AERO CONTRACTORS, LTD. • Johnston County Airport • P .0. Box 1139 • Smithfield. N.C. 27577 

(919) 934-0978 

934·0979 

Federal Aviation Administration 

Mr. Timothy Shaver 

Avionics Branch Manager, 

Avionics Branch AFS-360 

5th Floor, 950 L'Enfant Plaza, 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 CFR Part 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 Data Recorder. 

Petition for Relief: 

Aero Contractors, Ltd. is requesting an exemption from 14 CPR Part 125.226 based upon there is no 

Supplemental Type Certificate for a Digital Flight Data Recorder installation that covers the 88 

parameters required. 

Aero Contractors, Ltd. is requesting a exemption for Flight Data Recorder parameter collection on CN23 5 AEO 1 aircraft based upon the requirements of 14 CPR Part 125.226 (e). The Flight Data Recorder 

parameter numbers are referenced against 14 CFR Part 125.226 (a) (1) through (a) (57). A deviation for 

the following parameter numbers has been requested: 24, 25, 29, 30, 31, 33, 36, 45, 46, 55, and 56. 

In addition, Aero Contractors, Ltd. is requesting a exemption for Flight Data Recorder parameter 

collection on CN-235 AE02 aircraft based upon the requirements of 14 CPR Part 125.226 (f). The 

Flight Data Recorder parameter numbers are referenced against 14 CFR Part 125.226 (a) (1) through (a) 

(88). A deviation for the following parameter numbers has been requested: 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 that the exemption will 

be in force for these aircraft. The aircraft will also have a fully equivalent level of safety to any other 

aircraft operating in FAR 125 in the country. Thus, this exemption will not adversely affect safety. 

CASA CN-235-300 exemption 14 CPR Part 125 Page 1 
Supportive Information: 

Aero Contractors, Ltd. has installed a manufactured Data Image Recorder System on N187D, 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 of compliance for the Digital Flight Data Recorder. This installation and the 

aircraft's current configuration pose no detrimental effect on National Airspace System Safety. Aero 

Contractors, Ltd. is working with the Data Image Recorder System Manufacturer as a member of a beta 

group in providing installation and operational data from the device. 

Description of operation 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 Data Recorder 

requirements under 14 CPR Part 125.226. Aero Contractors, Ltd. will continue to work with the Data 

Image Recorder Manufacturer, FAA Avionics Branch AFS-360, and FAA Flight Standards District 

Office, EA-39 on the approval process for the device as an equivalent means of compliance until such 

time as FAA Avionics Branch AFS-360 determines the Data Image Recorder acceptable. 

Respectfully yours, 

Freddy 

:d?~ Pearce (fpearce@aerocontractors.com) 

Director of Maintenance 

CASA CN-235-300 exemption 14 CFRPart 125 Page2