Greensboro, NC FSDO concerning§ 125.226 FDR requirements, itwas decided that an alternative method of compliance path would be taken to meetthe regulatory intent of§125.226. There are no commercially available DFDR solutionsforthe CASA CN-235-300 series aircraftthat meetthe §125.226(e) or (f) requirements (as applicable). Afterfurther discussions with AFS-360 itwas decided that ACL would install a data video recording system in the CASA CN-235-300 aircraft. The data image recorderwas purchased, and in September, 2011 itwas installed in the aircraft cockpit on the recommendation of FAA ASF-360. Aircraft ground and taxi testing was conducted and the data/imagingtest results were reviewed. After review, itwas decided thatthe recommended system could not meetthe regulatory intentof §125.226(e) or (f), as applicable. The imaging system could notcapture the required numberof parameters, the images produced were notofgood enough focus/clarity, and there was no "crash hardened" data/imagingstorage capability (it cannot meetthe ED-112 standard). Personnel from ACL conducted further research intothe availability ofcommercial camera/imaging systems for use in aircraft. ACL personnel metwith representatives of Physical Optics Corporation (POC). POC offers a Digital Video recording (DVR) system, known as the FAERITO. The FAERITO system is FAA STC'ed in the Sikorsky S-76 helicopter. The FAERITO is a 4 camera system with an ED-112 approved data storage device. ACL forwarded the system specifications and capabilities to FAA AFS-360 for review and comment. ACL procured a FAERITO system and demonstrated the unitto FAA AFS-360 and Greensboro, NC FSDO personnel. During this meeting itwas decided to move forward with the integration ofthe system in an aircraft cockpit to gatherdata. The FAERITO system was test fit in the CN-235 cockpit. Initial testing appeared hopeful butfurthertesting was needed. It became apparent that is orderto capture all required data points/parameters, two FAERITO camera systems would need to be installed. With an eight camera system all required data could be captured/recorded. Ground and taxi testingwas performed with the camera system temporarily installed in the aircraft. The data was reviewed byACL, POC, FAA AFS-360, and the Greensboro, NC FSDO personnel. Adjustments were made to camera placement, focal ranges ofcameras, and camera orientation. The data was again reviewed and deemed satisfactory. A CASA CN-235-300 was then placed into Experimental Research 

### & Development category in orderto conductflighttesting with the camera system installed. Day and nightflights were conducted in orderto capture all required data points/parameters in different and changing environmental conditions. This

### data was reviewed and then submitted to FAA AFS-360 and the Greensboro NC FSDO forfinal review and comment. All FAA parties found the data to be acceptable. ACL is currently workingwith AFS-360 personnel and personnel from the Greensboro, NC FSDO on the permanent installation and approval ofthe digital video recording system in the CN-235-300 series aircraft operated by ACL. The permanent installation of the video recording system will provide an FAA approved alternative method ofcompliance to meetthe §125.226 (e) or (f) requirements, as applicable. ACL is requesting a 12 month extension tothe current exemption. This will movethe termination date of the exemption toJanuary 31, 2016. Movingthe termination date ofthe exemption will allowtime for ACL to receive FAA approval forthe installation ofthe digital video recording systems. ACL is working with the FAA (AFS-360 and Greensboro NC FSDO) and vendor in bringing this projectto completion. The extension tothe exemption will allow needed time forACL, the vendor, and the FAA to resolve any outstanding issues with the proposed equipment. Thank you foryour consideration.

Respectfully Submitted,

Richard Litka Director of Maintenance Aero Contractors LTD.