Petition for extension of FAA Exemption Number 10444A, Regulatory Docket Number, FAA-2012-0030 

Aero Contractors, Ltd. (ACL) is requesting an extension to FAA Exemption Number 10444A for the 

requirements for recording certain Flight Data Recorder (FDR) parameters identified in §125.226(e) and 

(f), as applicable. 

After discussions with FAA AFS-360 and assigned FAA Aviation Safety Inspectors from the Greensboro, 

NC FSDO concerning§ 125.226 FDR requirements, it was decided that an alternative method of 

compliance path would be taken to meet the regulatory intent of §125.226. There are no commercially 

available DFDR solutions for the CASA CN-235-300 series aircraft that meet the §125.226(e) or (f) 

requirements (as applicable). 

After further discussions with AFS-360 it was decided that ACL would install a data video recording 

system in the CASA CN-235-300 aircraft. The data image recorder was purchased, and in September, 

2011 it was installed in the aircraft cockpit on the recommendation of FAA ASF-360. 

Aircraft ground and taxi testing was conducted and the data/imaging test results were reviewed. After 

review, it was decided that the recommended system could not meet the regulatory intent of 

§125.226(e) or (f), as applicable. The imaging system could not capture the required number of 

parameters, the images produced were not of good enough focus/clarity, and there was no "crash 

hardened" data/imaging storage capability (it cannot meet the ED-112 standard). 

Personnel from ACL conducted further research into the availability of commercial camera/imaging 

systems for use in aircraft. ACL personnel met with 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 unit to FAA AFS-360 and Greensboro, NC FSDO 

personnel. During this meeting it was decided to move forward with the integration of the system in an 

aircraft cockpit to gather data. The FAERITO system was test fit in the CN-235 cockpit. Initial testing 

appeared hopeful but further testing was needed. 

It became apparent that is order to 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 testing was performed with the camera system temporarily 

installed in the aircraft. The data was reviewed by ACL, POC, FAA AFS-360, and the Greensboro, NC FSDO 

personnel. Adjustments were made to camera placement, focal ranges of cameras, 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 order to 

conduct flight testing with the camera system installed. Day and night flights were conducted in order to 

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 for final review 

and comment. 

All FAA parties found the data to be acceptable. ACL is currently working with AFS-360 personnel and 

personnel from the Greensboro, NC FSDO on the permanent installation and approval of the 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 of compliance to meet the 

§125.226 (e) or (f) requirements, as applicable. 

ACL is requesting a 12 month extension to the current exemption. This will move the termination date of 

the exemption to January 31, 2016. Moving the termination date of the exemption will allow time for 

ACL to receive FAA approval for the installation of the digital video recording systems. ACL is working 

with the FAA (AFS-360 and Greensboro NC FSDO) and vendor in bringing this project to completion. The 

extension to the exemption will allow needed time for ACL, the vendor, and the FAA to resolve any 

outstanding issues with the proposed equipment. 

Thank you for your consideration. 

Respectfully Submitted, 

Richard Litka 

Director of Maintenance Aero Contractors LTD.