### U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF HEARINGS ' 1 

### FEDERALAVIATION ADMINISTRATION



### FEDERAL AVIATION ADMINISTRATION, Complainant,
vs. AVIONICS MASTERS, INC., Respondent. DocketNo. FAA-2013-0288 FAA CaseNo. 2012S0190209
Judge Sullivan
MOTIONFORSUMMARYJUDGMENT 

### 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 summaryjudgment in this matter. No genuine issue of material fact exists to be determined, and the FAAis entitled tojudgmentas a matter oflaw. As grounds for the motion, the FAA states the following. STATEMENT OF THE CASE On May 14,2013, the FAA issued a Final Notice ofProposed Civil Penalty against the Respondent. Respondent timely appealed, and the Complaint was filed on Juue 5, 2013. The Complaint alleged that Respondent had returnedto service a Bendix!I<.ing I02A 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) ofthe 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 ofthatflight control system. Answer**~** 

### 5-8. STATEMENT OF THEFACTS Respondent is the holder ofa 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 ofRespondent'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-offwas executed on December 22, 20II. 

### 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 ofinvestigation (LOI). Attaclnnent F; see 

### Attaclnnent J**~** 

### 12. Inthe 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 "Unithas corrosion atthe base ofthe gyro capsule and onthe 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 itto repair gyros,
orto perform aninspection ofthe gyro as an independent component. Attaclnnent J

## ft7-10. 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 "Aparty may make a motion for decision, regarding all or any part ofthe proceedings, at any time before the administrative lawjudge 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 lawjudge has officially noticed, or evidence introduced during the hearing show that there is no genuine issue ofmaterial fact and that the party making the motion is entitled to a decision as a matter oflaw. The party making the motion for decision has the burden of showing that there is no genuine issue ofmaterial fact disputedby the parties." 14 C.F.R. § 

### 13.218(£)(5). A repair station is not authorized to perform every type ofmaintenance 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 ofratings 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, ratherthan on any componentthat 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 couldnotlegally performmaintenance onthat component. I. Respondent Returnedthe 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 ofthe form, Respondent stated that the gyro was "approved for return to service" and that "details ofthe repair are on file at this facility." Attachment D, Block 13. On that form, Respondent marked the gyro as returned to servicepursuantto 14 C.F.R. §43.9. Attachment D, Block 19. The form was signed and datedby 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. AttachmentE at 2, line 13. There can be no genuine dispute ofmaterial fact as to the contents ofthese documents, including the FAA Form 8130-3 approval for return to service. The FAA is entitled tojudgment
as a matter oflaw as to the fact thatRespondent did return the gyro to service as repaired. II. Respondent's Capabilities List Did NotInclude Gyroscopes As discussed above, Respondent's authorization to work on a particular instrument was governed by its Capability List. It

### is undisputedthatRespondent'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 ofan 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 personmay operate as a certificated repair station without, orinviolation 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 maynotmaintain or alter any article for whichit is rated ifitrequires special technical data, equipment, orfacilities that are not availableto it." 14 C.F.R. 

### § 145.20l(b). There is no dispute that, ifRespondent 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-102A because the gyro can be installed as part of a KFC-200 Flight Control System (autopilot), and Respondent
was authorized to repairthat 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-I02A 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 bythe Administrator. InIn 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 ofautopilot 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. Inre: 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 thatto include the flux gate as part ofthe 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 authorizationfor a repair stationto perform maintenance on them. Consistent with Royal Avionics and the plain language of its own Capability List, Respondent was not authorizedto work on the KG-I02A directional gyro, or any gyro. It

### was not authorized to perform an inspection ofthe gyro itselfto determine what, ifany, 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 20II makes no reference to the system, only a freestanding repair ofthe gyro. See 

### Attachment E. Further, Respondent admitted as much it its own response to the letter ofinvestigationit admittedthat it was not authorized to work onthe gyro, and that it wouldneed to send the gyro out to another repair station in orderto have the gyro itselfchecked 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 ifRespondent had been authorizedto repair the KG1The former § 145.31 is now located at § I45.59. 

### 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-I02A directional gyro, or any other gyroscope. Respondent contends that the authorization to work on a particular autopilot system that might include the KG-I02A 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 entitledtojudgment as amatter oflawonthis issue. III. The Sanction SoughtIs 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 ofthe 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 ofwhich is attached as Attachment I). The guidance for that offense is a Maximum civil penalty or Suspension or Revocation ofthe repair station's air agency certificate. The meaning ofa 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 midpointwould be $9,075. The sanction selected inthis case was the lowestpossible sanctionthat still fell withinthe Administrator's published sanction guidance, below the default midpoint penalty, and at the bottom ofthe Maximumrange. Respondent's personal opinion may be thatthe penalty should be lower, but Respondent's personal opinion does not create a genuine issue ofmaterial fact as to whether the penalty was appropriate. CONCLUSION Documentary evidence establishes that Respondent returned the KG-102A 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 canperform 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 entitledtojudgmentas a matter oflaw.
WHEREFORE, Complainantrespectfully requests thatthe Judge grant Summary Judgment and affirm the Complaintin its entirety.



# .**l~** 

### Respectfully submittedthis_§__day ofMarch, 2014.

# /~ CHRISTOPHER R. STEVENSON Attorney Office ofthe Regional Counsel

9

### CERTIFICATE OF SERVICE 

### Ihereby certifythat a copy ofthe foregoing Motionfor SummaryJudgment has been sent this date bythe following methods: original and one copy via certifiedmail: Federal AviationAdministration 800 Independence Avenue, S.W. Attention:Hearing Docket Clerk, AGC-430 Wilbur Wright Building- Suite 2W1000 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 ofHearings, M-20 U.S. Department ofTransportation 1200NewJerseyAvenue, S.E. (E11-310) Washington, DC 20590 

# L,, 

# jh I 

# JJtPith**Jrr~** DONNA sTANLEY Legal Assistant Office ofthe Regional Counsel 

## MAR - 6 

## 2014' Dated

10UNITED 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 

## thatt!d

## o~a/u"::cakwl 

## com1zlt"e.1 t/z 

## att!.Feytec'!:J tt•tthtk/?Jf?ttt/-e/JWab o/tk**S?;ck~>a/.Yft,tat/oa** 

## Ylepu!fztt"oad**nlfztt~** 

## to tke.Jta!fd:Jifmeatryf'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 oflitis certlji"ciJIL' is ptwishahle hy 11_{inc ofnot cJ:ccedlllg $1,000, or imprisol/111l'!l/ HOI cxn•cdi11g 3years, or h1!1! FAA Form 8000-4 (1·67) SUPERCEDES FAA FORM 390 

## ! GOVERNMENT 

# i EXABIT 

# i
_ _1.
_ _:...--U.S. Department ofTransportation 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, ConductAltimiter System and Altitude Reporting test and inspection in accordance with 14 CFR 43, Appendix "Enand F

Limitations

Print Date: 217/20 ll A003-l Avionics lv'Iasters, Inc. GOVERNMENT**E~IBIT**U.S. Department ofTransportation Federal Aviation Administration Operations Specifications

I. Issuedby the Federal Aviation Admicistration. 2. Support information reference: 3. These Operations Specifications are approved by direction ofthe 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 AmendmentNumber: 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 REPAIRSTATION No. VIMR095K

1001 West Cypress CreekRoad Suite 309 Ft. Lauderdale, Florida 33309 Capability List Revision 2, Dated 02/15/2011

ASSIGNMENT: ChiefInspector LOCATION: ChieflnspectorsOffice**~GOVERNMENT ~**  EXHIBIT


# - / 

## 1---'L-=---

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



## TABLE OF CONTENTS


## TITLE Table ofContents Record ofRevisions List ofEffective Pages Capability List



## REV 0 1 

### 2 REVDATE 01/29/2004 05/01/2008 02/15/2011

MAINTENANCE LEVEL: 

### RECORD OF REVISION INSERTIONDATE 

### 01/29/2004 05/0112008 02/15/2011



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

### Level2: Line and/or benchtest maintenance up to board level. Title: Table ofContents and Page: i Issue Date: 02/15/2011 Revision: 2



### PAGE

ii 

### 1-16



### BY DWT CLH CLH



### Leve13: Line and/or benchtest maintenance up to component level, and Installation.

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



## LIST OF EFFECTIVE PAGES I 

### PAGE I 

### REV I 

### NAME
1 0 Table ofContents 11 0 Record ofRevision

... 0 List ofEffective Pages 111 1-2 0 Light Com andNav 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 AreaNavigation System 14 0 Encoder 15 0 Autopilot 16 0 Miscellaneous 17 0 GPS 18 0 Weather Detection 

### IMulti-FunctionDisplay 19 0 High Frequency Communications 

### MAINTENANCE LEVEL: Levell: Line and/orbenchtest, and Installation. 

### Level2: Line and/or bench testmaintenance up to boardlevel. Title: List ofEffective Pages Page: ii Issue Date: 02/15/20II 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 benchtestmaintenance up to componentlevel, and Installation.

### I 

## I 20 0 Navigation Converters 01129/2004 21 0 Lorane 01129/2004 

# Avionics Masters, Inc. REP AIRSTATION CAPABILITYLIST



### Light Com and Nav MODEL 

### DESCRIPTION

··-- RT-328A/C/D/T NAV Receiver I Comm Transceiver -·--"- RT-428A NAV Receiver I Comm Transceiver

--- RT-385A I RT-485A NAV Receiver I Comm Transceiver

.. RT-485B NAV Receiver I Comm Transceiver =--···· ----· KN-53 Navigation Receiver =c-.·-·-- KY-92 Comm Transceiver _,

### ____ -- KY-96 I KY-97 Comm Transceiver

---------- KY-96A I KY-97A Comm Transceiver

---- KX-145 NAV Receiver I Comm Transceiver
--··· KX-155/ KX-165 NAV Receiver I Comm Transceiver**-~-~----** KX-155A I KX-165A NAV Receiver I Comm Transceiver

----- KX-170/A/B, KX-l75A/B NAV 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 benchtest, 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 benchtest maintenance up to board leveL 

### Leve13: Line and/or benchtest 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 NAV Receiver I Comm Transceiver

-- Comm Transceiver NAV Receiver I Comm Transceiver NAV Receiver I Comm Transceiver Comm Transceiver Navigation Receiver Navigation Receiver Comm Transceiver Navigation Receiver CommTransceiver Corum Transceiver NAV Receiver I Comm Transceiver NAV Receiver I Corum Transceiver NAV 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 benchtest maintenance up to board level. Level3: Line and/or benchtest maintenance up to component level, and Installation.

### Heavy Communication MODEL ----·· 1038A R-900 I KTR-900ARTKT KT KT KTR-905 I KT-90SA**--~--** -- R-906

--- R-9000 -

- 

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



### 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 ,618Ml VHF Corum, Transceiver Collins**~** ' I

-- -- M2 VHF Comm. Transceiver Collins 3 ' i M3/3A VHF Comm. Transceiver Collins 3**-~·--·---** F-20 I VHF-20A IVHF-20B VHF Comm. Transceiver Collins I 3 F-21 

# j VHF Comm. Transceiver Collins 3 '
------- ·------- 

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

------- ---**--~-------**



### MAINTENANCE LEVEL: Levell: Line and/or benchtest. and Installation. Level 2: Line and/or benchtest 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 

### MarkerBeacon MODEL DESCRIPTION

----- _____,_____
-------

---- R-402A/B, R-502A/B Marker Beacon

---- - KMA-20 Audio Panel/MarkerBeacon -"'" ___ KR-21 

# -i Marker Beacon !KMA-24 ·-···---- Audio Panel/Marker Beacon 

### ,-----.......... ·-·· -- .**~-** 'KMA-24H-70/71 

## I Audio Panel/Marker Beacon l____________.
__________
--- 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/MarkerBeacon

·--------- 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 benchtest, and Installation. --

----- 

### Page:4 Issue Date: 02/15/20II 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 iBendix/King

- 3 

## I Bendix/King 3 

## j Bendix/King 3 

## I Collins 

# i±

Collins 3 Garmin 

# J I

___T____

-- Narco ' 3 I Narco 3

--------- Narco 3

- Electrodelta 3**-~-------1**



### Leve12: Line and/or benchtest maintenance up to board level. Leve13: Line and/orbenchtest 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 

### -·-! 

### IBend1x/Kmg ' ' 3 3 Collins Narco 3



### Levell: Line and/orbenchtest, and Installation. 

### Level 2: Line and/or benchtest maintenance up to board level. 

### Leve13: Line and/or benchtestmaintenance up to component level, and Installation.

### DME 

# [- MODEL

-- I I
-- IDME400 loME-1000

## ~-62/I<N-62A ---**-~--** KN-63 IKN-64

- -----

## ~N-65 1KN-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 CAPABILITYLIST

--

### 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 benchtest, and Installation. Level 2: Line and/orbench test maintenance up to board leveL Level 3: Line and/or benchtest maintenance up to component level, and Installation.

# Avionics 

# Masters, Inc. REPAIR STATION CAPABILITYLIST
Page: 7 Issue Date: 02/15/20II Revision: 2 

### ADF

---- !__
___ _ r------ ,R-446A**,~**46E jR5 --'" 

### MODEL

--

-- 

### ';y:l2, T-12A, T-12B, T-12D F-2070 

### ;Ao

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/Kingi Bendix/King i Bendh/King Bendix/King I Collins

- Collins



### Leve12: Line and/or benchtest maintenance up to boardlevel. LEVEL 

### I
3 3 -----::- 3 3 3 3 3 3 3 3 3 3



### Level3: Line and/or bench test maintenance up to componentlevel, and Installation.

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



### Radar

'- ---· ----·---
' 

### MODEL DESCRIPTION 1-- -

--------· - :IN-132A WeatherRadar Indicator iiN-152A _ _.___ . WeatherRadar Indicator JIN-H02A ------ WeatherRadar Indicator

__,____ i!N-1202A/B 

### I WeatherRadar Indicator ' IN-l302A/B i WeatherRadar Indicator**--~-** ---**~---** ·-· ' IN-2021A, lN-2022A, IN-2025A i WeatherRadar Indicator i IN-2025A, IN-2026A, IN-2027A 

## I WeatherRadar Indicator

----**---~------.-** -- IN-2028A Weather Radar Indicator Ill!:131A WeatherRadar RIT IART-161A WeatherRadar R/T and Antenna

---·----------·-- RT-l201A WeatherRadarRIT IRf:l3otA/B WeatherRadarRIT lAf:I33A ---- --------- . WeatherRadar Antenna ;AT-143A Weather Radar Antenna

---·--·------ ------- DA-l44A Weather Radar Antenna DA-1203A Weather Radar Antenna



### MAINTENANCE LEVEL: Level 1: Line and!or benchtest, 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/orbenchtest maintenance up to board level. Level3: Line and/or bench test maintenance up to component level, and Installation.

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



### Radar**---~··-**



### ____MODEL WXR-100 WXR-200 WXR-250AIB KWX-58

----- 

### DESCRIPTION

- Weather Radar System WeatherRadar System WeatherRadar System WeatherRadar System WeatherRadar System RDS s1 1**Rcco=-s=--ccs2~1 Iills:s4-----j--~­**  IKWX-56 Weather Radar System 

### Page:9 Issue Date: 02/15/20II Revision: 2

MFR. LEVEL Collins 3 Collins 3 Collins 3 Bendix/King 3 Bendix/King 3 Narco 3 WeatherRadar System RCA 3 WeatherRadar System RCA 3

------

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

MAINTENANCE LEVEL: Levell: Line and/orbench test, and Installation. Level2: Line and/orbench 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 CAPABILITYLIST



### 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 : ---

IKXP-755
__ _ KXP-756

# ~~~~-?-___:::_:::_--

# -~··-·

- - 

# I

I

.-- I

--. --· 

## I 

# ---+

-



### MAINTENANCE LEVEL: Transponder

- Transponder

- Transponder Transponder Transponder Transponder

-- Transponder

-



### Levell: Line and/orbench 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 benchtest maintenance up to board level. 3 I

# ~~ 3 

# -j 3

# ~---1 

# -8

3 

# J

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

### Transponder MODEL

, RT-777, RT-787, RT-887 RT-667 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. REPAIR STATIONCAPABILITY LIST

DESCRIPTION Transponder

- Transponder Transponder Transponder

- - Transponder Transponder

-----

Transponder Transponder i Transponder i 

### Page: 11 IssueDate: 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/orbenchtest, and Installation. Level 

### 2: Line and/orbenchtest maintenance up to board level. Level 

### 3: Line and/orbenchtest 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_72-1573 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/orbenchtest, and Installation. - 

### I I Page: 12 Issue Date: 02115/20II Revision: 2



### MFR. LEVEL 

## I ' .! Bendix/King 3 i ' iBendix/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 benchtest maintenance up to board level. Level 

### 3: Line and/or bench test maintenance up to component level, and Installation.

### AreaNavigation 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/orbench 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 benchtest 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

------ Icentury

# 2ooo iKFC-200

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

---·····- ··-------**~--~-** -



### MAINTENANCE LEVEL: 

# Avionics Masters, Inc. REPAIR STATION CAPABILITY LIST

- 

## I DESCRIPTION Autopilot ' Autopilot I '-- 

## I Autopilot I Autopilot 

## ------+- Autopilot 

## i '

-------- Autopilot 

# -1 Autopilot

- 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/orbench test, and Installation. 

### Leve12: Line and/or benchtest maintenance up to board level. 

### Leve13: Line and/or benchtest maintenance up to component level, and Installation.

# Avionics Masters, Inc. REPAIR STATION CAPABILITYLIST



### Miscellaneous MODEL DESCRIPTION 'DK-100 I DK-120 I DK-130 I DK-140 Underwater Acoustic Beacon 'PC-50 I PC-50-1**'--~··** ---- 

# i 50 VA Static Inverter



### MAINTENANCE LEVEL: Levell: Line and/or benchtest, 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 benchtest 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 --

--

-



### MAINTENANCELEVEL: 

# Avionics Masters, Inc. REPAIR STATIONCAPABILITYLIST

I 

## I DESCRIPTION 

### 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: 02/15/20II Revision: 2



### MFR 

### I LEVEL II Morrow 1 II Morrow 1 11 Morrow 1 IIMorrow 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/orbenchtest, and Installation. Level2: Line and/or benchtestmaintenance up to board level. Level3: Line and/or benchtest maintenance up to component level, and Installation.

# Avionics Masters, Inc. REPAIR STATIONCAPABILITY LIST



## MISC. WEATHERDETECTION

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

### Page: 18 Issue Date: 02/15/2011 Revision: 2



### MFR LEVEL I Avidyne

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/orbench test, and Installation. Level2: Line and/or benchtestmaintenance 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: 02/15/20II Revision: 2 

### High Frequency Communications

- __,.,_ -- I -· 

### LEVELl MODEL I 

### DESCRIPTION MFR I
···-·· i 

### ! '

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

-------- I 

# .J -----

------



### MAINTENANCE LEVEL: Levell: Line and/orbench 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 STATIONCAPABILITYLIST



### 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 benchtestmaintenance up to board level. Leve13: Line and/or benchtest maintenance up to component level, and Installation.

# Avionics Masters, Inc. REPAIR STATION CAPABILITY LIST


### Page:21 Issue Date: 02/15/20II Revision: 2 

### Loran C MFR LEVEL

- 

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



### MAINTENANCE LEVEL: Level 1: Line and/or benchtest, and Installation. Leve12: Line and/orbenchtest 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: AuthorityiC4untry: 

# AUTHORIZEDRELEASE CERTIFICATE 11078-13 FAA/UNJtED STATES 

### FAAFonn8130-3,AIRWORTHINESSAPPROVALTAG

·, \ 4. Organization Name and Address: 5. Work Order/Contract/Invoice \ / J



### AVionics Masters, Inc. 1001 West Cypress CreekRoad, Suite309, FortLauderdale, Florida 33309 Number: 80711 6. Ifein: 7. Description: 8. PartNumber: 9.**Eligibilit~:*** I0. Quantitv: II. SeriaiJBatch Number: 12. Status/\Vork: Bendix/King 060-0015-00 N/A 1 REPAIRED KG-102A Directional Gyro X32301 13. Remarks: The component identified hereon was tested and inspected in accordance with current regulations ofthe Federal Aviation Administration and manufactures maintenance information and is approved for return to service. Pertinent details ofrepair are on file atthis facility. Manual Number: 006-5111-03 Rev. 3, Oct. 1976.

14. Certifies the items identified above were manufactured in conformityto: 19. [J 14 CFR43.9 Return to Service 

### 0 Other regulation specified in Block 13 

### 0 Approved design data and are in condition for safe operation. Certifies thatunless otherwise specified in block 13, tbe workidentified 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, part43 and in respectto thatwork, 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. HuntJr. 12/2212011 User/InstallerResponsibilities Itis importantto understand thatthe existence ofthis document alone does not automatically constitute authorityto install the part/component/assembly. Wherethe user/installerperforms workin accordancewith the national regulations ufan airworthiness aut.hority different than the airworthiness authority ofthe country specified in Block**1~** it is essential thatthe userlinstaller ensures that his/her airworthiness authority accepts parts/components/assemblies from theairworthiness authorityofthe country specified in Blockl. Statements in Blocks 14 and teinstallation certification. In all cases, aircraft maintenance records mustcontain an installation certification issued in accordancewith the national regulations bythe u CARDEl.S 100-783-0399 C) e the aircraft may be flown. FAA Form 8130-3 (6-01) 0 *Installermust 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 CreekRoad 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 BE

### lfOM£ PROPERTY OF AVIONICS MASTER, INC. lfthis is an A.O.G. (situation, there will be an additional A.O.G. fee.

- -------------------------- Signature ofOwner/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 ofthe Federal Aviation Administration ar..C is approved for return to service. Pertinent details nfthe 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 REPAIR STATION VIMR095K 

## WORKORDER 1001 West Cypress CreekRoad 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 ofPayment Credit Card 

### ALL WORKIS C 0 

### D UNLESS PRIORARRANGEMENTS ARE MADE 

# . REPAIR AUTHORIZATION: MAINTENANCE RELEASE: I hereby authorized the above repair workto 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 ofthe Federal Aviation Administration and ALL EQUIPMENT NOT PICKED UP WITHIN 90 DAYS WILL BE- is approved for return to service. Pertinent details oftheCOME PROPERTY OF AVIONICS MASTER INC. Ifthis 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 ofOwner/Agent Date Fm·m**~000** Re"· 3 05/01/1008U.S. Deportment of Transportation Federal Aviation Administration 

## MAY 23 2012 South Florida Flight Standards District Office 19



### CERTIFIED MAIL- RETURN RECEIPT REQUESTED File No. 2012S0190209 Mr. 

### Vincent Sortino Accountable Manager Avionics Masters, Inc. 1001 West Cypress Creek Road Suite #309 Fort Lauderdale, Florida 33309 DearMr. Sortino: 2895 SW 145(11 Avenue, Suite 120 Miramar, FL 33027



### Dming a visit to Avionics Masters, Inc. onMay 14,2012, inspectors from this oftlce observed a Directional Gyro, ManufacturedbyBendix/King, Model KGI02A, Serial NumberX32301, under Work OrderNo. 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 matterwithin five (5) days ofreceipt ofthis letter. Any discussion or written statements furnished by you will be given consideration in our investigation. Ifwe do not hear from you within the specified time, our report will be processed without the benefit ofyour 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 ourwork 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 unitwould 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. Ifyou 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--

### :?F v;r- 

### ;friumph Instruments- ,. Ft. Lauderdale**~** A Triumph Group Company 

## ,-il.mph Instruments-Ft. Lauderdale .J352 N.W. 21 Terrace
· Ft. Lauderdale ExecutiveAirport

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.10/01/07 2150.3B available to the Government. Legal counsel consults the Financial Litigation Staffofthe Executive Office for the United States Attorneys in the Department ofJustice 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 ofIndebtedness. j. Payments received by Legal Counsel. Ifdebtors send checks to legal counsel's office rather than the accounting office, legal counsel sends the checks to the accounting office immediately. The Assistant ChiefCounsel 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 ofForeign 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 ofa foreign regulation by a U.S. citizen or company. Atler the completion ofthe case, legal counsel advises the foreign aviation authority through the Department ofState ofthe action taken, except in the case ofCanada, the contact is made directly with Transport Canada. Ifthe program office does not refer the case to the legal office for handling, the program office advises the foreign aviation authority. 34. Violations ofFAA 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 ofhis or her FAA airman certificate, a foreign individual who commits a passenger violation, ora foreign air carrier operating under 14 C.F.R. part 129. All otherviolations committed by foreign persons, except Canadianpersons, are referred to the appropriate foreign aviation authority through the Department ofState. Violations committed by Canadian persons, for whom legal enforcement action is not taken, are referred directly to Transport Canada. b. Preparation ofReferral to Foreign Authority. To refer a case to another foreign aviation authority, FAA legal counsel prepares a letter that includes a brieffactual summary of the violation, a statementofthe regulations violated, and a request that Transport Canada or other foreign aviation authority advise the FAA ofany action that it takes regarding the matter. FAA legal counsel sends a copy ofthe EIR with the referral letter.
c. Notification ofLegal EnforcementAction Taken. FAA legal counsel advises Transport Canada directly or other foreign aviation authority through the U.S. Foreign Service Post, ifappropriate, ofthe 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 chapterprovides the FAA'spolicies 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 ofsanctions, ranges of sanctions within those types, and specific sanction amounts to impose in legal enforcement actions for typical violations ofthe 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 Ifa certificate holder improperly exercises the privileges ofa certificate, a natural consequence ofthat act is to lose the privileges for a period oftime 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 ofindividual 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 mayadversely affectthe public. Nevertheless, when the FAA determines that safety considerations warrant it, the agency will suspend the certificate ofany type ofcertificate holder. In no case will the FAA take civil penalty action alone when remedial legal action is necessary or appropriate. (2) Use ofboth 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 oftime) against a certificate holder for the same conduct. Ifunusual circumstances warrant deviation from this practice, legal counsel consult with the Assistant ChiefCounsel for Enforcement (AGC-300) before initiating the actions. {3) Change in type ofproposed sanction. The initial enforcement action reflects the agency's best assessmentofthe appropriate sanctionfor the violations alleged. After initiating the action, legal counsel ordinarily does not change the type ofsanction unless additional facts or circumstances are presented to the FAA that warrant a change. Ifthe action was coordinated underchapter 6, paragraph 3, with AGC-300 before initiation, then legal counsel coordinates any change in the type ofsanction 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 7-110/01/07 2150.38 suspend the privileges ofthe certificate orratingpending demonstration ofqualification 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 ofthe privileges ofthe 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 ofthe technical proficiency or a lack ofthe degree ofcare,judgment, or responsibility, required ofthe holder ofsuch 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 ofthe certificate. Legal counsel does not allege a lack ofqualifications to avoid dismissal ofcharges 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 ofwillingness or ability to comply consistently with statutory or regulatory requirements. A lack ofwillingness or ability to comply may be demonstrated by such things as repeated ordeliberate violations orby 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 ofa person who commits a violation involving intentional falsification. (4) Certificate revocation- entities. Revocation is normally appropriate when a certificate-holding entity deliberately orflagrantly violates the statute orregulations or falsifies records. Revocation also is generally appropriate whenthe certificate holder has committed the same or similarviolations in the recent past demonstrating a lack ofqualification, or when the certificate holder no longer has, and does not obtain in areasonable time, the personnel or equipmentto 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 ofanyairman who has been convicted ofviolating certain federal orstate statutes relating to a controlled substance when an airplane was used in the commission ofthe offense and the airman served as an airman, orwas aboard the aircraft, in connection with commission ofthe offense or the facilitation ofthe commission ofthe offense. Even whenthere has been no conviction, revocation is required when an airman has knowingly carried out an activity punishable under these criminal statutes. The Administratormay waive the revocation if a law enforcement officer requests the waiver and the Administrator decides the waiverwill facilitate lawenforcementpurposes. See 49 U.S.C. §44710(f). Under49 U.S.C. § 44106, the FAA also must revoke the registration certificate ofany airplane used in the commission ofsuch an offense when the use was permitted by the ownerofthe aircraft with knowledge that it would be used for such purpose. Under 49 U.S.C. 

### § 44726, the FAA mustrevoke the certificates ofany certificate holder oran individual who has a controlling orownership interest in the holder who was convicted ofa violation offederal lawrelating to the installation, production,repair, or sale ofa counterfeit or fraudulently-represented aviation part ormaterial orknowingly, and with the 7-210/01/07 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, orrevoking any FAA-issued certificate ifthe Administrator is notified by the Under Secretary ofBorder and Transportation Security (BTS) ofthe Department ofHomeland Security (DHS) that the certificate holder poses, or is suspected ofposing, a risk ofair piracy or terrorism or a threat to airline or passenger safety. Under 49 U.S.C. §44924, the Administrator is required, at the request ofthe Under Secretary ofBTS, to suspend orrevoke foreign repair station certificates in connection with security audits. 3. Applicability and Exclusions. The sanction guidance table (table) in Appendix B provides types ofsanctions and general ranges ofsanction amounts for violations of49 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 ofthis 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 ofagency 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 notconstitute either a formal adjudication ofthe incident or a finding ofviolation. Forthat reason, FAA investigative personnel do not propose a sanction using the table. b. The FAA's Exercise ofProsecutorial Discretion. The decision whether to prosecute a particular case is based on a review ofthe 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 casebased 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 ofthe federal hazardous materials transportation law, 49 U.S.C. chapter 51, orthe Department ofTransportation's Hazardous Materials Regulations, 49 C.F.R. parts l06 through 185. Enforcement sanction guidance for these violations is found in Appendix C. d. Violations by Members ofthe U.S. Armed Forces. The FAA is required to forward reports ofthese violations to the Secretary ofthe departmentconcerned under49 U.S.C. §4610l(b), wheneverthe violator is acting in the performance ofofficial duties. The FAA, however, takes remedial action in addition to referring a report when the violator, whether ornot

7-310/01107 2150.38 acting in the performance ofofficial military duties, holds an FAA certificate, and the violator's qualifications are at issue. The FAA may take punitive action against a member ofthe 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 ofpolicy making and case adjudication. They have proven useful and appropriate for determining the seriousness ofa 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 ofthe Violation. Three elements define the nature ofa violation: first. whether the violation was operational or non-operational; second, whether the violation involved careless orreckless 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 ofthat certificate, the natural consequence ofthat act should be loss ofprivileges for a period oftime 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 ofsanction. (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 notoutweighedby safety considerations. Even when a substantial adverse impactwould occur, when there is a need to prevent continuing violations orotheregregious conduct by any certificate holder, when any certificate holder lacks qualification, or there is a reasonable basis to question the qualifications ofany certificate holder, the FAA takes remedial action, for example, revocation orindefinite suspension, as necessary. (3) Careless orreckless conduct Violations that involve careless orreckless conduct in violation of 14 C.F.R. §91.13 may warrant more severe sanctions. Carelessness connotes conduct that falls below the standard ofcare or prudence expectedofa reasonable person, or holderofthe relevant certificate, actingunder the same or similar circumstances. Recklessness connotes conductthat demonstrates a gross, or even callous or flagrant, disregard for safety. Aircraft operations that do nototherwise result ina violation ofa specific regulation should be evaluated in light ofthese standards to determine whether they constitute careless or reckless operations in violation of 14 C.F.R. § 9Ll3. When a personoperates an aircraft in violation ofa specific regulation otherthan 14 C.F.R. § 9!.13, however, that violation constitutes a careless or reckless operation in and ofitself In these cases, the misconduct may also result 

### in a violation of 14 C.F.R. §9l.I3 ifit actually orpotentially endangers the lives orpropertyofothers. 7-410/01/07 2150.38 When calculating the amount ofsanction 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. Whetherthe Violation was Inadvertent and Not Deliberate, Ifa violation is deliberate or not inadvertent, a sanction at the upper end ofthe range or exceeding the range for that type ofviolation generally is appropriate. A deliberate violation generally warrants a sanction that is more severe than one that isjust not inadvertent (I) Not deliberate. This element means a lack ofthe degree ofdeliberation 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 ofboth inattention and lack ofpurposeful 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 ofchoosing 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 SafetyBoard, 678 F.2d 821, 828-829 (9th Cir. 1982).
c. CertificateHolder'sLevel ofExperience. (I) Level ofexperience refers primarily to the type ofcertificate and ratings held (for example, student, private, commercial, airline transport pilot, or certified flight instructor), and the numberofhours 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 maybe held to an even higher standard than commercial pilots. (2) In determining an appropriate sanction, the FAA may considerthe extent to which the certificate holder's action deviated from the degree ofcare and diligence normally expected ofa person with the certificate holder's level ofexperience. A significant deviation from the degree ofcare and diligence expected ofthe holder ofthat certificate may warrant a more aggravated sanction. d. Attitude ofthe 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 oromission contrary to statutory orregulatory requirements after receiving notice through a prioradministrative action orcounseling that suchconduct is in violation ofthose requirements mightwell beregarded as having a poor compliance disposition. In evaluating compliance disposition, the FAA does not 7-510/01/07 2150.38
view an alleged violator as having a poor attitudebecause the alleged violator fails to respond to a letter ofinvestigation, chooses to be represented by counsel, orcontests the violation. (2) In assessing the attitude ofan alleged violator, the FAA may consider the declaration ofan emergency to air traffic control. When an emergency is genuine and not ofthe 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 ofemergency 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 ofgoodjudgment and a constructive attitude. When an emergency is ofa person's own making, that person's declaration ofan 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 ifa person voluntarily reports a violation.
e. Degree ofHazard. (I) The degree ofhazard may be increased as a result ofthe interplay ofthe operational environment (for example, weather conditions, congested vs. sparsely populated areas) and the nature ofthe threat to safety (to the life orproperty ofanother, including those in the aircraft being operated, to other aircraft, or to persons orproperty on the surface) that the misconduct presents. The safety threat is based on the reasonably foreseeable consequences ofthe misconduct. Forexample, operating 500 feet below the minimum altitude poses a greaterhazard than operating I00 feet below. Similarly, ifan aircraft operator fails to comply with an airworthiness directive by operating I0 hours past a required inspection, the degree ofhazard 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 ofdangernormally inherent in an average violation ofa regulation, without aggravating circumstances. As discussed in chapter 7, subparagraph 5.b., an increase in the degree ofhazard 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 employerhas taken disciplinary action and whethercriminal prosecution is involved. (I) Employmentdiscipline. Where the violation would normally call for a certain type ofenforcement action, the FAA takes that action regardless ofany action taken by the violator's employer. Generally, the FAA does not credit an employer's disciplinary action toward a period ofsuspension the FAA imposes against the violator's certificate because ofthe different purposes ofgovernment-ordered, as contrasted with employer-ordered, actions. (2) Criminal prosecution. When arising out ofthe same conduct, local, state, orfederal prosecution does not preclude the FAA from taking appropriate remedial enforcement action; nor 7-610/01/07 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 ifthat 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. Ifthe 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 ofsanction to be sought in the FAA's punitive enforcement action. g. Use ofa Certificate. This factor relates to the nature or kind ofactivity oroperation 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 ofthe sanction. Air carriers are held to the highest standard ofcare. 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 ofsanction for a single, first-time, inadvertent violation. Given the expected norrn, a prior violation record can be evidence ofa poor compliance disposition or ofa pattern ofdisregard for the FAA's regulations, which are aggravating factors. As a result, a violation history canjustify imposing a sanction at the higher end ofthe normal range or a sanctionbeyond the normal range. It might alsojustifyrevocation rather than suspension ifthe pattern ofviolation reflects a lack of qualification. In addition, a violation history mightjustify a certificate suspension ifpreviously issued civil penalties have notproduced the desired deterrent effect. In deciding whether a violation historyjustifies aggravating the sanction or changing the usual type ofsanction, the FAA considers the length oftime that has elapsed between violations, whether the violations involved the same or similarregulations, and whether the violations are factually similar. (2) The following actions constitute violation history when they involve regulatory violations and become final: orders ofamendment, modification, suspension, or revocation ofan FAA certificate; orders assessing a civil penalty; findings ofviolation contained in a consent order, order ofcompliance or denial; and findings ofviolation made bya federal court. In addition, a party may agree as part ofa settlement that the FAA may consider alleged violations as findings ofviolation for future sanction determinations. i. Decisional Law. Decisions ofthe FAA decisionmakerrepresent the FAA Administrator's position on issues arising in civil penalty assessment actions, including issues regarding sanctions. Thepolicy 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 publishedbefore this document's issuance, the sanction guidance policy in this order supersedes those decisions. However, FAA decisionmakerdecisions published after

7-710/01/07 2150.38 the issuance ofthis 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 ofdoing 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 ofbusiness. Therefore, the FAA uses air carrier size as one means ofensuring a relatively equivalent deterrent effect on each air carrier that violates the same FAA regulation. The resulting classification ofair carriers by size and ranges ofcivil penalties arc set forth in part one ofthe 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 ofSanction. One ofthe 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 ofdeterrent or disciplinary value to others similarly situated. This goal may not always be achieved, however, because ofthe inherently subjective nature ofthe 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 andreceive 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 herreport of another's violations, voluntarily discloses his or her own participation in the same orrelated violations. This special enforcement consideration may range from mitigating the sanction to determining that no enforcement action is required. (2) Ifa person is not covered under one ofthese programs but nonetheless voluntarily reports anapparent 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 ofthe 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 ofcredit given in setting a sanction depends on the extentand timing ofthe corrective action, that is, how extensive was the corrective action andhow quickly was it taken. Implementingnewprocedures that are above those required under the FAA's regulations 7-810/01/07 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 ofa deficiency but before FAA discovery ofthe violation ordinarily warrants greater mitigation than corrective action that is taken only after the alleged violator receives notice ofthe FAA's enforcement action. Corrective action taken by an alleged violator that simply brings that person into compliance with the statutory orregulatory 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 ofthe Table ofSanctions.
a. General. Sanction detem1inations are not accomplished through a strict mathematical formula; rather, sanction determinations result from ajudgment ofwhere a case lies along a spectrum ofgravity. Ultimately, the circumstances ofeach case arc evaluated in terms ofthe needs ofsafety and the public interest. b. Single, First-time, Inadvertent Violations. (I) Part II ofthe table specifies both the normal types ofsanction (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 ofsanctions 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) Forfactors b, d, or h ofparagraph 4 (that is, inadvertent and not deliberate conduct, attitude, and violationhistory), the FAA does not normally deviate from the ranges listed in the table solelybased on the inadvertence ofthe violation oron the alleged violator's good reputation, past public service, violation-free history, orconstructive attitude. Any mitigating circumstances are to be found in the facts and circumstances ofthe violation itself. (3) Applyingranges 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 ofthe violation, level ofexperience, degree ofhazard, action by employeror otherauthority, use ofcertificate, decisional law, ability to absorb sanction, consistency ofthe sanction with similar cases, corrective action), to the extent they are applicable orrelevant. When determining a specific sanction amount within a range, FAAenforcement personnel begin with an amount in the middle ofthe range and increase that amount toward the higherend ofthe 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 onjustifiable mitigation under factorsj, 

### l, and m ofparagraph 4 (that is, the ability to absorb the sanction, voluntary reporting, corrective action). The FAA may 7-910/01/07 2150.38 impose sanctions above the normal ranges when the following circumstances, relating to factors b, d, e, and h ofparagraph 4 arc present: the violation is other than inadvertent', the violator has a violation history, the violation involves a significant degree ofhazard, 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 ofSanction. (!) 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 ofsanctions. Except in exceptional circumstances, the FAA uses the type ofsanction recommended in the table. The FAA must impose any sanction mandated by statute (for example, revocation under49 U.S.C. § §44106(b), 4471O(b), and 44726(b) unless waived by the Administrator). 6. General Guidance on Multiple Acts or Multiple Violations.
a. Description ofMultiple Violations. Enforcement actions often involve multiple violations: multiple violations ofa single regulation; a single violation ofmultiple regulations; ormultiple violations ofmultiple regulations. In addition, under 49 U.S.C. § 4630I(a)(2), ifa 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 determinedby 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 ofthe recommended amount ofpenalty provided for in the table for each violation.
c. Single Act ofNoncompliance Resulting 

### in Multiple Violations. When a single instance ofnoncompliance results inmultiple violations ofgeneral and specific regulations involvingthe same or similarconduct, the FAA ordinarily does not compound the sanction to reflect the amount ofsanction recommended in the table for each regulatory violation. In calculating the amount ofsanction for multiple violations, FAA enforcement personnel consider

4 When the violation is one that is generally inherently deliberate (e.g., interference with crewmemberor smoking violations), factorb. is not considered in detemtining whether the sanction should be above the range in the table. The ranges inthe table for such violations already have taken into consideration the inherently deliberate nature of the violation. 7-1010/01/07 2150.38 the totality ofcircumstances relating to the multiple violations, including the alleged violator's degree ofculpability, and whether the alleged violator had taken steps, although unsuccessful, to prevent the violations. d. Type ofLegal Enforcement Action. Where this guidance designates the type oflegal enforcement action for a single violation, the FAA ordinarily selects the same type ofsanction for multiple violations ofa similar nature. The seriousness ofmultiple 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 ofmultiple violations that ifFAA enforcement personnel were simply to add the recommended amounts ofpenalty for each flight orday 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 improperreturn to service; failure to maintain a quality control system). (2) Consult the table in Appendix Bandthe general guidance in chapter 7, paragraph 4, on aggravating and mitigating factors to determine the amount ofpenalty appropriate for each initial act or omission that caused orresulted in the multiple violations (for example, in airworthiness cases, a penalty for the act ofimproper maintenance or inspection; in manufacturing cases, apenalty for the act offailing to maintain a quality control system). (3) Determine the amount ofpenalty for the numerous multiple violations by applying the guidance in chapter 7, subparagraphs 7.b. through d. Ofparticular importance in determining an appropriate sanction for numerous multiple violations is the degree ofthe alleged violator's culpability for the multiple violations. A lowerdegree ofculpability is present when the alleged violator neitherknew nor was likely to discover the continuing violations. Forexample, once impropermaintenance was done there were no signs ofit trom such things as discrepancies reported bythe crew, and no inspections that would have led to its discovery were scheduled. A more significant degree ofculpability is present when factors such as the following are present:
• the initial act or omission was entered in records that should have led to immediatedetection and correction; • the initial act oromission remained undetected and continued through required inspections or checks designed to reveal such discrepancies; 7-1110/01/07 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 under49 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 AIRAGENCY (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-510/01/07 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 ofsupervisory or inspection Moderate to Maximum personnel (4) Failure to maintain record Moderate to Maximum (5) Failure to ensure that correct calibration ofall inspection Minimum to Maximum and test equipment is accomplished at prescribed'intervals (6) Failure to adcguatelydescribc work performed Minimum to Moderate (7) Failure ofmechanic to make log entry, record, or report Moderate to Maximum (8) Failure to sign or complete maintenance release Minimum to Moderate (9) Inspection ofwork 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) Failureto 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 orunairworthy 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 stationwithout 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 pendingBTS finding of compliance

B-21U.S. DEPARTMENTOFTRANSPORTATION OFFICE OF HEARINGS FEDERALAVIATION ADMINISTRATION

FEDERALAVIATION ADMINISTRATION, Complainant,
vs. AVIONICS MASTERS, INC., Respondent. DocketNo. FAA-2013-0288 FAA Case No. 2012S0190209
Judge Sullivan
DECLARATIONOF ROGERMCGLEN COMES NOW the Declarant, Roger McGien, and states as follows: 1. I am overthe age of 18 and Iunderstand the obligations ofan oath 2. I amcurrently employed bythe Federal AviationAdministration (FAA) as a Principle AvionicsInspector (PAl) atthe South FloridaFlight Standards District Office in Miramar, Florida. Myresponsibilities include serving as PAl for Avionics Masters. 3. I have served as an Avionics Inspector attheFAAfor over 13 years, including 9 years as the PAI forAvionics Masters. 4. I served 24 years inthe United States AirForce as an AvionicsInstruments, Autopilot andGuidance Control. Iwas trained inthe USAF onthe bench and onaircraft. I was a technician then a Shift Supervisor and aAvionics Branch Chief. In Augustof 1992, I was hiredInthe FAA Flight Inspection and EngineeringDivisionas Avionics Technician certifying FlightInspection aircraft and avionics equipment. InFlight Inspection Iwas attended numerous factory courses. I was transferred to Miami,Florida, FSDO· 19, December 1997, as anAvionics Inspector. Ihave 4 7years' experiencein the aviation. 5. On May 14, 2012, I conducted an inspectionofAvionics Masters, Inc. Iwas accompaniedby Carlton Kitchen, the Principle Maintenance InspectorforAvionics Masters. 6. Duringthe inspection, one ofthe items Ireviewed was Work Order 8078 (dated December 31,2011) and an accompanyingFAA Form 8130-3. Inthe Form 8130-3, Avionics Mastersreturnedto service asrepaired a KG-I02A Bendix/KingDirectional Gyro, PartNumber 060-0015-00, and serial/batchnumberX3230I.



### GOVERNMENT EXHIBIT 

# T7. Avionics Masters is not capable ofperforming a repairofa KG-I02A directional gyro, or any gyro, becausethey do not have the appropriate equipment and facilities. Repairing gyros requires a cleanroom andothermeasures to avoid contamination, and Avionics Masters does not have a clean roomor any proceduresfor maintaining the necessary environmental conditions. 8. Ifthere was a potential problemwith the KG-102A directional gyro, AvionicsMastersis notcapable ofperforming an independentinspection ofthe gyro. Inspecting the gyro itself requires an electronicturntable, and Avionics Masters does nothavethispiece ofequipment. 9. AvionicsMasters is not authorized to maintain a KG-!02Adirectional gyro, orany other gyros, asreflected intheir Capability List. IfAvionics Masters was authorized to maintainthe KG-!02A, orother gyros, then they would have a sectionintheir Capability List listingthe gyros onwhichtheywere authorized to work. TheCapabilityList depicts the KFC-200 Systemto completeLevel I Maintenance, Line and/orbench testand installation only. I0. Because Avionics Masters does not have the equipment andfacilities 

### to maintain gyros, ifAvionics Masters had added gyros to theircapabilitylist, I would haverejected that addition. 11. AvionicsMastersis authorized to performmaintenance onsomeautopilot systems, which may use directional gyros (includingthe KG-102A) as part ofthose systems. Accordingly, Avionics Masters would be authorizedto installthe directional gyro as part ofthe autopilot system, removethe directional gyro as partofthe autopilot system, orperform a functional test ofthe autopilot system withthedirectional gyro installed. However, the capabilityofAvionics Masters

### to maintain the overall autopilot system does not mean thatthey are authorized to maintain the directional gyros themselves. 12. On May23, 2012, I sentAvionicsMasters a letterofinvestigation (LOI) concerningthe return to serviceofthe KG-102A directional gyro. 13. OnJune 11, 2012, I received a response letterfrom Avionics Masters, which was dated May 30, 2012. As Avionics Mastersindicated inthat letter, their CapabilityListdid not include the KG-!02A directional gyro, and they should have sentthe gyro to another shopwith an appropriate authorization. Furtherdeclarant sayeth naught. I, RogerMcGlen, declare this 6 day ofMarch, 2014, underpenalty ofperjury thatthe above statements are true and correct.