AERO CONTRACTORS, LTD. • Johnston County Airport • P.0. Box 1139 • Smithfield. N.C.27577 (919) 934-0978 934·0979

Federal AviationAdministration 

### Mr. Timothy Shaver Avionics Branch Manager, Avionics BranchAFS-360 5thFloor, 950 L'EnfantPlaza, S.W. Washington, DC 20024 Aero Contractors, Ltd. 3463 Swift Creek Road Smithfield, NC 27577 (919) 934-0978 (919) 934-1161 fax January 17, 2012

Aero Contractors, Ltd. is requesting a 24 month exemption from 14 CFRPart 125.226 to operate CASA CN-235-300 SIN C-135, (AE01) and SIN C-139, C-143 and C-145(AE02) with their respective Digital Flight DataRecorder.

Petition for Relief: Aero Contractors, Ltd. is requesting an exemption from 14 CPRPart 125.226 baseduponthere is no Supplemental Type Certificate for a Digital Flight Data Recorder installationthat covers the 88 parameters required. Aero Contractors, Ltd. is requesting a exemption for Flight DataRecorder parameter collection on CN235 AEO1 aircraft based uponthe requirements of 14 CPRPart 125.226 (e). The Flight DataRecorder parameternumbers are referenced against 14 CFRPart 125.226 (a) (1) through (a) (57). A deviation for the following parameter numbers has beenrequested: 24, 25, 29, 30, 31, 33, 36, 45, 46, 55, and 56. In addition, Aero Contractors, Ltd. is requesting a exemption for Flight DataRecorder parameter collection on CN-235 AE02 aircraft based upon the requirements of 14 CPRPart 125.226 (f). The Flight DataRecorder parameter numbers are referenced against 14 CFR Part 125.226 (a) (1) through (a) (88). A deviation for the following parameter numbers has beenrequested: 24, 25, 29, 30, 31, 33, 36, 45, 46, 55, 56, 60, 74, 75, 77, 78, 82, 83, 84 and 85. No reduction in operational functionality will be experienced during this period thatthe exemption will be in force for these aircraft. The aircraft will also have a fully equivalent level ofsafety to any other aircraft operating inFAR 125 inthe country. Thus, this exemption will not adversely affect safety.

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### Supportive Information: Aero Contractors, Ltd. has installed a manufactured Data Image Recorder System onN187D, SIN C-143 on a FAA Field Approval from FAA FSDO EA-39. The Data Image Recorder system is being reviewed as an equivalent means ofcompliance for the Digital Flight Data Recorder. This installation and the aircraft's current configurationpose no detrimental effect onNational Airspace System Safety. Aero Contractors, Ltd. is working withthe Data Image Recorder System Manufacturer as a member ofa beta group inproviding installation and operational data from the device. Description ofoperation under the proposed exemption: Aero Contractors, Ltd. will operate these aircraft under the rules and regulation of 14 CPR 125 as a passenger and cargo airplane with a 24 month exemption for the Digital Flight DataRecorder requirements under 14 CPRPart 125.226. Aero Contractors, Ltd. will continue to workwith the Data Image Recorder Manufacturer, FAAAvionics Branch AFS-360, and FAA Flight Standards District Office, EA-39 onthe approval process for the device as an equivalent means ofcompliance until such time as FAAAvionics Branch AFS-360 determines the Data Image Recorder acceptable. Respectfully yours,

# :d?~ Freddy Pearce (fpearce@aerocontractors.com) Director ofMaintenance

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