U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS ' 1 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

AVIONICS MASTERS, INC., 

Respondent. 

Docket No. FAA-2013-0288 

FAA Case No. 2012S0190209 

Judge Sullivan 

MOTION FOR SUMMARY JUDGMENT 

Pursuant to 14 C.F.R. § 13.218(£)(5), and Rule 56(c) of the Federal Rules of Civil 

Procedure, the FAA hereby moves for summary judgment in this matter. No genuine issue of 

material fact exists to be determined, and the FAA is entitled to judgment as a matter of law. As 

grounds for the motion, the FAA states the following. 

STATEMENT OF THE CASE 

On May 14,2013, the FAA issued a Final Notice of Proposed Civil Penalty against the 

Respondent. Respondent timely appealed, and the Complaint was filed on Juue 5, 2013. The 

Complaint alleged that Respondent had returned to service a Bendix!I<.ing I 02A directional gyro, 

but that Respondent was not authorized to do so by its Operations Specifications or Accepted 

Capability list. Complaint ~~ 4-5. As a result, the Complaint alleged that Respondent had 

violated§§ 145.5(a) and 145.20l(b) of the Federal Aviation Regulations (FARs), and that a civil 

penalty of $7,150 was appropriate. Complaint~~ 6, 8. 

In its Answer, Respondent admitted that it had executed the Form 8130-3, but asserted 

that it was authorized to "inspect and install" the Bendix/King gyro because it was authorized to 

1 
inspect and install a Bendix/King KFC 200 Flight Control System, and the gyro was a 

component of that flight control system. Answer ~ 5-8. 

STATEMENT OF THE FACTS 

Respondent is the holder of a repair station certificate with, in pertinent part, a Limited 

Instruments rating. See Attachment A. Respondent's Operations Specifications authorize it to 

conduct maintenance on instruments as specified in its Capability List. See Attachment B. 

Respondent's capability list authorizes it to conduct maintenance on certain autopilot systems, 

but does not contain an authorization for Respondent to conduct maintenance on gyros. See 

Attachment Cat 3, 15; see generally Attachment C. The autopilot systems on which Respondent 

was authorized to conduct repairs include the Bendix/King KFC-200 system. See Attachment C 

at 15. 

On May 14, 2012, FAA Aviation Safety Inspectors Roger McGlenn and Carlton Kitchen 

conducted an inspection of Respondent's facilities. Attachment J ~ 5. During the inspection they 

discovered an FAA Form 8130-3 relating to work performed on a Bendix/King KG-102A 

Directional Gyro, part number 060-0015-00. Attachment D; Attachment J ~ 6. The Form 8130-3 

indicated the following: (I) Respondent had repaired the gyro; (2) Respondent had returned the 

gyro to service; (3) the sign-off was executed by Charles L. Hunt using the repair station's 

certificate; and ( 4) the sign-off was executed on December 22, 20 II. See Attachment D at boxes 

12, 19, 20-23; see also Attachment J ~ 6. The Inspectors also reviewed Respondent's Work 

Order 8078, which included the work on the gyro and reflected that Respondent had conducted a 

"Bench check and repair" on the gyro, and included a signed maintenance release. Attachment E 

at 2, line 13; see Attachment J ~ 6. 

2 
On May 23, 2013, Inspector McGlenn sent Respondent a letter of investigation (LOI). 

Attaclnnent F; see Attaclnnent J ~ 12. In the LOI, Inspector McGlenn noted that Respondent had 

returned the gyro to service, that the gyro was not on Respondent's capabilities list, and that 

Respondent was not authorized to return the gyro to service. Attaclnnent F. Respondent replied 

to the letter on May 30, 2012. Attaclnnent G; see Attaclnnent J ~ 13. In the letter, Respondent 

admitted that the gyro was not on its capabilities list, and indicated that the gyro should have 

received a final check from another repair station (such as Triumph Instruments) that was set up 

to handle gyros. Attaclnnent G; see also Attaclnnent J ~ 13. 

After the FAA Aviation Safety Inspectors discovered the problem, Respondent sent the 

directional gyro to Triumph Instruments for inspection. See Attaclnnent H. Triumph's initial 

examination found that "Unit has corrosion at the base of the gyro capsule and on the entire case. 

Unit is inop[erative], blew circuit breaker." Id. at !. Upon opening the gyro, Triumph found 

"Corrosion on the circuit board and voltage selector switch. Rotor bearings are worn. Gimbal 

bearings are contaminated and rocking. Q205 and Q207 are shorted." Jd. at I. Triumph 

overhauled the gyro. Jd. at 1-2. 

At no material time has Respondent had the facilities that would enable it to repair gyros, 

or to perform an inspection of the gyro as an independent component. Attaclnnent J ft 7-10. 

SUMMARY OF THE ARGUMENT 

As described in its capabilities list and as admitted by Respondent in pre-litigation 

correspondence, Respondent is not authorized to repair a gyro or return one to service. The 

authorization to work on gyros is a distinct one from a general authorization to work on other 

sorts of instruments. Nonetheless, Respondent did return the gyro to service as repaired. 

Respondent thus violated§§ 145.5(a) and 145.201(b) ofthe PARs. 

3 
Additionally, the sanction of $7,150 is consistent with the Administrator's published 

sanction guidance and is otherwise appropriate. 

ARGUMENT 

"A party may make a motion for decision, regarding all or any part of the proceedings, at 

any time before the administrative law judge has issued an initial decision in the proceedings. 

The administrative law judge shall grant a party's motion for decision if the pleadings, 

depositions, answers to interrogatories, admissions, matters that the administrative law judge has 

officially noticed, or evidence introduced during the hearing show that there is no genuine issue 

of material fact and that the party making the motion is entitled to a decision as a matter of law. 

The party making the motion for decision has the burden of showing that there is no genuine 

issue of material fact disputed by the parties." 14 C.F.R. § 13.218(£)(5). 

A repair station is not authorized to perform every type of maintenance work on every 

type of aircraft and component, but rather may only work on those kinds of aircraft and/or 

components that it has been explicitly authorized to work on. See 14 C.F.R. § 145.59 (listing 

various types of ratings that a repair station might have). Additionally, a repair station might 

have either a Class rating or a Limited rating; a Limited rating only permits work on certain 

specific aircraft or components, rather than on any component that falls within a Class. 14 C.F.R. 

§ 145.61. Where a repair station has a Limited rating, it might have the components on which it 

is authorized recited directly in the operations specifications or, more commonly, maintain a 

capabilities list, with the operations specifications requiring adherence to the capability list. See 

14 C.F.R. § 145.215 (permitting capability lists). 

In this case, the applicable class rating here would be Instruments Class 3 Gyroscopic. 

See 14 C.F.R. § 145.59(e)(3). However, Respondent only had a Limited Instruments rating, to be 

4 
managed by a Capability List. Attachments A, B. Accordingly, if a component was not on 

Respondent's Capability List, it could not legally perform maintenance on that component. 

I. Respondent Returned the Gyroscope to Service As Repaired 

Contemporaneous documentary evidence demonstrates that Respondent returned the KG102A directional gyro to service as repaired. Respondent executed an FAA Form 8130-3. 

Attachment D. On that form, Respondent marked that the KG-102A directional gyro had been 

repaired. Attachment D, Block 12. In the Remarks section of the form, Respondent stated that 

the gyro was "approved for return to service" and that "details of the repair are on file at this 

facility." Attachment D, Block 13. On that form, Respondent marked the gyro as returned to 

service pursuant to 14 C.F.R. § 43.9. Attachment D, Block 19. The form was signed and dated by 

Charles Hunt under Respondent's repair station certificate. Attachment D, Blocks 20-23. 

Additionally, the Respondent's December 2011 work order states that the gyro was repaired. 

Attachment E at 2, line 13. 

There can be no genuine dispute of material fact as to the contents of these documents, 

including the FAA Form 8130-3 approval for return to service. The FAA is entitled to judgment 

as a matter of law as to the fact that Respondent did return the gyro to service as repaired. 

II. Respondent's Capabilities List Did Not Include Gyroscopes 

As discussed above, Respondent's authorization to work on a particular instrument was 

governed by its Capability List. It is undisputed that Respondent's Capability List did not include 

the Bendix/King directional gyro at issue in this case. See Attachment C. Respondent asserts that 

it can implicitly work on the gyro because the gyro was a subcomponent of an autopilot it was 

authorized to work on, but this assertion is incorrect. Because Respondent was not authorized to 

5 
repair the gyro or return it to service, Respondent violated §§ 145.5(a) and 145.20l(b) when it 

did so. 

"No person may operate as a certificated repair station without, or in violation of, a repair 

station certificate, ratings, or operations specifications issued under this part." 14 C.F.R. 

§ 145.5(a). "A certificated repair station may not maintain or alter any article for which it is not 

rated, and may not maintain or alter any article for which it is rated if it requires special technical 

data, equipment, or facilities that are not available to it." 14 C.F.R. § 145.20l(b). 

There is no dispute that, if Respondent performed maintenance on an aircraft component 

for which it was not rated- or for which it did not have the appropriate equipment and facilities 

- then it violated §§ 145.5(a) and 145.201(b). And it is indisputable that, on its face, 

Respondent's Capability List does not include the KG-102A directional gyro. Respondent 

asserts, however, that there is an implied authorization to work on the KG-1 02A because the 

gyro can be installed as part of a KFC-200 Flight Control System (autopilot), and Respondent 

was authorized to repair that system. 

Respondent's contention is misplaced. It is accurate that there exists a Supplemental 

Type Certificate for the KFC-200 Flight Control System that lists the KG-I 02A as a component 

to be installed. However, it is not the case that being able to work on a larger system means 

being able to perform maintenance on a particular component. This exact argument has been 

previously rejected by the Administrator. In In re: Royal Avionics Systems, Inc., Royal Avionics 

argued that its work on a flux gate (also referred to as a flux valve) was permissible because the 

flux gate was a component of autopilot systems, that Royal Avionics was authorized to work on 

numerous autopilot systems, and that therefore Royal Avionics was authorized to work on the 

flux gate. In re: Royal Avionics Systems, Inc., FAA Order No. 2002-6, 2002 WL 1042303 at *3 

6 
(April IS, 2002). The ALJ noted that flux gates were separately identified in§ 145.3l(e)(3) and 

that to include the flux gate as part of the autopilot would "eviscerate proper distinctions between 

separable components." 1 ld. The Administrator affirmed the ALJ's ruling, holding that Royal 

Avionics' authorization to work on autopilot systems did not mean that it could perform 

maintenance on the flux gate. ld. at *6. Just as with the flux gate in Royal Avionics, directional 

gyros are explicitly called out in § 145.59(e)(3). They are a distinct component and require a 

distinct authorization for a repair station to perform maintenance on them. 

Consistent with Royal Avionics and the plain language of its own Capability List, 

Respondent was not authorized to work on the KG-I 02A directional gyro, or any gyro. It was not 

authorized to perform an inspection of the gyro itself to determine what, if any, problems there 

might be with the gyro. See Attachment J ~ 8. And it was not authorized to open up and repair 

the gyro. See Attachment J ~ 7. Indeed, there is no indication that the work on the directional 

gyro had any relation to the KFC-200 Flight Control System- Respondent's work order for the 

month of December 20 II makes no reference to the system, only a freestanding repair of the 

gyro. See Attachment E. 

Further, Respondent admitted as much it its own response to the letter of investigationit admitted that it was not authorized to work on the gyro, and that it would need to send the gyro 

out to another repair station in order to have the gyro itself checked out and returned to service. 

The distinction is made even clearer when one considers the equipment and facilities 

available to Respondent. Respondent did not have an electronic turntable, which would have 

been required to perform an independent check on the directional gyro. See Attachment J ~ 8. 

And it did not have a clean room, which is necessary in order to open up a gyro and perform 

repair work on it. Attachment J ~ 7. Even if Respondent had been authorized to repair the KG1 The former § 145.31 is now located at § I 45 .59. 

7 
102A directional gyro, it would have violated § 145.201(b) for Respondent to conduct such a 

repair when it did not have appropriate equipment and facilities. 

Respondent was not authorized to perform repairs on the KG-I 02A directional gyro, or 

any other gyroscope. Respondent contends that the authorization to work on a particular 

autopilot system that might include the KG-I 02A implies the authority to perform independent 

work on the direction gyro, but the Administrator has previously rejected this contention in 

Royal Avionics. The FAA is entitled to judgment as a matter of law on this issue. 

III. The Sanction Sought Is Appropriate 

The FAA seeks a sanction of $7,150 for Respondent's violations in this case. That 

sanction is consistent with the Administrator's published sanction guidance, and is otherwise 

appropriate. 

Although two regulations were violated, Respondent only committed a single act of 

violation here -the improper return to service as repaired of the directional gyro. Accordingly, 

the penalty proposed is unitary, not bifurcated on a per-regulation basis. The Administrator's 

published sanction guidance includes guidance for "Maintaining or altering an airframe, 

powerplant, propeller, instrument, radio, or accessory for which the repair station is not rated." 

FAA Order 2150.3B at B-21, Figure B-3-b(13) (a copy of which is attached as Attachment I). 

The guidance for that offense is a Maximum civil penalty or Suspension or Revocation of the 

repair station's air agency certificate. 

The meaning of a Maximum civil penalty is also found in the Administrator's published 

sanction guidance. For a small business air agency (such as Respondent) a Maximum civil 

penalty means an amount from $7,150 to $11,000. FAA Order 2150.3B at B-5(4). In determining 

where in the range to set the penalty, FAA personnel are to start in the middle and vary from 

8 
there based on aggravating or mitigating factors. FAA Order 2150.3B at 7-9, ~ 5(b)(3). In this 

case, that starting midpoint would be $9,075. 

The sanction selected in this case was the lowest possible sanction that still fell within the 

Administrator's published sanction guidance, below the default midpoint penalty, and at the 

bottom of the Maximum range. Respondent's personal opinion may be that the penalty should be 

lower, but Respondent's personal opinion does not create a genuine issue of material fact as to 

whether the penalty was appropriate. 

CONCLUSION 

Documentary evidence establishes that Respondent returned the KG-1 02A directional 

gyro to service as repaired. Documentary evidence establishes that the gyro was not on 

Respondent's capability list, and case law forecloses Respondent's argument that it's 

authorization to work on an autopilot system also means that it can perform maintenance on the 

gyro. Further, the proposed penalty is appropriate and consistent with the Administrator's 

published sanction guidance. There are no genuine issues of material fact, and the FAA is 

entitled to judgment as a matter of law. 

WHEREFORE, Complainant respectfully requests that the Judge grant Summary Judgment and 

affirm the Complaint in its entirety. 

. l~ 

Respectfully submitted this_§__ day of March, 2014. 

CHRISTOPHER /~ R. STEVENSON 

Attorney 

Office of the Regional Counsel 

9 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Motion for Summary Judgment has been sent this 

date by the following methods: 

original and one copy via certified mail: 

Federal Aviation Administration 

800 Independence Avenue, S.W. 

Attention:Hearing Docket Clerk, AGC-430 

Wilbur Wright Building- Suite 2W1 000 

Washington, D.C. 20591 

one copy via certified mail: 

Charles L. Hunt, Jr. 

Vincent Sortino 

Avionics Masters, Inc. 

1001 West Cypress Road, Suite 309 

Ft. Lauderdale, FL 33309 

fax: (954) 491-5279 

Honorable Judge J.E. Sullivan 

Office of Hearings, M-20 

U.S. Department of Transportation 

1200New Jersey Avenue, S.E. (E11-310) 

Washington, DC 20590 

L,, jh I JJtPith Jrr~ DONNA sTANLEY 

Legal Assistant 

Office of the Regional Counsel 

MAR - 6 2014' 

Dated 

10 
UNITED STATES OF AMERICA 

...,t:PARTMENT OF TRANSPORTAl1~'~ 

FEDERAL AVIATION ADMINISTRATION 

Air Agency Certificate 

Jlta~n6ev VIMR095K 

.?lld.Yce#iflicak i.Y~twdtrY 

AVIONICS MASTERS, INC. 

1001 West Cypress Creek Road 

Fort Lauderdale, Florida 33309 

ftJZMfou:tt/l;fl that t!d o~a/u"::cakwl com1zlt"e.1 t/z att!.Feytec'!:J 

tt•tth tk /?Jf?ttt/-e/JWab o/tk S?;ck~>a/.Yft,tat/oa Ylepu!fztt"oad 

nlfztt~ to tk e.Jta!fd:Jifmeat ryf'aa SJ!t;,.. .w'peacpt:, aad tJ 

enywwend tc cyz-eFate at? a;yzMvea Repair Station. 

RADIO (07-14-1988) 

LIMITED AIRFRAME (12-01-1988) 

LIMITED INSTRUMENTS (06-13-1989) 

,.,., ', ·/'- . "" E / I I ,(7 I ,(7 /'p :J'hcJ ce.Ftljtcate/ t//?te.1.1 ccYlCecea; .1u.yteaaea; o.F .Feoo/tect, .1/zat;c 

coakaue t/z #ct Indefinitely. 

July 14,1988 

Manager, South Florida FSD0-19 

ThiS Certificate is not Transferable, AND ANY MAJOR CHANGE IN THE BASIC FACILITIES, OR IN THE LOCATION THEREOF, 

SHALL BE IMMEDIATELY REPORTED TO THE APPROPRIATE REGIONAL OFFICE OF THE FEDERAL AVIATION ADMINISTRATION 

A11y a/lcrolion of litis certlji"ciJIL' is ptwishahle hy 11_{inc of not cJ:ccedlllg $1,000, or imprisol/111l'!l/ HOI cxn•cdi11g 3 years, or h1!1! 

FAA Form 8000-4 (1·67) SUPERCEDES FAA FORM 390 

! GOVERNMENT i EXABIT i _ _1. _ _:...--
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

A003 . Ratings and Limitations HQ Control: 01/30/2004 

HQ Revision: 010 

The Certificate Holder is authorized the following Ratings and/or Limitations: 

Class Ratings 

Radio Class 1: Communications Equipment 

Radio Class 2: Navigational Equipment 

Radio Class 3: Radar Equipment 

Limited Ratings 

Rating 

Airframe 

Manufacturer 

N/A 

Instruments From the accepted 

Capability List, as 

amended. 

Make/Model 

N/A 

From the accepted 

Capability List, as 

amended. 

Limited Ratings- Specialized Services 

Rating Specifications 

None Authorized 

Limitations 

Compass Swings and Calibration, 

Test and repairs ofPitot Static Systems, 

Radio, Instrument and Autopilot installations 

to include Weight and Balance Reports 

associated with installations 

Install, Remove, Repair and Replace 

lnsrtuments, Autopilot and Radios, 

Conduct Altimiter System and Altitude 

Reporting test and inspection in accordance 

with 14 CFR 43, Appendix "En and F 

Limitations 

Print Date: 217/20 ll A003-l 

Avionics lv'Iasters, Inc. 

GOVERNMENT 

E~IBIT 
U.S. Department 

of Transportation 

Federal Aviation 

Administration Operations Specifications 

I. Issued by the Federal Aviation Admicistration. 

2. Support information reference: 

3. These Operations Specifications are approved by direction of the Administrator. 

2011.02.07 14:0:5:56 Ccmrul St~mdard Ti1111.' 

Locntion: \VcbOPSS 

Dil!:ilallv si!!n1.·d bv Rouer tl·1cCikiL 

Pri~1eipt~l A \·ionicS lnsJ)cctor (SO 19) 

4. Date Approval is effective: 02/07/2011 Amendment Number: 5 

5. I hereby accept and receive the Operations Specifications in this paragraph. 

Sortino, Vincent I., General Manager 

' I 

, 

·1; ;. :'..--<•j . ._,' 

-F- -·~·-.· ', .. ~~· 

Print Date: 217/2011 A003-2 

Avionics Masters, Inc. 

Date: 02/07/2011 

Certificate No.: VIMR095K 
AVIONICS MASTERS, INC. 

REPAIR STATION CAPABILITY LIST 

CAPABILITY LIST 

FOR 

FAA APPROVED REPAIR STATION 

No. VIMR095K 

1001 West Cypress Creek Road 

Suite 309 

Ft. Lauderdale, Florida 33309 

Capability List 

Revision 2, Dated 02/15/2011 

ASSIGNMENT: Chief Inspector 

LOCATION: Chieflnspectors Office 

~GOVERNMENT 

~ EXHIBIT 

- / 

1---'L-=---
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

TABLE OF CONTENTS 

TITLE 

Table of Contents 

Record of Revisions 

List of Effective Pages 

Capability List 

REV 

0 

1 

2 

REV DATE 

01/29/2004 

05/01/2008 

02/15/2011 

MAINTENANCE LEVEL: 

RECORD OF REVISION 

INSERTION DATE 

01/29/2004 

05/0112008 

02/15/2011 

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Title: Table of Contents and 

Page: i 

Issue Date: 02/15/2011 

Revision: 2 

PAGE 

ii 

1-16 

BY 

DWT 

CLH 

CLH 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

LIST OF EFFECTIVE PAGES 

I PAGE I REV I NAME 

1 0 Table of Contents 

11 0 Record of Revision ... 

111 0 List of Effective Pages 

1-2 0 Light Com and Nav 0 0 Heavy Communications " 4 0 Audio Panel/ Marker Beacon 

5 0 GlideSlope 

6 0 DME 

7 0 ADF 

8-9 0 Radar 

10-11 0 Transponder 

12 0 Navigation Indicators 

13 0 Digital Area Navigation System 

14 0 Encoder 

15 0 Autopilot 

16 0 Miscellaneous 

17 0 GPS 

18 0 Weather Detection I Multi-Function Display 

19 0 High Frequency Communications 

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Title: List of Effective Pages 

Page: ii 

Issue Date: 02/15/20 II 

Revision: 2 

DATE 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01129/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

01/29/2004 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
I 

I 

20 0 Navigation Converters 01129/2004 

21 0 Lorane 01129/2004 

Avionics Masters, Inc. 

REP AIR STATION CAP ABILITY LIST 

Light Com and Nav 

MODEL DESCRIPTION 

··-- RT -328A/C/D/T NA V Receiver I Comm Transceiver -·--"- RT-428A NA V Receiver I Comm Transceiver --- RT-385A I RT-485A NA V Receiver I Comm Transceiver .. 

RT-485B NA V Receiver I Comm Transceiver =--···· ----· KN-53 Navigation Receiver =c-.·-·--

KY-92 Comm Transceiver _, ____ -- KY -96 I KY -97 Comm Transceiver ----------

KY -96A I KY -97 A Comm Transceiver ---- KX-145 NAV Receiver I Comm Transceiver --··· 

KX-155/ KX-165 NA V Receiver I Comm Transceiver -~-~----

KX-155A I KX-165A NA V Receiver I Comm Transceiver ----- KX-170/A/B, KX-l75A/B NA V Receiver I Comm Transceiver --~-----

KY-195, KX-195B Corum Transceiver 

KY 196/ KY-197 Comm Transceiver --------·-·--· -

KY-196A, KY-197A Comm Transceiver 

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

Page: 1 

Issue Date: 02/15/2011 

Revision: 2 

MFR. LEVEL 

ARC 3 

ARC 3 

ARC 3 - ARC 3 .. 

Bendix/King 3 -- Bendix/King 3 

Bendix/King 3 ----- Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Level 2: Line and/or bench test maintenance up to board leveL 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Light Com and Nav 

MODEL 

·--- - VHF251 --- VHF-251A ---· VIR 351 

1----- -·-- ESCOURT HO 

COM II I COM IIA "---··--

MK-120 

--- ----- MK-12E 

COM 120 I COM 120-20 

NAV 121,122 

NAV 124 

COM 8101811 

NAV824 

MX-ll 

MX-12 

MX-300 

MX-385 

MX-170 

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

DESCRIPTION 

Comm Transceiver 

Corum Transceiver 

Navigation Receiver 

NA V Receiver I Comm Transceiver -- Comm Transceiver 

NA V Receiver I Comm Transceiver 

NA V Receiver I Comm Transceiver 

Comm Transceiver 

Navigation Receiver 

Navigation Receiver 

Comm Transceiver 

Navigation Receiver 

Comm Transceiver 

Corum Transceiver 

NA V Receiver I Comm Transceiver 

NA V Receiver I Corum Transceiver 

NA V Receiver I Corum Transceiver 

Page:2 

Issue Date: 02115/2011 

Revision: 2 

MFR. LEVEL 

Collins 3 

S-Tec 3 

Collins 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

Narco 3 

TKM 3 

TKM 3 

TKM 3 

TKM 3 

TKM 3 '---

Levell: Line and/or bench test, and Installation. 

Leve12: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
Heavy Communication 

MODEL ----·· 

1038A 

R-900 I KTR-900A 

RTKT 

KT 

KT 

KT 

R-905 I KT -90S A --~-- -- R-906 

---

R-9000 

-

-

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

DESCRIPTION 

VHF Comm Transceiver I 

- VHF Comm Transceiver 

VHF Comm Transceiver 

VHF Comm Transceiver 

I VHF Comm Transceiver 

Page:3 

Issue Date: 02/15/2011 

Revision: 2 

MFR. LEVEL 

ARC 3 

Bendix/King 3 i 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

16lR 

,618 

Ml VHF Corum, Transceiver Collins ~ I ' 

-- -- M2 VHF Comm. Transceiver Collins 3 

' i 

M3/3A VHF Comm. Transceiver Collins 3 -~·--·---

F-20 I VHF-20A I VHF-20B VHF Comm. Transceiver Collins I 3 

F-21 j VHF Comm. Transceiver Collins 3 ------- ·------- ' 

F-22 VHF Corum. Transceiver ' 3 I Collins ------- --- --~-------

MAINTENANCE LEVEL: 

Levell: Line and/ or bench test. and Installation. 

Level 2: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Audio Panel I Marker Beacon 

MODEL DESCRIPTION ----- _____ , _____ -------

---- R-402A/B, R-502A/B Marker Beacon ---- - KMA-20 Audio Panel/Marker Beacon -"'" ___ 

KR-21 -i Marker Beacon 

!KMA-24 ·-···----

Audio Panel/Marker Beacon 

,-----.......... ·-·· -- . ~-

'KMA-24H-70/71 

I l____________. __________ Audio Panel/Marker Beacon --- iKMA-26 Audio Ponei/Morker Beacon '-"···- ---- -------···--·- I 

KA-25/C Audio Amp -------~--

KA-134 Audio Panel ,., _____ KMR-675 Marker Beacon - ---- AMR-350 ' Audio Panel/Marker Beacon i-~-"--·-···--

,MKR350 Marker Beacon ~---.------------- ------------ GMA-340 Audio Panel/Marker Beacon ·--------- CP-135 i Audio PaneUMarker Beacon 

ICP-136 I Audio Panel/Marker Beacon 

iMBT Marker Beacon [AA.::-sol- ---- - -------------- Audio Panel 

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

--

-----

Page:4 

Issue Date: 02/15/20 II 

Revision: 2 

MFR i LEVEL ' 

I I 

ARC 3 ·-- Bendix/King 3 -- Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

! 

Bendix/King I 3 i 

i Bendix/King -

3 I 

Bendix/King 3 j Bendix/King 3 I 

Collins 

Collins 

i± 

3 

Garmin J I ___ T____ --

Narco ' 3 I 

Narco 3 ---------

Narco 3 - Electrodelta 3 -~-------1 

Leve12: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Glideslope 

f-----'MODEL 

R-443A/B 

R-543A ----

KN73 

!KN7~-

! C. I $-;)SO 

•UGR-2/2A/3 

-

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATTON CAPARTUTV J.TST 

I! 

DESCRIPTION -

i 

1-

GlideSlope 

I GlideSlope 

I GlideSlope 

I GhdeSlope 

GlideSlope 

GlideSlope 

Page:5 

Issue Date: 02/15/2011 

Revision: 2 

MFR. LEVEL -·-· 

- ARC 3 

ARC 3 I 

Bendix/King 1 3 -·-! 

I Bend1x/Kmg 

' 

' 3 

Collins 3 

Narco 3 

Levell: Line and/or bench test, and Installation. 

Level 2: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
DME 

[- MODEL 

-- I 

I -- IDME400 

loME-1000 

~-62 /I<N-62A ---

-~--

KN-63 

IKN-64 - -----

~N-65 1 KN-65A 

[KDM-700, KDM-700~ --·-

. --···-· 

IKDM--705, KDM-7_0~A 

DME40 

loME 42 ---

jDME 450 )______________ ______ -·-- !DME-190 - 'DME-195 

!-----·--·-·-

1DME 890 

loi\1-[=891 ---

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

--

DESCRIPTION 

DME 

' DME I 

I DME 

DME - I OME 

! DME 

I 

! DME 

I DME 

DME -- I 

I DME 

DME - DME 

i DME 

I DME -

I DME 

Page: 6 

Issue Date: 02/15/2011 

Revision: 2 

MFR. I LEVEL 

I --- ARC 3 

ARC 3 

Bendix/King 3 

Bendix/King 3 --- Bendix/King 'I 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Collins 3 

COLLINS 3 

Collins 3 

Narco 3 

Narco 3 -- Narco 3 

Narco I 3 i 

Levell: Line and/or bench test, and Installation. 

Level 2: Line and/or bench test maintenance up to board leveL 

Level 3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Page: 7 

Issue Date: 02/15/20 II 

Revision: 2 

ADF 

----

!__ ___ _ 

r------

,R-4 46A ,~ 

jR5 46E 

--'" 

MODEL 

--

--

';y:l 2, T-12A, T-12B, T-12D 

;Ao F-2070 1

KR 

ii{R. 

~-­

jKR 

iKD 

1--;-;; 

KD 

85 -~-.. -- -86 -- ·- -87 ·-·----

F-800 ---·- F-805 ___ ,. ___ 

F-806 - F-60 --------- F-650, ADF-6SOA 

I 

-~ -----+~ I 

I 

' -

' 

' ' 

i 

--·· I 

: --·--

---

------·- ---

·-----· 

MAINTENANCE LEVEL: 

DESCRIPTION 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Automatic Director Finder 

Levell: Line and/or bench test, and Installation. 

' MFR. 

ARC 

ARC 

Bendix I 

Bendix I 

Bendix/King i 

Bendix/King: 

Bendix/King i 

Bendix/King i 

Bendh/King 

Bendix/King 

I Collins - Collins 

Leve12: Line and/or bench test maintenance up to board level. 

LEVEL I 

3 

3 -----::-

3 

3 

3 

3 

3 

3 

3 

3 

3 

3 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REP AIR STATION CAP ABILITY LIST 

Radar 

' 

- ---· ----·---

' 

MODEL DESCRIPTION 1-- -

--------· - :IN-132A Weather Radar Indicator 

iiN-152A 

_ _. ___ . 

Weather Radar Indicator 

JIN-H02A ------ Weather Radar Indicator __ , ____ 

i!N-1202A/B I Weather Radar Indicator 

' IN-l302A/B i Weather Radar Indicator --~- --- ~--- ·-· ' IN-2021A, lN-2022A, IN-2025A i Weather Radar Indicator i 

IN-2025A, IN-2026A, IN-2027 A I Weather Radar Indicator ---- ---~------.- --

IN-2028A Weather Radar Indicator 

Ill!: 131 A Weather Radar RIT 

IART-161A Weather Radar R/T and Antenna ---·----------·-- RT-l201A Weather Radar RIT 

IRf:l3otA/B Weather Radar RIT 

lAf:I33A ---- --------- . 

Weather Radar Antenna 

;AT-143A Weather Radar Antenna ---·--·------ ------- DA-l44A Weather Radar Antenna 

DA-1203A Weather Radar Antenna 

MAINTENANCE LEVEL: 

Level 1: Line and! or bench test, and Installation. 

I 

i 

' 

i 

Page: 8 

Issue Date: 02/15/2011 

Revision: 2 

MFR. 

I 

LEVEL! 

! ----- Bendix 3 

Bendix 3 

Bendix I 3 -- Bendix i 3 

Bendix 3 

Bendix 3 

Bendix 3 -----·---- Bendix 3 

Bendix 3 I 

Bendix 3 

Bendix I 3 

Bendix 3 

Bendix 3 

Bendix 

·1---:----

3 

Bendix 3 

Bendix l 3 

Leve12: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Radar 

---~··-

____ MODEL 

WXR-100 

WXR-200 

WXR-250AIB 

KWX-58 -----

DESCRIPTION 

-

Weather Radar System 

Weather Radar System 

Weather Radar System 

Weather Radar System 

RDS Weather Radar System s1 1 Rcco=-s=--ccs2~1 Iills:s4-----j--~­

IKWX-56 Weather Radar System 

Page:9 

Issue Date: 02/15/20 II 

Revision: 2 

MFR. LEVEL 

Collins 3 

Collins 3 

Collins 3 

Bendix/King 3 

Bendix/King 3 

Narco 3 

Weather Radar System RCA 3 

Weather Radar System RCA 3 ------

f:~:::: ~:;-:~;-;;~---------_--------+----:-o-c--:----:o--:----:!--:---+-=cc--l---::--

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Level 3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Transponder 

Page: 10 

Issue Date: 02/15/2011 

Revision: 2 

~T :,-~9-A--~~~-E-L ___ --1---D-E-=:c-.. ~-~-sp-~-~~T--cd 1-e~-N --+--M-eA-=:-=-:- ll,E, 

;RT-459A Transponder ARC I 3 

IRT-8~9-~~-··-___ Transponder ARC : 3 I ···-

iTR-641 

~~ 

I Transponder 

I 

Transponder ------

Transponder 

~:.7s···'·KT-75R ~T-76, KT-76A -~ Transponder 

Transponder 

·~'K'f:78, KT-78A 

KT-79 =--- ,KXP-750 

: ---

I

KXP-755 __ _ 

KXP-756 

~~~~-?-__ _:::_:::_---~··-· -

-

I 

I . -- I 

--. --· 

I 

---+ -

MAINTENANCE LEVEL: 

Transponder - Transponder - Transponder 

Transponder 

Transponder 

Transponder -- Transponder -

Levell: Line and/or bench test, and Installation. 

.. - Bendix 

Bendix .. 

Bendix/King, 

Bendix/King 

Bendix/King 1 

Bendix/King I 

Bendix/King: 

Bendix/King 

Bendix/King 

Bendix/King 

Collins 

Collins I 

Leve12: Line and/or bench test maintenance up to board level. 

3 I 

~~ 3 

3 -j 

~---1 

-8 

3 J 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Transponder 

MODEL 

RT-667 , RT-777, RT-787, RT-887 

GTX-33 

GTX-32 

GTX-33 

AT-50, 

TRT-25 

814 

1014 

, GTX-33D -- 0, GTX-327 -- 0 ··--· - AT-SOA, AT-150 

0, TRT-2500 

- ----· -- TP-114B ---------

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REP AIR STATION CAP ABILITY LIST 

DESCRIPTION 

Transponder - Transponder 

Transponder 

Transponder - - Transponder 

Transponder -----

Transponder 

Transponder 

i Transponder i 

Page: 11 

Issue Date: 02/15/2011 

Revision: 2 

--

MFR. LEVEL 

Edo-Aire 3 

Garmin I 

Garmin 1 

Garmin 1 

Narco 3 

Terra 3 

Wilcox 3 , Wilcox 3 i 

___J 

Sperry 3 I 

Levell: Line and/or bench test, and Installation. 

Level 2: Line and/or bench test maintenance up to board level. 

Level 3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Navigation Indicators 

EL 

----

214 

~265, Kl-266, KIiKI-520 

]KI-52s,K:j::iliA- IKm 5_72- 1 573 1 s2~­

!NSD-36o 

267 

·-

-

-

i-----·--;;-c=;:-:o= 

jiND-350 /IND-351 !TND-351C 

. D-450 /lND-45~ 

102A I GI-106A - VN-210A ------ --·· 

--··-·· 

-

-· 

··----

MAINTENANCE LEVEL: 

DESCRIPTION 

Navigation Indicators - Navigation Indicators - Navigation Indicators 

Navigation Indicators - Navigation Indicators 

ADF Indicators 

DME Indicators ·-- Navigation Indicators 

Navigation Indicators 

! 

DME Indicators 

i Navigation Indicators 

i Navigation Indicators _J - .. 

DME Indicators 

i Navigation Indicators 

l Navigation .L 

Levell: Line and/or bench test, and Installation. 

-

I 

I 

Page: 12 

Issue Date: 02115/20 II 

Revision: 2 

MFR. LEVEL I 

.! ' 

Bendix/King 3 i 

' 

i Bendix/King 3 ' 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 ' 

I Bendix/King 

I 

3 I 

Bendix/King 3 I 

~=1 Bendix/King 

Bendix/King 

Bendix/King 3 

Edo-Mitchell I 

Collins 3 

Collins 3 I 

- Garmin 

RCA --~ 3_j 

Level2: Line and/or bench test maintenance up to board level. 

Level 3: Line and/or bench test maintenance up to component level, and Installation. 
Area Navigation System 

~ •. --

iKNC~-61 

·----

MODEL ···---·-·· 

---·~-

0 

-----

~-7:_ 

KNS-80 

··---··- - I 

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

I DESCRIPTION I .• i 

- -

I Area Navigation System .. 

Area Navigation System 

Digital Area Navigation System 

Digital Area Navigation System 

Digital Area Navigation System 

Page: 13 

Issue Date: 02115/2011 

Revision: 2 

MFR. LEVEL 

- Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Bendix/King 3 

Collins 3 

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
Encoder 

-~---

t=OI 

~~;;,-2 

MODEL 

, EA-801 

3 

A -------··· 

0 

5350P 

ACK-=-:30 

AK-350 

AT-300 

AR-850 

AAV32 

SSD-12 

---·--

A 

0-XXA 

---

·--'" 

--

--

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

DESCRIPTION 

Encoding Alt 

Encoding Alt 

Encoding Alt -----·· Blind Encoder 

Blind Encoder 

Blind Encoder 

Blind Encoder ---·-- Encoding Alt I - -- Blind Encoder 

-

Page: 14 

Issue Date: 02/15/2011 

Revision: 2 

MFR. LEVEL 

ARC I 

United I 

United ! I 

ACK I I 

Ameriking 1 I 

Terra 3 ' I - 1----

Narco I 

Kollsman I 

TransCal --,-

I --

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Autopilot 

---

___ __ccM ODEL 

200, 200A 

300, 300A 

----··--

A/FD 

-·-··-

-··· 

800, 800A 

Century I, II, I ----------·- IB,lll [""" -·-· 

tCentury 41 ------ I century 2ooo 

iKFC-200 

[Ail~=_l'~c ~{)~ els 

---·····-

··-------

~--~-

-

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

-

I DESCRIPTION 

Autopilot 

I ' Autopilot '--

I Autopilot 

I Autopilot 

------+- Autopilot i ' -------- Autopilot 

Autopilot -1 - Autopilot 

Autopilot 

Autopilot 

Page: 15 

Issue Date: 02115/2011 

Revision: 2 

MFR LEVEL 

ARC I 

ARC 1 

ARC 3 I 

ARC 1 

ARC I 3 

Mitchell 3 

Century l 

Century I 

Bendix/King l 

S-Tec 2 I 

Levell: Line and/or bench test, and Installation. 

Leve12: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAP ABILITY LIST 

Miscellaneous 

MOD EL DESCRIPTION 

'DK-100 I DK-120 I D K-130 I DK-140 Underwater Acoustic Beacon 

'PC-50 I PC-50-1 '--~·· ---- i 50 VA Static Inverter 

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

' 

Page: 16 

Issue Date: 02/15/2011 

Revision: 2 

MFR LEVEL 

"" 

Dukane I 

Flite-Tronics I 3 

I 

! 

Leve12: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
GPS 

~- -=--------

___ 

0 

!GX-60 

!Zoot GPS 

MODEL 

-----

--

---

----~---·----

s 

- -----

- iGNS-150 XL 

-

-- XL 

IGPS-:_165 

iGNS-250 

t_<:;__~-250 

IGNS-430 

GNS-530 

GNC-300 XL 

--

----~---

GX-250 

IGX-300 --·"- -

~~--------

f

GX-500 

KLN-89B 

I(LN-90B 

--

--

-

MAINTENANCE LEVEL: 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

I 

DESCRIPTION I 

I 

I 

GPS -- -

i GPS 

I GPS 

GPS 

GPS 

GPS 

GPS 

GPS - GPS 

GPS/COM 

GPS 

GPS - GPS/COM --I - ----

'· 

GPS 

GPS 

GPS 

GPS 

GPS I 

GPS I 

I 

I 

GPS I 

Page: 17 

Issue Date: 02/15/20 II 

Revision: 2 

MFR I LEVEL 

II Morrow 1 

II Morrow 1 

11 Morrow 1 

II Morrow I 

Garmin l 

Garmin I 

Garmin l 

Garmin l 

Garmin 1 

Garmin 1 -- Garmin 1 

Garmin 1 

Garmin -,~ 

1 

Garmin 1 

Garmin 1 --- Garmin 1 

Garmin 1 -·-· Garrnin 1 

King 1 

King 1 

Levell: Line and/or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

MISC. WEATHER DETECTION 

' ------------'f----=-c~~-~--=-~ 

Page: 18 

Issue Date: 02/15/2011 

Revision: 2 

MFR LEVEL 

Avidyne I 

BFG 3 

I Multi-Function Display -~~~--+--~~-+--~--~ 

Stormscope 

_____ Stormscope BFG 3 " ____ _ 

BFG 3 

BFG 1 

WX-10 /lOA Stormscopc 

WX-500 -------- --t-------;c;Sc-to_r_m_sc-o~p-e ___ -j--==---+-----c:--- -----

BFG 1 

BFG l 

BFG 1 

Insight I 

WX-900 Stormscope 

IWX-950_____ Stormsco-'-p-e ----+--=-=--1--~--l 

IWX-1000 /IOOOA____ Stormscope 

~~ikefinder ---------- ~S~t-or_m_s_c-'op'-e----+---c--c-c--+----cc----l 

Garmin I 

Garmin 

Garmin 

; MX-20 Multi-Function Display 1-- ---c--c~-- IGDL-49 Data Link Unit 

j GDL~69~-------_ -_ -_ ----~-------L__-::_-::_-::_-=D~a~ta~Lccic-n:-k~U;-n:-it---+---:cc--::_~-::_-:;_-___ ~ 

MAINTENANCE LEVEL: 

Level 1: Line and/ or bench test, and Installation. 

Level2: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
i 

I 

' 

Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Page: 19 

Issue Date: 02/15/20 II 

Revision: 2 

High Frequency Communications 

- __ ,.,_ -- I -· 

MODEL I DESCRIPTION MFR LEVELl I ···-·· i 

! ' ----

LHF:950 I HF Bendix/King 3 -------- I 

.J -----

------

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

Leve12: Line and/or bench test maintenance up to board level. 

Level 3: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Navigation Converters 

------,-----=-==-c-c-=-=-c~-----

IVIODEL DESCRIPTION f-----'-

~ 

KN-72 Navigation Converter ------- . """. 

KN-77 Navigation Converter 

1]3:445 Navigation Converter 

MAINTENANCE LEVEL: 

Levell: Line and/or bench test, and Installation. 

Page:20 

Issue Date: 02/15/2011 

Revision: 2 

[ IVIFR I LEVEL I 

Bendix/King 3 ! I Bendix/King 3 

L ARC 3 

Level2: Line and/or bench test maintenance up to board level. 

Leve13: Line and/or bench test maintenance up to component level, and Installation. 
Avionics Masters, Inc. 

REPAIR STATION CAPABILITY LIST 

Page:21 

Issue Date: 02/15/20 II 

Revision: 2 

Loran C 

MFR LEVEL 

- [I<':N-88 LoranCRNAV King 3 

MAINTENANCE LEVEL: 

Level 1: Line and/or bench test, and Installation. 

Leve12: Line and/or bench test maintenance up to board level. 

Level3: Line and/or bench test maintenance up to component level, and Installation. 
1. Approving Nattonal Aviation 2. 3. Form Tr-acking Number: 

A uthorityiC4untry: AUTHORIZED RELEASE CERTIFICATE 11078-13 

FAA/UNJtED STATES FAA Fonn 8130-3, AIRWORTHINESS APPROVAL TAG 

·, \ 4. Organization Name and Address: 5. Work Order/Contract/Invoice \ / J AVionics Masters, Inc. 1001 West Cypress Creek Road, Suite 309, Fort Lauderdale, Florida 33309 Number: 

80711 

6. Ifein: 7. Description: 8. Part Number: 9. Eligibilit~:* I 0. Quantitv: II. SeriaiJBatch Number: 12. Status/\Vork: 

Bendix/King 

KG-102A Directional Gyro 060-0015-00 N/A 1 X32301 REPAIRED 

13. Remarks: 

The component identified hereon was tested and inspected in accordance with current regulations of the Federal Aviation Administration and manufactures maintenance information 

and is approved for return to service. Pertinent details of repair are on file at this facility. 

Manual Number: 006-5111-03 Rev. 3, Oct. 1976. 

14. Certifies the items identified above were manufactured in conformity to: 19. [J 14 CFR 43.9 Return to Service 0 Other regulation specified in Block 13 

0 Approved design data and are in condition for safe operation. Certifies that unless otherwise specified in block 13, tbe work identified in Block 12 

0 Non-approved design data specified in Block 13. and described in Block 13 was accomplished in accordance with Title 14, Code of 

Federal Regulations, part 43 and in respect to that work, the items are approved for 

~service. 

15. Authorize_«;~ Signature: 16. Approval/Authorization No.: ruthorize~~ _, 

---r:t""t. Approval/Certificate No.: 

N/A N/A -- VIMR095K 

17. Name (Typed or Printed): 18. Date (m/d/y): · 22. """'", • yped or Printed): 23. Date (m/d/y): 

N/A N/A Charles L. Hunt Jr. 

12/2212011 

User/Installer Responsibilities 

It is important to understand that the existence of this document alone does not automatically constitute authority to install the part/component/assembly. 

Where the user/installer performs work in accordance with the national regulations uf an airworthiness aut.hority different than the airworthiness authority of the country specified in 

Block 1~ it is essential that the userlinstaller ensures that his/her airworthiness authority accepts parts/components/assemblies from the airworthiness authority of the country specified 

in Blockl. 

Statements in Blocks 14 and te installation certification. In all cases, aircraft maintenance records must contain an installation certification issued in accordance with the 

national regulations by the u CARDEl.S 100-783-0399 

C) e the aircraft may be flown. 

FAA Form 8130-3 (6-01) 0 *Installer must cross-check eligibility with applicable technical data. ~;;; NSN: 0052-00-012-9005 

:G 

·~z s: -lm z ..... 
Reg. No. SALES Work uroer i'<o. llU/i'S --

AVIONICS MASTERS, INC. 

FAA APPROVED REPAIR STATION VIMR095K 

WORK ORDER 

1001 West Cypress Creek Road 

Suite 309 

Ft. Lauderdale, Florida 33309 

Date: 12/01/ll AirCarrier: 0 Part91: 0 Total Pages _____3;{ 

AIC Make SALES ::____ __ AJC Model SALES AIC Serial No. SALES Hobbs/time ------------ ------------

Ov.vner/ Agent Avionics Masters, Inc. Telephone (954)491-2580 

Address ~1~0_:_0_1 _W__:C.::.Yo_Pr:..:e_:_ss:..:C_r_e_ek_R_d_:_.,_s_u_ite_30_9 ________ City _:_F:..:t:..:. L::.•:..:u~d--er:..:d_a_le _____ State. FL 

_"...:_....,,__,....;==o;;p=====...,===..,. Pilot December Shop W.O. ,.,====~ 

2 

3 

7 

8 

9 

10 

11 

12 

item Description 

Method of Payment 

II REPAIRAUTHORIZATION: 

I hereby authorized the above repair work to be done along with the nee-

. essary materiaL An express mechanic's lien is hereby acknowledged on 

II above aircraft or equipment to secure the amount of repairs thereto. 

!',LL EQUIPMENT NOT PICKED UP WITHIN 90 DAYS WILL BEl fOM£ PROPERTY OF AVIONICS MASTER, INC. lfthis is an A.O.G. 

(situation, there will be an additional A.O.G. fee. 

- --------------------------

Signature of Owner/Agent Date 

Insp. Shipping 

Outside 

GOVERNMENT 

EX~ IT 

\:::-

MAINTENANCE RELEASE: I 

The component and/or appliance identified above wo•; I 

repaired and/or inspected ln accordance vvith currcn! 

regulations of the Federal Aviation Administration ar..C 

is approved for return to service. Pertinent details nf the 

re:pair are on file at this repair station under thts \Vod" 

Date. 

Representative 
Reg. No. SALES Work Un:ler l'W. IHI f"('j 

Oate: 12/01/11 ---~ 

A/C Make SALES 

==---

AVIONICS MASTERS, INC. 

FAA APPROVED REP AIR STATION VIMR095K 

WORK ORDER 

1001 West Cypress Creek Road 

Suite 309 

Ft. Lauderdale, Florida 33309 

Air Carrier: 0 Part 91: 0 

A/C Model SALES A/C Serial No. SALES --------- -----~ 

Total Pages ~ -~ -<,':>L -~·---·--------

Hobbs/time 

Owner/ Agent Avionics Masters, Inc. Telephone (954)491-2580 ·---------

Address 1001 W Cypress Creek Rd., Suite 309 City Ft. Lauderdale ~~~~------~-----------------

State FL 

16 

17 

18 

19 

20 

22 

24 

Item Description Insp. Shipping 

Outside 

Total Labor@ __ _ 

Total Parts 

!Method of Payment Credit Card 

ALL WORK IS C . 0 D UNLESS PRIOR ARRANGEMENTS ARE MADE 

REPAIR AUTHORIZATION: MAINTENANCE RELEASE: 

I hereby authorized the above repair work to be done along with the nee- The component and/or appliance identified above \Vas 

essary material. An express mechanic's lien is hereby acknowledged on repaired and/or inspected in accordance with current 

above aircraft or equipment to secure the amount of repairs thereto. regulations of the Federal Aviation Administration and 

ALL EQUIPMENT NOT PICKED UP WITHIN 90 DAYS WILL BE- is approved for return to service. Pertinent details of theCOME PROPERTY OF AVIONICS MASTER INC. If this is an A.O.G. repair are on file at this repair station under this Work 

situation, there will be an additional A.O.G. fee. Order and Date. 

' 

Signature of Owner/Agent Date 

Fm·m ~000 Re"· 3 05/01/1008 
U.S. Deportment 

of Transportation 

Federal Aviation 

Administration 

MAY 2 3 2012 

South Florida 

Flight Standards District Office 19 

CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

File No. 2012S0190209 

Mr. Vincent Sortino 

Accountable Manager 

Avionics Masters, Inc. 

1 001 West Cypress Creek Road 

Suite #309 

Fort Lauderdale, Florida 33309 

Dear Mr. Sortino: 

2895 SW 145(11 Avenue, Suite 120 

Miramar, FL 33027 

Dming a visit to Avionics Masters, Inc. on May 14,2012, inspectors from this oftlce 

observed a Directional Gyro, Manufactured by Bendix/King, Model KGI02A, Serial 

Number X32301, under Work Order No. 8078, Item 13. An FAA Form 8130-3 was issued 

for the Return-to-Service. This part is not listed on Avionics Masters, Inc. Capability List. 

Therefore, Avionics Masters, Inc. is not authorized to Return-to-Service this article. 

This letter is to inform you that this matter is under investigation by the Federal Aviation 

Administration (FAA). We would appreciate receiving any evidence or statements you 

might care to make regarding this matter within five ( 5) days of receipt of this letter. Any 

discussion or written statements furnished by you will be given consideration in our 

investigation. If we do not hear from you within the specified time, our report will be 

processed without the benefit of your statement. 

Sincerely. 

~s Roger A McGlen 

Principal Avionics Inspector 

GOVERNMENT 

EXHIBIT 

p 
AVIONICS MASTERS 

Date: May 30, 2012 

From: Vincent Sortino 

Charles L. Hunt, Jr. 

To: Mr. Roger McGien 

1001 W. Cypress Creek Road, Suite #309 

Ft Lauderdale, FL 33309 

Phone: (954) 491-2580 Fax: (954) 491-5279 

Principal Avionics Inspector 

FAA-South Florida FSDO Office 19 

2895 SW 145th Avenue, Ste. 120 

Miramar, Florida 33027 

Re: KG-1 02A S/N X32301 Return to Service- Case No 201280190209 

Dear Mr. McGien, 

In reference to your letter on May 23, 2012, Case No 2012S0190209, regarding 

Avionics Masters, Inc returning a KG-102A HSI Remote Gyro to service; we 

reviewed our capabilities list and discovered, as you did, that this unit is not on 

our list. We perform service to KCS-55A systems on aircrafts in connection with 

our limited airframe rating when repairing auto pilot systems (for which we are 

rated). And, indeed the HSI component KI-525A is listed on our capabilities list. 

We normally have these units contracted out for service to one of our contractors 

who are set up for gyros such as Triumph Instruments. We then add their 8130 to 

our work order. In this case the above mentioned KG-102A was inadvertently 

tagged as part of a list of equipment being installed in an aircraft. Normally, this 

unit would have had a final check and certification from Triumph Instruments 

before being installed in the aircraft for service. We are instituting a procedure 

where all equipment will be grouped in the stock room and the appropriate 

certifications reviewed before the equipment is routed to the shop for a particular 

installation. This will avoid this type of situation in the future. 

If you have any further questions regarding this matter please feel free to contact 

us at any time. 

Regards,--- , __ , / ---- / / .//'_ / ~.___----·-

/ ~~/~/ 

C-6,aff?s(H~~t. ~; Chief Inspector 

Avionics Masters, Inc 

FAA CRS VIMR095K 

Vincent Sortino 

Accountable Manager 

~GOVERNMENT 

i EXHIBIT 

j 6--
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;friumph Instruments - ,. Ft. Lauderdale ~ A Triumph Group Company 

,-il.mph Instruments-Ft. Lauderdale 

.J352 N.W. 21 Terrace 

· Ft. Lauderdale Executive Airport 

Ft. lauderdale, FL 33309 

800/422-4559 OR9641772-4559 

FAA CRS NO. WI4R623M 

Sold To: (l900S7J 

SOUTHERN AERO AVIONICS 

1903 NW 46 STREET 

TAMARAC, FL 33309-3&22 

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Phone# 9548037543 Fax# 9544914981 

S~ECIAL INSTRUCTIONS: 

//. 11 h tf· ;q;;WORK ORDER FORM 100 · (L/7'-V \ (y/ WORK ORDER# 233310 

Date In Jun 27,2012 

Work Req BENCH CHECK AND ADVISE 

Cust PO IU,0-§.3.1. ... 

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Serial# 

Model 

Ship To: 

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SOUTHERN AERO AVIONICS 

1805 NW 51 PLACE 

HANGAR#3 

FT. LAUDERDALE, FL 33309 

Attn: CHAD HUNT 

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Mfgr KING 

Dept# FWR 

ADVISE COST TO RE~AIR. ADVISE IF ANY AD'S APPLY. 

HIDDEN DAMAGE: 

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DAT:e: CERTIFICAT:e: 

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EXHIBIT 

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' Ft Lauderdale Executive Airport 

Ft Lauderdale, FL 33309 

954/772-4559 

F.A.A. No. WI4R623M 

TO: 

SOUTHERN AERO AVIONICS 

1805 NW 51 PLACE 

HANGAR#3 

FT. LAUDERDALE, FL 33309 

Contact CHAD HUNT Phone 

PART NO :060-0015-00 

SERIAL NO :32301 

Special OVERHAULED TO MFG SPECS 

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Remarks 

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10/01/07 2150.3B 

available to the Government. Legal counsel consults the Financial Litigation Staff of the 

Executive Office for the United States Attorneys in the Department of Justice before referring 

debts less than $2,500. To refer matters to the Justice Department, the FAA must fill out and 

send a Claims Collection Litigation Report and a signed Certificate of Indebtedness. 

j. Payments received by Legal Counsel. If debtors send checks to legal counsel's office 

rather than the accounting office, legal counsel sends the checks to the accounting office 

immediately. The Assistant Chief Counsel for Enforcement and each Regional Counsel appoints 

one individual to be the principal contact responsible for collecting any checks sent to the legal 

office and for transmitting those checks to the appropriate accounting office. 

33. Violations of Foreign Regulations by U.S. Citizens or Companies. Legal counsel for the 

region with geographical responsibility for the country filing the complaint processes a legal 

enforcement case for a violation of a foreign regulation by a U.S. citizen or company. Atler the 

completion of the case, legal counsel advises the foreign aviation authority through the 

Department of State of the action taken, except in the case of Canada, the contact is made 

directly with Transport Canada. If the program office does not refer the case to the legal office 

for handling, the program office advises the foreign aviation authority. 

34. Violations of FAA Regulations by Foreign Persons. 

a. General. Legal counsel for the region with geographic responsibility for the 

investigation processes a case against a foreign person who violates the Federal Aviation 

Regulations. Legal counsel takes legal enforcement action against an airman who commits a 

violation while exercising the privileges of his or her FAA airman certificate, a foreign 

individual who commits a passenger violation, or a foreign air carrier operating under 14 C.F.R. 

part 129. All other violations committed by foreign persons, except Canadian persons, are 

referred to the appropriate foreign aviation authority through the Department of State. Violations 

committed by Canadian persons, for whom legal enforcement action is not taken, are referred 

directly to Transport Canada. 

b. Preparation of Referral to Foreign Authority. To refer a case to another foreign 

aviation authority, FAA legal counsel prepares a letter that includes a brief factual summary of 

the violation, a statement of the regulations violated, and a request that Transport Canada or 

other foreign aviation authority advise the FAA of any action that it takes regarding the matter. 

FAA legal counsel sends a copy of the EIR with the referral letter. 

c. Notification of Legal Enforcement Action Taken. FAA legal counsel advises 

Transport Canada directly or other foreign aviation authority through the U.S. Foreign Service 

Post, if appropriate, of the final action taken in a legal enforcement case against a foreign person 

for violating the Federal Aviation Regulations. 

6-49 

~GOVERNMENT 

iii EXHIBIT i l. 
10/01/07 2150.38 

Chapter 7. Sanction Guidance Policies 

1. Purpose. This chapter provides the FAA's policies for determining an appropriate sanction 

once FAA enforcement personnel decide that legal enforcement action is appropriate. This chapter 

contains the general policy the FAA intends to apply in selecting the types of sanctions, ranges of 

sanctions within those types, and specific sanction amounts to impose in legal enforcement actions 

for typical violations of the FAA's statute and regulations. This guidance covers the parameters 

both for selecting sanctions and for modifYing sanctions during the informal procedures. The 

guidance in this chapter is applied in adjudications under 49 U.S.C §§ 44106,44709, 447!0, 

44726,44924,46111,46301, and 701!5. Hazardous materials sanction guidance and policies are 

addressed in Appendix C 

2. General Guidelines. 

a. Certificate Suspension Action and Civil Penalty Action: Sanctions for Punitive and 

Deterrent Purposes. 

( 1) GeneraL If a certificate holder improperly exercises the privileges of a certificate, a 

natural consequence of that act is to lose the privileges for a period of time commensurate with 

the violation. Balanced against this principle, however, the FAA considers the adverse impact 

that a certificate suspension could have on the public. Thus, the agency generally suspends the 

certificates of individual certificate holders for violations. However, the FAA usually takes civil 

penalty action against air carriers and airports because such actions do not disrupt service, which 

may adversely affect the public. Nevertheless, when the FAA determines that safety 

considerations warrant it, the agency will suspend the certificate of any type of certificate holder. 

In no case will the FAA take civil penalty action alone when remedial legal action is necessary 

or appropriate. 

(2) Use of both punitive certificate action and civil penalty action for the same 

violations. The FAA generally does not take civil penalty action and punitive certificate action 

(that is, certificate suspension for a fixed period of time) against a certificate holder for the same 

conduct. If unusual circumstances warrant deviation from this practice, legal counsel consult 

with the Assistant Chief Counsel for Enforcement (AGC-300) before initiating the actions. 

{3) Change in type of proposed sanction. The initial enforcement action reflects the 

agency's best assessment of the appropriate sanction for the violations alleged. After initiating 

the action, legal counsel ordinarily does not change the type of sanction unless additional facts or 

circumstances are presented to the FAA that warrant a change. If the action was coordinated 

under chapter 6, paragraph 3, with AGC-300 before initiation, then legal counsel coordinates any 

change in the type of sanction with AGC-300 before making the change. 

b. Legal Sanctions for Remedial Purposes. 

(!) Indefinite certificate suspension pending compliance or demonstration of 

qualification. Suspension action is appropriate where there is a need temporarily to 

7-1 
10/01/07 2150.38 

suspend the privileges of the certificate or rating pending demonstration of qualification or 

compliance with statutory or regulatory requirements. FAA generally uses remedial suspension 

when an individual does not voluntarily surrender his or her certificate pending reexamination. 

See chapter 5. 

(2) Certificate revocation- general. The FAA revokes a certificate when a certificate 

holder lacks the qualifications to hold the certificate. The certificate holder's continued exercise 

of the privileges of the certificate in such circumstances would be contrary to safety in air 

commerce or air transportation and the public interest. Revocation is appropriate whenever a 

certificate holder's conduct demonstrates a lack of the technical proficiency or a lack of the 

degree of care, judgment, or responsibility, required of the holder of such a certificate. Orders of 

revocation are issued on an emergency basis when the certificate holder lacks qualification and is 

reasonably able as a practical matter to exercise the privileges of the certificate. Legal counsel 

does not allege a lack of qualifications to avoid dismissal of charges under 49 C.F .R. § 821.33, 

the NTSB 's stale complaint rule. 

(3) Certificate revocation- individuals. The FAA generally revokes an individual's 

certificate or rating whenever he or she demonstrates a lack of willingness or ability to comply 

consistently with statutory or regulatory requirements. A lack of willingness or ability to comply 

may be demonstrated by such things as repeated or deliberate violations or by violations that 

involve grossly careless or reckless conduct. Even a single violation may be sufficient to warrant 

a conclusion an individual lacks qualifications. The FAA ordinarily revokes all certificates of a 

person who commits a violation involving intentional falsification. 

(4) Certificate revocation- entities. Revocation is normally appropriate when a 

certificate-holding entity deliberately or flagrantly violates the statute or regulations or falsifies 

records. Revocation also is generally appropriate when the certificate holder has committed the 

same or similar violations in the recent past demonstrating a lack of qualification, or when the 

certificate holder no longer has, and does not obtain in a reasonable time, the personnel or 

equipment to conduct its operation in full compliance with statutory and regulatory requirements. 

(5) Mandatory certificate revocation. Under49 U.S.C. § 44710, the FAA is required to 

revoke the certificates of any airman who has been convicted of violating certain federal or state 

statutes relating to a controlled substance when an airplane was used in the commission of the 

offense and the airman served as an airman, or was aboard the aircraft, in connection with 

commission of the offense or the facilitation of the commission of the offense. Even when there 

has been no conviction, revocation is required when an airman has knowingly carried out an 

activity punishable under these criminal statutes. The Administrator may waive the revocation if 

a law enforcement officer requests the waiver and the Administrator decides the waiver will 

facilitate law enforcement purposes. See 49 U.S.C. § 44710(f). Under 49 U.S.C. § 44106, the 

FAA also must revoke the registration certificate of any airplane used in the commission of such 

an offense when the use was permitted by the owner of the aircraft with knowledge that it would 

be used for such purpose. Under 49 U.S.C. § 44726, the FAA must revoke the certificates of any 

certificate holder or an individual who has a controlling or ownership interest in the holder who 

was convicted of a violation of federal law relating to the installation, production, repair, or sale 

of a counterfeit or fraudulently-represented aviation part or material or knowingly, and with the 

7-2 
10/01/07 2150.38 

intent to defraud. carried out or facilitated an activity punishable under such a law. The 

Administrator may waive that sanction to facilitate law enforcement purposes or amend, rather 

than revoke, a certificate under certain circumstances. See 49 U.S.C. §§ 44726(1) and (g). 

(6) Mandatory certificate action for security concerns. Under 49 U .S.C. § 46111, the 

Administrator is required to issue an order amending, modifying, suspending, or revoking any 

FAA-issued certificate if the Administrator is notified by the Under Secretary of Border and 

Transportation Security (BTS) of the Department of Homeland Security (DHS) that the 

certificate holder poses, or is suspected of posing, a risk of air piracy or terrorism or a threat to 

airline or passenger safety. Under 49 U.S.C. § 44924, the Administrator is required, at the 

request of the Under Secretary of BTS, to suspend or revoke foreign repair station certificates in 

connection with security audits. 

3. Applicability and Exclusions. The sanction guidance table (table) in Appendix B provides 

types of sanctions and general ranges of sanction amounts for violations of 49 U.S.C. subtitle VII 

and 14 C.F.R. parts l.-199 and 49 U.S.C. subtitle IX, chapter 701 and 14 C.F.R. chapter III. 

Once the agency has determined that legal enforcement action is warranted for a violation, FAA 

enforcement personnel use the table and paragraph 4 of this chapter, as well as any other 

sanction guidance in this order, to determine a proposed sanction. The matters described in 

chapter 7, subparagraphs 3a.-d. arc some types of agency action that fall outside the scope of 

paragraph 3 and the table. 

a. Decisions to Take Administrative Action (Warning Notices or Letters of 

Correction). An administrative action does not constitute either a formal adjudication of the 

incident or a finding of violation. For that reason, FAA investigative personnel do not propose a 

sanction using the table. 

b. The FAA's Exercise of Prosecutorial Discretion. The decision whether to prosecute a 

particular case is based on a review of the evidence and relevant policy and litigation 

considerations. The agency exercises broad discretion in both the initial decision to bring a legal 

enforcement action, and in any later determination to compromise or settle a case based on 

various considerations. The FAA's discretion in these areas is absolute and presumed to be 

immune from review. Heckler v. Cheney, 470 U.S. 821, 831 (1985). 

c. Hazardous Materials Violations. Actions involving violations of the federal hazardous 

materials transportation law, 49 U.S.C. chapter 51, or the Department of Transportation's 

Hazardous Materials Regulations, 49 C.F.R. parts l 06 through 185. Enforcement sanction 

guidance for these violations is found in Appendix C. 

d. Violations by Members of the U.S. Armed Forces. The FAA is required to forward 

reports of these violations to the Secretary of the department concerned under 49 U.S. C. 

§ 4610l(b), whenever the violator is acting in the performance of official duties. The FAA, 

however, takes remedial action in addition to referring a report when the violator, whether or not 

7-3 
10/01107 2150.38 

acting in the performance of official military duties, holds an FAA certificate, and the violator's 

qualifications are at issue. The FAA may take punitive action against a member of the U.S. 

Armed Forces for a violation committed when the member is not performing official duties. 

4. Mitigating or Aggravating Factors and Elements. The factors in chapter 7, subparagraphs 

4.a. through m. have been developed over years of policy making and case adjudication. They 

have proven useful and appropriate for determining the seriousness of a violation and for 

selecting an appropriate sanction. Elements for evaluating and weighing each factor are also 

described. These factors and elements provide a framework for determining sanctions for 

violations specifically listed in the table as well as those not specifically listed. All the factors 

and elements, however, may not apply to each violation. Only those factors and elements that 

are relevant to a violation are considered in determining a sanction for the violation. This list of 

factors and elements is not intended to be exhaustive; other factors may be relevant as welL 

a. Nature of the Violation. Three elements define the nature of a violation: first. whether 

the violation was operational or non-operational; second, whether the violation involved careless 

or reckless conduct; and third, whether the violation involved any special aggravating or 

mitigating factors. 

(I) Individuals. When an individual who holds a certificate improperly exercises the 

privileges of that certificate, the natural consequence of that act should be loss of privileges for a 

period of time commensurate with the violation. The FAA, therefore, primarily uses certificate 

actions to enforce operational regulations against individuals who hold certificates. The 

potential adverse impact that certificate action may have on an individual's livelihood does not 

alter this principle. Non-operational violations may warrant a different type of sanction. 

(2) Entities. The FAA ordinarily takes civil penalty action against a certificate-holding 

entity (for example, an air carrier) when it determines there would be a substantial adverse 

impact on the public interest from disrupted service by that certificate holder and the impact is 

not outweighed by safety considerations. Even when a substantial adverse impact would occur, 

when there is a need to prevent continuing violations or other egregious conduct by any 

certificate holder, when any certificate holder lacks qualification, or there is a reasonable basis to 

question the qualifications of any certificate holder, the FAA takes remedial action, for example, 

revocation or indefinite suspension, as necessary. 

(3) Careless or reckless conduct Violations that involve careless or reckless conduct in 

violation of 14 C.F.R. § 91.13 may warrant more severe sanctions. Carelessness connotes 

conduct that falls below the standard of care or prudence expected of a reasonable person, or 

holder of the relevant certificate, acting under the same or similar circumstances. Recklessness 

connotes conduct that demonstrates a gross, or even callous or flagrant, disregard for safety. 

Aircraft operations that do not otherwise result in a violation of a specific regulation should be 

evaluated in light of these standards to determine whether they constitute careless or reckless 

operations in violation of 14 C.F.R. § 9Ll3. When a person operates an aircraft in violation of a 

specific regulation other than 14 C.F.R. § 9!.13, however, that violation constitutes a careless or 

reckless operation in and of itself In these cases, the misconduct may also result in a violation 

of 14 C.F .R. § 9l.I 3 if it actually or potentially endangers the lives or property of others. 

7-4 
10/01/07 2150.38 

When calculating the amount of sanction based on this factor, a distinction generally is drawn 

between instances where 14 CF.R. § 9l.l3 is an independent violation and those where it is 

residual to another violation. When a 14 CF.R. § 9Ll3 violation is residual only, a higher 

sanction generally is not warranted unless the conduct is also reckless. 

b. Whether the Violation was Inadvertent and Not Deliberate, I fa violation is 

deliberate or not inadvertent, a sanction at the upper end of the range or exceeding the range for 

that type of violation generally is appropriate. A deliberate violation generally warrants a 

sanction that is more severe than one that is just not inadvertent 

(I) Not deliberate. This element means a lack of the degree of deliberation found in 

intentional misconduct Deliberate or intentional misconduct is an aggravating circumstance and 

includes deliberate conduct that leads to a violation as well as circumstances indicating intent to 

commit a violation. 

(2) Inadvertence. An act is inadvertent when it is the result of both inattention and lack 

of purposeful choice. For example, an inadvertent act occurs when a pilot flies at an incorrect 

altitude because he or she misread the aircraft's instruments; however, it is not an inadvertent act 

when a pilot flies at an incorrect altitude as a result of choosing not to consult the aircraft's 

instruments or choosing not to use other available means to verifY altitude. The test to be applied 

is whether the conduct, not the factual or legal consequences, is inadvertent and unintended. 

Ferguson v. National Transportation Safety Board, 678 F.2d 821, 828-829 (9th Cir. 1982). 

c. Certificate Holder's Level of Experience. 

(I) Level of experience refers primarily to the type of certificate and ratings held (for 

example, student, private, commercial, airline transport pilot, or certified flight instructor), and 

the number of hours flown, by the certificate holder. Certificate holders with greater levels of 

experience may be held to a higher standard. Thus, for example, commercial pilots may be held 

to a higher standard than private pilots and airline transport pilots may be held to an even higher 

standard than commercial pilots. 

(2) In determining an appropriate sanction, the FAA may consider the extent to which 

the certificate holder's action deviated from the degree of care and diligence normally expected 

of a person with the certificate holder's level of experience. A significant deviation from the 

degree of care and diligence expected of the holder of that certificate may warrant a more 

aggravated sanction. 

d. Attitude of the Violator. 

(!) A good compliance attitude is the norm and does not warrant a reduction in sanction. 

A prior violation history may suggest that a person has a poor compliance disposition, which is 

an aggravating factor. Furthermore, a person who commits an act or omission contrary to 

statutory or regulatory requirements after receiving notice through a prior administrative action 

or counseling that such conduct is in violation of those requirements might well be regarded as 

having a poor compliance disposition. In evaluating compliance disposition, the FAA does not 

7-5 
10/01/07 2150.38 

view an alleged violator as having a poor attitude because the alleged violator fails to respond to 

a letter of investigation, chooses to be represented by counsel, or contests the violation. 

(2) In assessing the attitude of an alleged violator, the FAA may consider the declaration 

of an emergency to air traffic control. When an emergency is genuine and not of the person's 

own making, the emergency is exculpatory under 14 C.F.R. § 9l.3(b). However, this situation is 

distinct from the situation where a declaration of emergency is not exculpatory but is a factor that 

might be appropriate to consider in determining sanction. In emergency situations, the FAA 

views declaring an emergency to air traffic control as a sign of good judgment and a constructive 

attitude. When an emergency is of a person's own making, that person's declaration of an 

emergency may be considered mitigating in determining the sanction to be imposed for any 

violations committed, in much the same way it is considered mitigating if a person voluntarily 

reports a violation. 

e. Degree of Hazard. 

(I) The degree of hazard may be increased as a result of the interplay of the operational 

environment (for example, weather conditions, congested vs. sparsely populated areas) and the 

nature of the threat to safety (to the life or property of another, including those in the aircraft 

being operated, to other aircraft, or to persons or property on the surface) that the misconduct 

presents. The safety threat is based on the reasonably foreseeable consequences of the 

misconduct. For example, operating 500 feet below the minimum altitude poses a greater hazard 

than operating I 00 feet below. Similarly, if an aircraft operator fails to comply with an 

airworthiness directive by operating I 0 hours past a required inspection, the degree of hazard is 

probably not as great as when the aircraft is operated 100 hours beyond the required. And it is 

not mitigating when a violation does not result in actual harm; that is simply fortuitous. 

(2) The sanction ranges reflect the degree of danger normally inherent in an average 

violation of a regulation, without aggravating circumstances. As discussed in chapter 7, 

subparagraph 5.b., an increase in the degree of hazard may form the basis for exceeding the 

sanction ranges. For example, the range for an unauthorized low flight does not assume extreme 

departures from required altitudes, for example, flying an airplane over a crowded assembly of 

persons at 50 feet 

f. Action Taken by Employer or Other Authority. This factor ordinarily involves the 

following elements: whether the alleged violator's employer has taken disciplinary action and 

whether criminal prosecution is involved. 

(I) Employment discipline. Where the violation would normally call for a certain type 

of enforcement action, the FAA takes that action regardless of any action taken by the violator's 

employer. Generally, the FAA does not credit an employer's disciplinary action toward a period 

of suspension the FAA imposes against the violator's certificate because of the different 

purposes of government-ordered, as contrasted with employer-ordered, actions. 

(2) Criminal prosecution. When arising out of the same conduct, local, state, or federal 

prosecution does not preclude the FAA from taking appropriate remedial enforcement action; nor 

7-6 
10/01/07 2150.38 

does it preclude the FAA from taking appropriate punitive enforcement action. For cases where 

federal, state, or local authorities prosecute criminally, the FAA generally does take remedial 

enforcement action if that is warranted despite the criminal prosecution. However, the FAA does 

not generally take punitive legal enforcement action for the same conduct, unless it believes the 

criminal sanctions arc not sufficient to provide an adequate deterrent for future violations by the 

violator and others similarly situated, or when the FAA wants to establish a violation history 

record. If the FAA decides to proceed with a punitive civil enforcement action in addition to the 

criminal prosecution, it generally considers the criminal penalties incurred in those proceedings 

in determining the appropriate amount of sanction to be sought in the FAA's punitive 

enforcement action. 

g. Use of a Certificate. This factor relates to the nature or kind of activity or operation 

involved at the time the violation was committed. Whether the certificate holder was engaged in 

student, private, commercial, or airline activity bears on the severity of the sanction. Air carriers 

are held to the highest standard of care. Likewise, personnel engaged in air transportation are 

held to the highest safety standard. 

h. Violation History. 

(l) A violation-free history is the expected norm, not the exception and, therefore, is not 

a mitigating factor. Sanction ranges in the table generally represent the normal range of sanction 

for a single, first-time, inadvertent violation. Given the expected norrn, a prior violation record 

can be evidence of a poor compliance disposition or of a pattern of disregard for the FAA's 

regulations, which are aggravating factors. As a result, a violation history can justify imposing a 

sanction at the higher end of the normal range or a sanction beyond the normal range. It might 

also justify revocation rather than suspension if the pattern of violation reflects a lack of 

qualification. In addition, a violation history might justify a certificate suspension if previously 

issued civil penalties have not produced the desired deterrent effect. In deciding whether a 

violation history justifies aggravating the sanction or changing the usual type of sanction, the 

FAA considers the length of time that has elapsed between violations, whether the violations 

involved the same or similar regulations, and whether the violations are factually similar. 

(2) The following actions constitute violation history when they involve regulatory 

violations and become final: orders of amendment, modification, suspension, or revocation of an 

FAA certificate; orders assessing a civil penalty; findings of violation contained in a consent 

order, order of compliance or denial; and findings of violation made by a federal court. In 

addition, a party may agree as part of a settlement that the FAA may consider alleged violations 

as findings of violation for future sanction determinations. 

i. Decisional Law. Decisions of the FAA decisionmaker represent the FAA 

Administrator's position on issues arising in civil penalty assessment actions, including issues 

regarding sanctions. The policy in this order also represents the Administrator's position on 

sanctions in legal enforcement actions. To the extent that this document conflicts with FAA 

decisionmaker decisions published before this document's issuance, the sanction guidance policy 

in this order supersedes those decisions. However, FAA decisionmaker decisions published after 

7-7 
10/01/07 2150.38 

the issuance of this document that conflict with the policy in this order supersede this document 

and are controlling. 

j. Ability to Absorb Sanction. Sanctions should be deterrent. While punitive sanctions 

should not be unduly harsh, they should be substantial enough to prevent violators from profiting 

from their violations, that is, the sanction should be high enough to remove any profit incentive 

for violations. Penalties should never be permitted to be a cost of doing business. Air carriers, 

in particular, are required by law to have the financial wherewithal to operate according to 

established safety standards. While the FAA does not allow financial circumstances to excuse 

any violation, it does consider a carrier's size and financial strength in choosing the appropriate 

sanction amount. The difference in the penalties fixed in the law for large and small business 

concerns recognizes this fact. A civil penalty that may be a mere cost ofdoing business to a 

major air carrier might compel a small air carrier to go out of business. Therefore, the FAA uses 

air carrier size as one means of ensuring a relatively equivalent deterrent effect on each air 

carrier that violates the same FAA regulation. The resulting classification of air carriers by size 

and ranges of civil penalties arc set forth in part one of the table. For all entities and individuals, 

the FAA considers ability to pay a civil penalty and the effect a civil penalty will have on a 

person's ability to continue in business to the extent it knows such information. 

k. Consistency of Sanction. One of the agency's goals is to achieve relative consistency in 

imposing similar sanctions for similar violations. The FAA pursues this objective to assure 

fairness and so the sanction's impact has an equivalent degree of deterrent or disciplinary value 

to others similarly situated. This goal may not always be achieved, however, because of the 

inherently subjective nature of the exercise of judgment in setting sanctions. 

I. Whether the Violation was Reported Voluntarily. 

(I) The FAA has programs that allow persons to report voluntarily apparent violations 

and receive lesser enforcement action provided certain criteria are met. These programs include 

the aviation safety reporting program, the voluntary disclosure reporting program, and the 

aviation safety action program. Besides these programs, the FAA may grant special enforcement 

consideration under certain circumstances to a person who, incident to his or her report of 

another's violations, voluntarily discloses his or her own participation in the same or related 

violations. This special enforcement consideration may range from mitigating the sanction to 

determining that no enforcement action is required. 

(2) If a person is not covered under one of these programs but nonetheless voluntarily 

reports an apparent violation to the FAA before the FAA discovers it, takes immediate action to 

correct the noncompliance, and works with the FAA on steps to preclude recurrence of the 

apparent violation, the FAA may consider such actions in mitigating the sanction for the 

violation. 

m. Corrective Action. The FAA considers corrective action a mitigating factor in 

determining sanction provided the corrective action exceeds the minimum regulatory or statutory 

requirements. The amount of credit given in setting a sanction depends on the extent and timing 

of the corrective action, that is, how extensive was the corrective action and how quickly was it 

taken. Implementing new procedures that are above those required under the FAA's regulations 

7-8 
10/01/07 2150.38 

to prevent future violations ordinarily is considered a mitigating factor in determining an 

appropriate sanction. Corrective action taken after the alleged violator first becomes aware of a 

deficiency but before FAA discovery of the violation ordinarily warrants greater mitigation than 

corrective action that is taken only after the alleged violator receives notice of the FAA's 

enforcement action. Corrective action taken by an alleged violator that simply brings that person 

into compliance with the statutory or regulatory requirements is not considered in mitigation of 

sanction. To mitigate a sanction based on such corrective action would put at an economic 

disadvantage competitors who have expended the resources necessary to maintain compliance. 

5. Use of the Table of Sanctions. 

a. General. Sanction detem1inations are not accomplished through a strict mathematical 

formula; rather, sanction determinations result from a judgment of where a case lies along a 

spectrum of gravity. Ultimately, the circumstances of each case arc evaluated in terms of the 

needs of safety and the public interest. 

b. Single, First-time, Inadvertent Violations. 

(I) Part II of the table specifies both the normal types of sanction (certificate action, civil 

penalty action, or other type) and the normal ranges within those types the FAA ordinarily seeks 

to impose in a legal enforcement action for a single, first-time violation that is generally 

inadvertent (the table includes ranges of sanctions for several violations that usually arc 

intentional, for example, interference with a crewmember, smoking on an aircraft). In addition, 

the table generally reflects a presumption that the alleged violator wants to comply with the law 

and to remedy any noncompliance and that the alleged violator, therefore, has a constructive 

attitude. 

(2) For factors b, d, or h of paragraph 4 (that is, inadvertent and not deliberate conduct, 

attitude, and violation history), the FAA does not normally deviate from the ranges listed in the 

table solely based on the inadvertence of the violation or on the alleged violator's good 

reputation, past public service, violation-free history, or constructive attitude. Any mitigating 

circumstances are to be found in the facts and circumstances of the violation itself. 

(3) Applying ranges within a sanction type. In determining where, within each range, a 

sanction should be imposed, the FAA generally considers factors a, c, e, f, g, i,j, k, and m of 

paragraph 4 (that is, nature of the violation, level of experience, degree of hazard, action by 

employer or other authority, use of certificate, decisional law, ability to absorb sanction, 

consistency of the sanction with similar cases, corrective action), to the extent they are applicable 

or relevant. When determining a specific sanction amount within a range, FAA enforcement 

personnel begin with an amount in the middle of the range and increase that amount toward the 

higher end of the range for aggravating factors or decrease that amount toward the lower end of 

the range for mitigating factors. 

(4) Deviating from ranges within a sanction type. The FAA might impose sanctions 

below the normal ranges based on justifiable mitigation under factors j, l, and m of paragraph 4 

(that is, the ability to absorb the sanction, voluntary reporting, corrective action). The FAA may 

7-9 
10/01/07 2150.38 

impose sanctions above the normal ranges when the following circumstances, relating to factors 

b, d, e, and h of paragraph 4 arc present: the violation is other than inadvertent', the violator has 

a violation history, the violation involves a significant degree of hazard, or the violator has a 

poor compliance disposition. The ranges also may be exceeded when the case involves multiple 

violations. (See chapter 7, paragraphs 6 and 7). 

c. Types of Sanction. 

(!) General. The FAA ordinarily does not initiate punitive civil penalty and punitive 

certificate actions (that is, fixed-period certificate suspensions) against a certificate holder tor the 

same offense. While electing to impose one sanction is not a legal bar to a concurrent 

proceeding to impose another, pursuing both actions solely for punitive purposes usually is not 

necessary. The FAA takes remedial and punitive actions in the same case, however, when 

warranted. 

(2) Selecting types of sanctions. Except in exceptional circumstances, the FAA uses the 

type of sanction recommended in the table. The FAA must impose any sanction mandated by 

statute (for example, revocation under 49 U.S.C. § § 441 06(b ), 44 71 O(b ), and 44726(b) unless 

waived by the Administrator). 

6. General Guidance on Multiple Acts or Multiple Violations. 

a. Description of Multiple Violations. Enforcement actions often involve multiple 

violations: multiple violations of a single regulation; a single violation of multiple regulations; 

or multiple violations of multiple regulations. In addition, under 49 U.S.C. § 4630 I (a)(2), if a 

violation is a continuing one, each day the violation continues, or each flight for which the 

violation was committed, constitutes a separate offense. 

b. General Sanction Guidance. Multiple violations ordinarily result in high sanction 

amounts. Such sanction amounts ordinarily are not determined by simply adding up the 

individual penalties for multiple violations set forth in the table, however. Simply adding up the 

individual penalties for each violation could result in compounding a sanction in a 

disproportionately harsh manner for the conduct involved. Conversely, multiple violations may 

be so serious in their consequences for safety and the public interest as to require a penalty 

greater than the sum of the recommended amount of penalty provided for in the table for each 

violation. 

c. Single Act of Noncompliance Resulting in Multiple Violations. When a single 

instance of noncompliance results in multiple violations of general and specific regulations 

involving the same or similar conduct, the FAA ordinarily does not compound the sanction to 

reflect the amount of sanction recommended in the table for each regulatory violation. In 

calculating the amount of sanction for multiple violations, FAA enforcement personnel consider 

4 When the violation is one that is generally inherently deliberate (e.g., interference with crewmember or smoking 

violations), factor b. is not considered in detemtining whether the sanction should be above the range in the table. 

The ranges in the table for such violations already have taken into consideration the inherently deliberate nature of 

the violation. 

7-10 
10/01/07 2150.38 

the totality of circumstances relating to the multiple violations, including the alleged violator's 

degree of culpability, and whether the alleged violator had taken steps, although unsuccessful, to 

prevent the violations. 

d. Type of Legal Enforcement Action. Where this guidance designates the type of legal 

enforcement action for a single violation, the FAA ordinarily selects the same type of sanction 

for multiple violations of a similar nature. The seriousness of multiple violations, however, may 

require changing what is normally a civil penalty action to a certificate action or, sometimes, a 

punitive certificate suspension to a remedial revocation action. 

7. Special Considerations for Numerous Multiple Violations Resulting From an Initial Act 

or Omission. To determine penalties for numerous multiple violations that result from an initial 

act or omission, the FAA applies the special considerations and guidance in chapter 7, 

subparagraphs 7.a. through e. These cases involve such a high number of multiple violations that 

ifF AA enforcement personnel were simply to add the recommended amounts of penalty for each 

flight or day that constitutes a separate violation, the resulting sanction amount could be 

disproportionately harsh for the misconduct involved, in an average case. 

a. Determining Proposed Penalty. To determine an appropriate civil penalty in a case 

involving numerous multiple violations resulting trom an initial act or omission (for example, an 

aircraft operated on a dozen or more flights after being improperly returned to service), FAA 

enforcement personnel: 

(I) Identify each initial act or omission that caused or resulted in the multiple violations 

(for example, improper maintenance plus improper return to service; failure to maintain a quality 

control system). 

(2) Consult the table in Appendix Band the general guidance in chapter 7, paragraph 4, 

on aggravating and mitigating factors to determine the amount of penalty appropriate for each 

initial act or omission that caused or resulted in the multiple violations (for example, in 

airworthiness cases, a penalty for the act of improper maintenance or inspection; in 

manufacturing cases, a penalty for the act of failing to maintain a quality control system). 

(3) Determine the amount of penalty for the numerous multiple violations by applying 

the guidance in chapter 7, subparagraphs 7.b. through d. Of particular importance in determining 

an appropriate sanction for numerous multiple violations is the degree of the alleged violator's 

culpability for the multiple violations. A lower degree of culpability is present when the alleged 

violator neither knew nor was likely to discover the continuing violations. For example, once 

improper maintenance was done there were no signs of it trom such things as discrepancies 

reported by the crew, and no inspections that would have led to its discovery were scheduled. A 

more significant degree of culpability is present when factors such as the following are present: 

• the initial act or omission was entered in records that should have led to 

immediate detection and correction; 

• the initial act or omission remained undetected and continued through required 

inspections or checks designed to reveal such discrepancies; 

7-11 
10/01/07 

Minimum $100-$299 

(2) VIOLATION COMMITTED BY PART 129 OPERATOR 

Maximum $18,750-$25,000 

Moderate $10,000-$18,749 

Minimum $2,000-$9,999 

(3) VIOLATION COMMITTED BY PART 125 OPERATOR. 

Large Business Concern: 

Maximum 

Moderate 

Minimum 

$16,250-$25,000 

$8,750-$16,249 

$1,850-$8,749 

Small Business Concern (for violations covered under 49 U.S.C. § 46301 (a)(5)(A)): 

Maximum 

Moderate 

Minimum 

$8,250-$11,000 

$3,850-$8,249 

$935-$3,849 

2150.38 

Small Business Concern (for violations covered under 49 U.S.C. § 4630l(a)(l)(A) or (B) but 

not under 49 U.S. C.§ 4630l(a)(5)(A)): 

Maximum 

Moderate 

Minimum 

$750-$1,100 

$450-$749 

$250$449 

(4) VIOLATION COMMITTED BY AIR AGENCY (INCLUDING REPAIR STATION). 

Large Business Concern: 

Maximum 

Moderate 

Minimum 

$16,250-$25,000 

$8,750-$16,249 

$1,850-$8,749 

Small Business Concern (for violations covered under 49 U.S.C. § 4630!(a)(5)(A)): 

Maximum 

Moderate 

Minimum 

$7,150-$11,000 

$3,850-$7,149 

$935-$3,849 

B-5 
10/01/07 2150.36 

Fig. B-3-b. Repair Stations cont. Civil Penalty Certificate 

Action 

(2) Failure to provide qualified personnel who can perform, Maximum Indefinite 

supervise, and inspect work for which the station is rated Suspension 

until 

compliance 

to 

Revocation 

(3) Failure to maintain record of supervisory or inspection Moderate to Maximum 

personnel 

( 4) Failure to maintain record Moderate to Maximum 

(5) Failure to ensure that correct calibration of all inspection Minimum to Maximum 

and test equipment is accomplished at prescribed' intervals 

(6) Failure to adcguatelydescribc work performed Minimum to Moderate 

(7) Failure of mechanic to make log entry, record, or report Moderate to Maximum 

(8) Failure to sign or complete maintenance release Minimum to Moderate 

(9) Inspection of work performed, or approval for return to Maximum Up to 30-day 

service, by other than a qualified inspector Suspension 

(10) Failure to have an adequate inspection system that Moderate to Maximum Up to 30-day 

produces satisfactory quality control Suspension 

(II) Maintaining or altering an article for which it is rated, Maximum Up to 30-day 

without using required technical data, equipment or facilities Suspension 

(12) Failure to perform or properly perform maintenance, Moderate to Maximum Up to 30-day 

repair, alteration, or required inspection for an air carrier or Suspension 

commercial operator 

(13) Maintaining or altering an airframe, powerplant, Maximum Suspension 

propeller, instrument, radio, or accessory for which the repair or 

station is not rated Revocation 

(14) Failure to report defect or unairworthy condition to Moderate to Maximum 

FAA in a timely manner 

(15) Failure to satisfy housing and facility requirement Moderate 

(16) Change oflocation, housing or facilities wifhout written Moderate 

approval 

( 17) Operating as a certificated repair station without a repair Maximum 

station certificate 

(18) Failure to permit FAA to inspect Maximum Indefinite 

Suspension 

until 

Compliance 

(19) Failure to perform inspection properly on part 125 Moderate 

aircraft 

(20) Failure to comply wifh SFAR 36- Second offense Maximum 

(21) Failure to maintain and carry out BTS-required security Mandatory 

measures under 49 U.S.C. § 44924(c)(l) Suspension 

pending BTS 

finding of 

compliance 

B-21 
U.S. DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

FEDERAL AVIATION ADMINISTRATION 

FEDERAL AVIATION ADMINISTRATION, 

Complainant, 

vs. 

AVIONICS MASTERS, INC., 

Respondent. 

Docket No. FAA-2013-0288 

FAA Case No. 2012S0190209 

Judge Sullivan 

DECLARATION OF ROGER MCGLEN 

COMES NOW the Declarant, Roger McGien, and states as follows: 

1. I am over the age of 18 and I understand the obligations of an oath 

2. I am currently employed by the Federal Aviation Administration (FAA) as a Principle 

Avionics Inspector (PAl) at the South Florida Flight Standards District Office in Miramar, 

Florida. My responsibilities include serving as PAl for Avionics Masters. 

3. I have served as an Avionics Inspector at the FAA for over 13 years, including 9 years as 

the P AI for Avionics Masters. 

4. I served 24 years in the United States Air Force as an Avionics Instruments, Autopilot 

and Guidance Control. I was trained in the USAF on the bench and on aircraft. I was a technician 

then a Shift Supervisor and a Avionics Branch Chief. In August of 1992, I was hired In the FAA 

Flight Inspection and Engineering Division as Avionics Technician certifying Flight Inspection 

aircraft and avionics equipment. In Flight Inspection I was attended numerous factory courses. I 

was transferred to Miami, Florida, FSDO· 19, December 1997, as an Avionics Inspector. I have 

4 7 years' experience in the aviation. 

5. On May 14, 2012, I conducted an inspection of Avionics Masters, Inc. I was 

accompanied by Carlton Kitchen, the Principle Maintenance Inspector for Avionics Masters. 

6. During the inspection, one of the items I reviewed was Work Order 8078 (dated 

December 31, 2011) and an accompanying FAA Form 8130-3. In the Form 8130-3, Avionics 

Masters returned to service as repaired a KG-I 02A Bendix/King Directional Gyro, Part Number 

060-0015-00, and serial/batch number X3230 I. 

GOVERNMENT 

EXHIBIT 

T 
7. Avionics Masters is not capable of performing a repair of a KG-I 02A directional gyro, or 

any gyro, because they do not have the appropriate equipment and facilities. Repairing gyros 

requires a clean room and other measures to avoid contamination, and Avionics Masters does not 

have a clean room or any procedures for maintaining the necessary environmental conditions. 

8. Ifthere was a potential problem with the KG-1 02A directional gyro, Avionics Masters is 

not capable of performing an independent inspection of the gyro. Inspecting the gyro itself 

requires an electronic turntable, and Avionics Masters does not have this piece of equipment. 

9. Avionics Masters is not authorized to maintain a KG-! 02A directional gyro, or any other 

gyros, as reflected in their Capability List. If Avionics Masters was authorized to maintain the 

KG-! 02A, or other gyros, then they would have a section in their Capability List listing the gyros 

on which they were authorized to work. The Capability List depicts the KFC-200 System to 

complete Level I Maintenance, Line and/or bench test and installation only. 

I 0. Because Avionics Masters does not have the equipment and facilities to maintain gyros, 

if Avionics Masters had added gyros to their capability list, I would have rejected that addition. 

11. Avionics Masters is authorized to perform maintenance on some autopilot systems, which 

may use directional gyros (including the KG-1 02A) as part of those systems. Accordingly, 

Avionics Masters would be authorized to install the directional gyro as part of the autopilot 

system, remove the directional gyro as part of the autopilot system, or perform a functional test 

of the autopilot system with the directional gyro installed. However, the capability of Avionics 

Masters to maintain the overall autopilot system does not mean that they are authorized to 

maintain the directional gyros themselves. 

12. On May 23, 2012, I sent Avionics Masters a letter of investigation (LOI) concerning the 

return to service of the KG-102A directional gyro. 

13. On June 11, 2012, I received a response letter from Avionics Masters, which was dated 

May 30, 2012. As Avionics Masters indicated in that letter, their Capability List did not include 

the KG-! 02A directional gyro, and they should have sent the gyro to another shop with an 

appropriate authorization. 

Further declarant sayeth naught. 

I, Roger McGlen, declare this 6 day of March, 2014, under penalty of perjury that the 

above statements are true and correct.