i.^S^'lJO' 

To:DMS ,;,P 

EXHIBITS GO-JET 2010-0190 AND 2010-0025 

2 

M-20 Pat Matthews 
GoJet FAA 2010 - 0025, FAA 2010 - 0190; FAA Exhibit List 

1 A-1 

2 A-2 

3 A-3 

4 A-4 

5 A-5 

6 A-6 

7 A-7 

8 A-8 

9 A-9 

10 A-10 

11 A-11 

12 A-12 

13 NA 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

Description 

Log book, 26 Nov 07 - 1 pp 

Brake ass - removal/installation - 2 pp 

Jacking at Main Landing Gear - 1 pp 

Troubleshooting Info GMM - 1 pp 

Self Disclosure VDP - 5 pp 

Ltr 20080125 FAA to GoJet - ignore first disclosure - 3 pp 

Ltr 20080125 FAA to GoJet routing slip - ignore first disclosure - 5 pp 

NO EXHIBIT 

NO EXHIBIT 

8900.1 chgO-VDP- 7 pp 

AC 00 - 58 A excerpt-5 pp 

duplicate of p 3 of Ex A-10 - 1 pp 

Sanctions guidance 

ID 

X 

X 

X 

X 

X 

X 

X 

NA 

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X 

X 

X 

NA 

IN 

X 

X 

X 

X 

X 

X 

X 

NA 

NA 

X 

X 

NO 

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AIRCRAFT MAINTENANCE MANUAL 

BRAKE UNIT ASSEMBLY - REMOVAUINSTALLATION 

On A/C 10001-10999 

TASK 32-43-26-000-801-A01 

1. Removal of the Brake Unit Assembly 

A. General 

{1) The maintenance procedure that follows is for the removal of the brake unit 

assembly (written as the "brake unit" in this procedure). There are four brake units 

installed on the right side and the left side main landing gears (MLG). This 

procedure is for the left outboard brake unit. Differences tor the left inboard brake 

unit are identified. 

B. Job 5et-Up Information 

{1) Tools and Equipment 

•^^^ ,,oo ^'• ^ 

^ \ ^ 'W2^ 

^ 5 

REFERENCE 

14-6883-0110 

G670321101-1 

(2) Parts 

(3) Reference Information 

Effectivity: See first page of 

TASK 32-43-2e--^0'301-A01 

DESIGNATION 

Dolly-Wheels and brakes removal and 

installation 

Sleeve - MLG Axle Protection 

NAME OF PART 

Assembly, bia';^ uni; 

AIPC FIGURE REFERENCE 

32-^3-20-01 

REFERENCE 

TASK 07-12-01-582-301 

TASK 12-00-00-867-801 

TASK 24-00-00-910-801 

DESIGNATION 

Jacking at the f^^ain Landing Gear 

(MLG) 

Standard Aircraft Configuration for 

Maintenance 

Electrical/Electronic Safety Precautions 

32-43-26 

^ ' \ 

2-

Page 401 

Oct 20/2007 
^^^^^j ^ Regional 

AIRCRAFT MAINTENANCE MANUAL 

REFERENCE 

TASK 32-41-01-000-801 

TASK 32-46-01-000-801 

DESIGNATION 

Removal of the Mainwheel and Tire 

Assembly 

Removal of IheThermocoupie Sensor 

(4) Standard Practices Information 

REFERENCE 

TASK 20-51-00-000-802 

DESIGNATION 

Removal of Lockwire 

C. Job Set-Up 

(1) Make sure the aircraft Is in the standard configuration for maintenance (TASK 

12-00-00-867-801). 

(2) Obey all the electrical/electronic safety precautions {TASK 24-00-00-910-801 

(3) Open and tag the circuit breakers that follow: 

CB-PANEL 

CBP-1 

CBP-1 

CBP-2 

CBNO. 

F14 

F11 

F14 

NAME 

HYD SYST AC PUMP CONT 2 

HYD SYST AC PUMP CONT 38 

HYD SYST AC PUMP CONT 3A 

',4j Lit', irie ML U ^.'IU"I the |acK iTASK 0'-12-0l-SB^-SOlj. 

(5) Remove the mainwheel and tire assembly (TASK 32-41 -01 -000-801 

(6) Remove the thernnocouple sensor {TASK 32-46-01-000-801). 

D. Procedure 

Refer to Figure 32-43-26-991-803 

Effectivity: See first page of 

TASK 32-43-26-000-801-A01 32-43-26 Page 402 

S"r 30/2005 

T \ 

V 
4/24/20U8 2-12:11 PM 

'-' ON A/C 10001-10012, 10013-10173, 10174-10265, 10266-10428, 10429-10591, 10592-10754, 10755-

10999, 15001-15081, 15082-15407, 15408-15570, 15571-15733, 15734-15990 

TASK 07-12-01-582-801-A01 

1. Jacking at the Main Landing Gear (MLG) 

A. General 

{1) The maintenance procedure that follows is to lift the aircraft at the main landing gears (MLG). The 

jacking points are found below each MLG axie 

B. Job Set-Up Information 

(1) Tools and Equipn^ient 

REFERENCE 

02-7830-0100 

SSL25-9-45 

W88F36 

DESIGNATION 

Jack-MLG Axle(25ton) 

Beam-Jacking-NLG & MLG Axles 

Wheel Chocks-NLG & MLG (36 inch) 

(2) Reference Information 

REFERENCE 

TASK 10-11-01-587-801 

TASK 10-11-01-910-801 

TASK 10-11-01-910-802 

TASK 12-00-00-867-801 

DESIGNATION 

Parking 

Set the Parking Brake 

Release the Parking Brake 

Standard Aircraft Configuration for Maintenance 

C. Job Set-Up 

(1) Make sure that the aircraft is in the standard configuration for maintenance(TA^SK 1^_-0_0-00^_67-

801). 

(2) Park the aircraft on level groundtTASK_1_P-_1l-gi-5^7-_80,1)-

NOTE; Do not install the wheel chocks at this time. 

(3) Make sure that the N/W STRG switch is set to OFP on the left side panel. 

(4) Open, safety, and tac; the circuit breakers that follow: 

CB-PANEL 

CBP-1 

CBP-2 

CB NO. 

G2 

G2 

NAMP 

NOSE STEER 

NOSE STEER 

D. Procedure 

Ref.eL to J.lguie_^07-_12-01.-991-801 

WARNING: YOU MUST OBEY THE PRECAUTIONS THAT FOLLOW WHEN YOU LIFT OR 

LOWER THE AIRCRAFT ON JACKS: 

• MAKE SURE THAT NO PERSON OR TOOL IS ON OR IN THE AIRCRAFT. 

• MAKE SURE THE LOCKPINS ARE INSTALLED IN THE NLG AND THE MLG. 

• MAKE SURE THAT THE CHOCKS ARE REMOVED FROM THE WHEELS. 

• MAKE SURE THAT THE PARKING BRAKE IS RELEASED. 

• MAKE SURE THERE IS SUFFICIENT CLEARANCE AROUND THE AIRCRAFT. 

THESE PRECAUTIONS CAN PREVENT INJURY TO PERSONS AND DAMAGE TO 

THE AIRCRAFT. ^-C^riir' 

(1) Lift the aircraft at the MLG as follows: J^T ^ | EXHIBIT 

(a) If the two tires of the '.vrs-Si^is to be reinoved are not deflated, do as fojiows: 

1 Put the jack below the applicable MLG axle. _ ^.yf^f^"^^"" 

Airrrpft MaintRnanne Manual - Revi... 

- 2 / 

-7 .^\ ^ oa<r 
GMWl - General Maintenance Manual MAINTENANCE DEPARTMENT 

Volume 1 POLICIES & PROCEDURES 

Part 12 TROUBLESHOOTING INFORMATION, PROCEDURES AND REQUIREMENTS FOR SAFETY 

12.1 Oxygen and Nitrogen Servicing and Storage Requirements 

A. Servicing 

1. The direct bottle-to^bottle servicing of Aircraft Oxygen Systems while passengers are on board the 

aircraft is prohibited. However, oxygen servicing utilizing aircraft exterior servicing panel may be 

utilized with passengers on board under the following conditions: 

• The emergency lighting system must be armed to aid in rapid passenger egress in case of 

emergency. 

• When passengers are on board the aircraft, qualified crewmember must be present in the 

passenger cabin. 

• In the event of an electrical power interruption, this procedure will provide automatic 

emergency illumination of escape path lighting, aiding evacuation of aircraft in case of 

emergency. 

2. Aircraft equipped with servicing fixtures or panels within the aircraft may not be serviced while 

passengers are on board. 

3. For all servicing requirements always refer to the appropriate maintenance manuals. 

B. Storage 

Oxygen and nitrogen cylinders shall be stored with the dust caps on the connectors and in area av^ay 

from open flames or intense heat. Care should be taken to keep oil, grease and other contaminants 

away from the area where oxygen and nitrogen cylinders are stored. 

12.2 Usage of Landing Gear Pins 

Anytime maintenance personnel install any of or all landing gear pins, into the landing gear, for any 

reason, it is required that you make an entry in the Aircraft Maintenance Flight Logbook stating: 

"Landing gear pin installed, remove before flight". 

Once the landing gebr pin is removed, yau a\e required to sign ihe co;iec'.ivL- dCLio i bloci, ofi a'.-

removing the landing gear pins. 

Zo//>-<^B:^ 

Rev.: 8 ^-*., ^ t^ t Chapter; 3 

Eff.: 05/17/07 S^^__. _ I Page: 70 

A I R L r NI E S I 
1/24.9008 3:06-34 PM 

Self Disclosure Details 

Notification ID: 1636 

EJR Number: 200SCE034004 

EIR Status: OPEN 

Current Stage: WR 

Notification Title: A/C flew with Ldg Gear Pin installed 

Initial Notification 

Submited By: Jeffrey Craig 

Designator ID: N6WA 

Designator Name: GoJet Airlines, LLC 

Business Concern: Large Business Concern 

Was Alleged Violation Discovered as the Result of an Aviation Safety Action Program (ASAP) 

Report: No 

Was Alleged Violation Discovered During Air Carrier Program (ACEP) Evaluation: No 

Did Non-Compliance Cease after Detection: Yes 

Is Evaluation Underway to Determine Systemic Problem: Yes 

Will Written Report be Submitted in 10 Working Days: Yes 

Inspector Code: CE03GJC 

Insjvjftui Nnnit: Cini>'Ccioj^c; 

Inspector Type; PMl 

Notification Mode; Web 

Notification Date: 11/26/2007 13:00 

INFORMATION OF THE PERSON PREPARING COMPREHENSIVE FIX: : 

Name: Jeffrey Craig 

Contact Information:314 222-4790 

DESCRIPTION OF ALLEGED VIOLATION: -^j/ ^ 

GoJet Airlines operated N15 IGJ with the gear pin installed in the left main landing gear. Mechanic 

forgot to remove the left main landing gear pin after replacing the number 2 brake^^ssembl^^^^^^^^^ 

^ r ^ I EXHIBIT 

DESCRIPTION OF IMMEDIATE ACTION: ^.0?, ^ \ \ /^-9 " 

SD-Detail Pnnter Fnendly Page ' ' 1 ^ \ ^ mhi i fib f^3ioKyoo^ 
1/24/2008 3:06:34 PM 

Aircraft returned from flight due landing gear would not retract. Had maintenance inspect aircraft, 

found lef main landing gear pin installed. Sent Aircraft to the maintenance hangar to perform 

operational check of landing gear retraction / extension system. 

COMMENTS: 

Initial Notification Response 

Is Valid SD?: Yes 

Investigation Commence Date: 1/1/1900 

Submitted By: Gary Cooper 

Submitted Date: 11/29/2007 

BRIEF DESCRIPTION IF NOT VALID SD: 

Written report 

Written Report Date: 12/4/2007 

full Report: Yes 

Discover Date, Time: 11/26/2007 13:00 

Submitted ^y. 3effve\' Craie 

Submitted Date: 12/10/2007 

Violation Location: St. Louis Missouri 

WR Version: 1 

REASON OF INCOMPLETE WRITTEN REPORT: 

DETAILED SELF DISCLOSURE (VIOLATION) DESCRIPTION: 

GoJet Airlines operated Nl5IGJ with the landing gear pin installed in the left main landmg 

gear. Aircraft returned from flight. 

ANALYSIS SUMMARY: 

While changing the left inboard main brake assembly, the mechanic installed the and landing gea& 

SD-Detai] Printer Friendly Page Page 2 of 5 
1/24/2008 3:06.34 PM 

pin in the left main landing gear. After completing the brake change, the mechanic failed to remove 

the landmg gear ptn from the left main landing gear. 

GoJet Airlines General Maintenance Manual (volume one,chapter 3 part 12.2) requires you to make 

an entiy in the Aircraft Mamtenance Flight Logbook stating 'Landing gear pin installed, remove 

before flight'. This was not done. 

This was detected by the landing gear not retracting after take off. 

REASON WHY THE VIOLATION WAS INADVERTENT: 

Human Factors; At the time of replacing the brake assembly, the mechanic failed to recall the 

procedures outlined in the GMM to generate a log book discrepancy. 

EVIDENCE DESCRIPTION: 

N/A 

Certificate Type: sch cargo carrier 121 &/or 135 

Time Violation Remained Undetected: 0 Cycles / 

Immediate Action Date: 11/26/2007 

Company Name/Address: GoJet Airlines, LLC/11495 Navaid Road Suite 303 , ,Bridgeton,MO63044 

Equipment: Type-Aircraft, Make-CNDAIR, Model-CL6002C10, group-CL600. 

Aircraft Registration Number: N151GJ 

IMMEDIATE ACTION DESCRIPTION: 

Sent aircraft to the maintenance hanger to perform operational check of landing gear retraction / 

extension system. 

FARCODE(S): 

43.13A - REQUIREMENTS FOR PERFORMING MAINTENANCE, ALTERATION OR PREVENTIVE MAINTENANCE ON A PRODUCT 

PERSONNEL INFORMATION: 

Immediate Action - Craig, Jeffrey, jcraig@gojetairlines.com, 3142224790 x 

Comprehensive Fix - Craig, Jeffrey, jcraig@gojetairlines.com, 3142224790 x 

Discovered Alleged Violation - Craig, Jeffrey, jcraig@gojetairlines.com, 3142224790 x 

Filing Report - Craig, Jeffrey, jcraig@gojetairlines.com, 3142224790 x 

Monitoring implementation of Fix - Craig, JeffreyJcraig@gojetairlines.com, 3142224790 x _ 

SD-Detail Printer Friendly Page Page 3 of 5 
/24/200S 3:06:34 PM 

COMPREHENSIVE FIX PROPOSAL: 

Step Title 

Counsoling / training 

Begin Date 

11/26/2007 

End Date 

11/30/2007 

Name 

Jeffrey Craig 

Details 

The Mechanic was counseled on the mandatory procedures outlined m the General Mamtenance 

Manual that requires you to make an entry in the Aircraft Maintenance Flight Logbook stating 

'Landing gear pin installed, remove before flight'. 

Written Report Review 

Designator: N6WA 

Comprehensive Fix Status: AMMEND 

Comprehensive Fix Implementation Deadline: 2/7/2008 

Inspector Name: Gary Cooper 

Inspector Code: CE03GJC 

Inspector Type: PMI 

2150.3 FORM: 

Ojicration T>'pe: air can-ier - 1 2 I 

Operation Subtype: scheduled passenger 

Violation Category: maintenance 

Violation Source: self disc - flight standards 

Problem Category: maintenance 

Problem Code: other remarks 

Review Date: 

Fix Description: personnel-organization 

SD Identity: sd sched air carrier 121 

Accident Type: no accident 

Management Intervention: No 

Submitted Date: 1/24/2008 

SD-Detail Pnnter Friendly Page P^S^ "^ °f ^ 
J/24/200S 3•06-34 PM 

Additional Comments: The following items neeed to be addressed and a comprehensive fix 

established, as described in FAA Order 8900.1, no later than Febiuan,' 7, 2008. 

1. DESCRIPTION OF ALLEGED VIOLATION: Please clarify, current description does not 

mention the GMM required logbook entry, for the eear pins being installed, was not made. 

2. DETAILED SELF DISCLOSURE (VIOLATION) DESCRIPTION: Go mto the details of the 

violation (who, what, when, and why) provided in the DESCRIPTION OF ALLEGED VIOLATION 

section (include GMM logbook requirement). 

3. REASON WHY THE VIOLATION WAS INADVERTENT: Please clarify if this is a frequent 

occurance, or isolated incidient (i.e., during the previous twelve months no other landing gear 

pins/twenty-four landing gear pins were left in the gears following maintenance). 

4. COMPREHENSIVE FIX PROPOSAL: The proposed comprehensive fix does not preclude 

recuiTcnce of this violation. The mechanic involved knew of the GMM requirement to make a 

logbook entry stating the landing gear pin was installed prior to this incident, and yet still forgot to 

make the entry. Counseling (reminding) the mechanic of the GMM requirement does not meet the 

guidance in FAA Order 8900.1, Volume 11, Chapter 1, paragraph 11 -4. The comprehensive fix 

should prevent the same mechanic, or any other mechanic, from forgetting to make the logbook 

entry and subsequently forgetting to remove the gear pins following maintenance again. 

QUESTIONS: 

1. Does the specific maintenance manual procedure call for the gear pins to be installed? 

2. Does the specific maintenance manual procedure call for the gear pins to be removed? 

3. Is there any company procedures requiring the flight crew to conduct a walk around, following 

mamtenance actions, paying particular attention to the areas where maintenance was perfonned? 

SD-Detail Printer Friendly Page Page 5 of 5 
o 

U.S. Department Si. Louis FJight Standards DisUict Office 

of Transportation ] 0801 Pear Tree Lane 

Federal Aviatiou Suite 200 

Administration St. Arm, Missouri 63074 

January 25, 2008 

GoJet Airlines, LLC 

Mr. Richard Leach, Chief Operating Officer 

11495 Navaid Road, Suite 303 

Bridgeton, MO 63044 

Dear Mr. Craig; 

This letter is to infortn you of two self-disclosures submitted by GoJet Airhnes to this office using 

the web based VDR? (Voluntary Disclosure Reporting Program). These self-disclosures were 

returned on January 23 and 24, 2008 to GoJet for additional action/mfomiatiou, as defined below 

and m the web based VDRP system. The items listed for each disclosure need to be addressed 

and a comprehensive fix established, as described m FAA Order 8900T, by close of business on 

February 8, 2008. Failure to provide a comprehensive fix acceptable to this office by the close of 

business on February 8, 2008 will result in the self-disclosures being closed out of the web based 

VDRP system and processed as enforcements utilizing FAA Order 2150.3. 

^j- ^ A. First Disclosure 

^ p 2008CEQ34QQ3 Thrust Reverser Deferral 

I DESCRIPTION OF ALLEGED VIOLATION: Please clarify. The cunent description does not 

sti'.ir iJKit the riL^hl thi'iisi re\'erse.r was deferred impioperh . lesulting in both ihriisl re\'ersers being 

Lie;icii\Lii-^'d. \N]iich IS co]Urar\ lu the Ml:L. and ilic :iiiL!-;!ii l\^-\\ [Y\\\.^ \]\'Su\-. m iii.,[ (.ondiijoi'i 

2. DESCRIPTION OF IMMEDIATE ACTION; Please clarify the immediate action taken to 

termmate the conduct that resulted in the apparent violation, including when it was taken, and who 

was responsible for taking the action. 

3. DETAILED SELF DISCLOSLTRE (VIOLATION) DESCRIPTION: Go mto details of the 

violations (who, what, when, how) provided in DESCRIPTION OF ALLEGED VIOLATION 

section, providing date and location maintenance defeual occurred, and dates and locations of 

flights flown while in that condition. 

4. ANALYSIS SUMMARY: Please clarify the aircraft was flown after the flight crew/s identified 

both thrust reversers were inadvertently deactivated following the deferral of the nght thnisl 

reverser. Also, please include any conclusions reached regai'ding possible or probable systemic 

deficiencies. 

x ^ 

F EXHIBIT 

^ 1 A ^ AyJ J *. 
5. REASON WHY THE VIOLATION WAS ]"NADVERTENT: None piovided earlier. 

6. EVIDENCE DESCRIPTION: None jirovided eailiei. 

7. FAR CODE(S): FAR 121.153(a)(2) was not included 

8. COMPREHENSIVE FIX PROPOSAL; None provided earlier. 

B. Second Disclosure 

2008CE0340Q4 A/C flew with Ldg Gear Pin installed 

1. DESCRIPTION OF ALLEGED VIOLATION: Please clarify, cunent descnption does not 

mention the GMM required logbook entiy, for the gear pins being installed, was not made. 

2. DETAILED SELF DISCLOSLJRE (VIOLATION) DESCRIPTION; Go mto the details of the 

violation (who, what, when, and why) provided in the DESCRIPTION OF ALLEGED 

VIOLATION section (include GMM logbook requirement). 

3. REASON WHY THE VIOLATION WAS INADVERTENT: Please clarify if this is a firequent 

occurrence, or isolated incident (i.e., during the previous twelve months no other landing gear 

pins/twenty-four landing gear pins were left in the gears following maintenance). 

4. COMPREHENSIVE FIX PROPOSAL: The proposed comprehensive fix does not preclude 

recurrence of this violation. The mechanic involved knew of the GMM requirement to make a 

logbook entry stating the landing gear pin was installed prior to this incident, and yet still forgot to 

make the entry. Counseling (reminding) the mechanic of the GMM requirement does not meet the 

guidance in FAA Order 8900.1, Volume II, Chapter 1, paragraph 11-4. The comprehensive fix 

should prevent the same mechanic, or any other mechanic, fi-om forgetting to make the logbook 

entry and subsequently forgetting to remove the gear pins following maintenance again. 

QLTSTIO^- ^ 

1. Does the specific maintenance manual procedure call for the gear pins to be installed? 

2. Does the specific maintenance manual procedure call for the gear pins to be removed? 

3. Is there any company procedures requiring the fiight crew to conduct a walk around, following 

maintenance actions, paying particular attention to the areas where maintenance was perfomied? 

n.H ^> 
Please note the submitted comprehensive fixes to these disclosures should address (what appears 

to be) a systemic issue of maintenance personnel not followmg e.'^tablished maintenance 

procedures and logbook entries not being made to address maintenance issues. I can be reached 

at (314) 890-4812 if you need additional information. 

Sincerely, 

Gary J. Cooper 

Prmcipal Maintenance hispector 

cc: Richard Leach, Chief Operating Officer 

?)H' J 
U.S. Depailment 

of Transportation 

Federal Aviation 

Administration 

Januai7 25,200S 

GoJet Airlines, LLC 

Mr. Richard Leach, Chief Operating Officer 

11495 Navaid Road, Suite 303 

Bridgeton, MO 63044 

Dear Mr. Craig: 

St. Louis Flight Standards District Offi 

lOSOl Pear Tree Lai! 

Suite 2 

St. Ann, Missouri 630 

INI 

te 

{JO 

iNITIALS/SIG 

^ 

/ ^ 

This letter is to inform you of two self-disclosures submitted by GoJet Airlines to this office usi ig CuJP 

the web based VDRP (Voluntary Disclosure Reporting Progiam). These self-disclosures were 

returned on January 23 and 24, 2008 to GoJet for additional action/information, as defined bela 

and in the web based VDR? system. T\\^ items /isted for each disc/osure need lo be addressed 

and y comprehensive fix established, as described in FAA Order 8900.1, by close of business or 

February 8, 2008. Failure to provide a comprehensive fix acceptable to this office by the close t 

business on Februaiy 8, 2008 will result in the self-disclosures being closed out of the web base 

VDRP System and processed as enforcements ufilizing FAA Order 2150.3. 

A. First Disclosure 

2008CE034003 Thrust Reverser Deferral 

1. DESCRIPTION OF ALLEGED VIOLATION: Please clarify. The cun-ent description does nc 

slate that the right thrust reverser was deferred improperly, resulting in both thrust reversers 

deactivated, which is contrar>' to the MEL, and the aircraft flew three flights in that condition. 

beibs 

2. DESCRIPTION OF IMMEDIATE ACTION: Please clarify the immediate action taken to 

temiinate the conduct that resulted in the apparent violation, including when it was taken, and wjh'e'""'^^'^!^ 

was responsible for taking the action. 

3. DETAILED SELF DISCLOSURE (VIOLATION) DESCRIPTION: Go into details of the 

violations (who, what, when, how) provided in DESCRIPTION OF ALLEGED VIOLATION 

section, providing date and location maintenance deferral occurred, and dates and locations of 

flights flown while in that condition. 

C0NC£3tENCC.<; 

IITG SYMBOL 

IIALS/SIG 

TE 

l/iir 

4tTG SYMBOL 

f/ntr 

INtTlALS/SlG 

DATE 

//^y/r i Ci.'6 1* 

RTG SYMBOL 

INITlAUjtSlG 

DATE 

vrasvMpo 

(RTG S^THBOL 

INmALSraiG 

DATE 

RTG SYMBOL 

[NITFALSJSIG 

BATE 

RTG SYMBOL 

DATE 

RTG SYMBOL 

INrriALS/SIG 

DATE 

4. ANALYSIS SUMMARY: Please clarify the aircraft was flown after the flight crew/s identifi4d_ 

botli tliTust reversers were inadvertently deactivated following the defeual of the right thnisl 

reverser. Also, please include any conclusions reached regai'ding possible or probable systemic 

deficiencies. 

FAA FORM 1300-14(6-81) 

9 

OFHCIAL OFFICE COPY 

- ^ 

t ,g" / 

USGPC1M1-0-5B8-425 

EXHIBIT 

,xf/ 

' ^ ^ \ ^ 

"> 

^ih_^±^i^oo9<r\ 
5. REASON WHY THE VIOLATION WAS INADVERTENT: None provided earlier. 

6. EVIDENCE DESCRIPTION: None provided earlier. 

7. FAR CODE(S): FAR 121.153(a)(2) was not included. 

8. COMPREHENSIVE FIX PROPOSAL: None provided eailier. 

B. Second Disclosure 

CONCEKENCES 

RTG SYMBOL 

INmALS/SIG 

DATE 

RTG SYMBOL 

2008CE034004 A/C flew with Ldg Gear Pin installed 

1. DESCRIPTION OF ALLEGED VIOLATION: Please claiify, cunent description does not 

mention the GMM required logbook entry, for the gear pins being installed, was not made. 

2. DETAILED SELF DISCLOSURE (VIOLATION) DESCRIPTION: Go into the details of the 

violation (who. what, when, and why) provided in the DESCRIPTION OF ALLEGED 

VIOLATION section (include GMM logbook requirement). 

3. REASON WHY THE VIOLATION WAS INADVERTENT: Please clarify if this is a freque 

occurrence, or isolated incident (i.e., during the previous twelve months no other landing gear 

pins/twenty-four landing gear pins were left in the geais following maintenance). 

It 

4. COMPREHENSIVE FIX PROPOSAL: The proposed comprehensive lix does not preclude 

recurrence of this violation. The mechanic involved icnew of the GMM requirement to make a 

logbook entry stating the landing gear pin was installed prior to tliis incident, and yet still forgol 

make the entry. CounseHng (reminding) the mechanic of the GMM requirement does not meet t 

guidance in FAA Order 8900.1, Volume 11, Chapter 1, paragraph 11 -4. The comprehensive fix 

should prevent the same mechanic, or any other mechanic, from forgetting to malce the logbook 

entry and subsequently forgetting to remove the gear pins following maintenance again. 

QUESTIONS: 

1. Does the specific maintenance manual procedure call for the gear pins to be installed? 

2. Does the specific maintenance manual procedure call for the gear pins to be removed? 

3. Is there any company procedures requiring the flight crew to conduct a walk around, followir ^ 

maintenance actions, paying particular attention to the ai-eas where maintenance was performed 

JNITIALS/SJG 

DATE 

RTG SYMDOL 

INITIAIJ/SIG 

DATE 

RTG SYMBOL 

fNmALS^lG 

DATE 

RTG SYMBCH. 

INmAL5/SIG 

DATE 

le 

RTG SYMDOL 

INmALS/SIG 

DATE 

RTG SYMDOL 

INIT[ALS/S1G 

DATE 

J RTG SYMBOL 

INmALSiBKj 

DATE 

FAA FORM I360-M(fi-B)) OFFICIAL OFHCE COPY US CPC 1931-0-588-^25 

•} ^ 

• ^ 
Please note the submitted comprehensive fixes to these disclosures should address (what appeal 

to be) a systemic issue of maintenance personnel not following established maintenance 

procedures and logbook entries not being made to address maintenance issues. 1 can be reached 

a( (314] 890-4S12 if you need additional information. 

Sincerely, 

Gary I. Cooper 

Principal Maintenance hispector 

cc: Richard Leach, Chief Operating Officer 

CONCERENCES 

.RTG SYMDOL 

INITIALS/SIG 

DATE 

HTG SYMBOL 

INITIALS/SIC 

DATTi 

UTG SYMBOL 

imnMSfSlG 

DATE 

RTG SYMBOL 

INITIALS/SIG 

DATlRTG SYMBOL 

INmAUi/SlG 

DAl^ 

RTG SYMBOL 

fNTTIALS/SlG 

DATE 

RTG SYMDOL 

INITIALS/SIG 

DATE 

RTG SYNfBOL 

tNirULS/SIG 

DATE 

FAA FORM 1360-14 (6-61) OFHCIAL OmCE COPY USCPC 199I-0-SB8.425 
o 

U.S. Depailment 

ofTransportation 

Federal Aviatiou 

Administration 

May 1,2008 

GoJel Airiines, LLC 

Mr. Richaj'd Leach, Chief Operating Officer 

11495 Navaid Road, Suite 303 

Bridgeton, MO 63044 

Dear Mr. Leach: 

St. Louis Flight Staadai'ds District Offi 

10801 Pear Tree 

Suite 

St. Ajin, Missouri 630 

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The purpose of this letter is to follow-up our letter sent to you on Januai^ 25, 2008, and to inforin 

you both seJf-discJosures referenced in our letter were rescindedydosed out in the VDRP systen 

February 15, 2008, and aie currently being processed using traditional enforcement methods in 

FAA Order 2150.3B. As such, the tracking numbers in the VDRP were closed and new EfR 

numbers were established. The new numbers, as well as the old numbers used in the VDRP 

system, are listed below for your information. 

A. First Disclosure; Thrust Reverser Defen'al 

Old VDRP tracking #2008CE034003 New EIR tracking #2008CE030046 

B. Second Disclosure: A/C flew with Ldg Gear Pin installed following mainteance 

Old VDRP tracking #2008CE034004 New EIR tracking #2008CE030045 

If you have any questions or need additional infomiahon lean be reached at (314) 890-4812. 

Sincerely, 

Gary J. Cooper 

Principal Maintenaiice Inspector 

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noncompliance and to invest more resources in efforts to preclude their recurrence. The FAA's 

policy of forgoing civil penalty actions when one of these entities detects violations, promptly 

discloses the violations to the FAA, and takes prompt corrective action to ensure that the same or 

similar violations do not recur is designed to encourage compliance with FAA regulations, foster 

safe operating practices, and promote the development of internal evaluation programs. 

11-4. KEY TERMS. The following key terms and phrases are defined to ensure a standard 

interpretation and understanding of FAA voluntary disclosure policy. 

A. Evidence. For the purpose of voluntary disclosure, evidence generally should be in 

the form of written documentation or reports that support a certificate holder's, qualified 

fractional ownership programs, or PAH's analysis of the disclosed apparent violation and the 

resulting elements of the proposed comprehensive fix. Evidence generally comes from the 

following four elements; 

1) Documents or manuals reviewed. 

2) Equipment examined. 

3) Activities observed. 

4) Interview data. 

B. Comprehensive Fix. 

1) A comprehensive fix is an action, or actions, proposed by the certificate holder, 

qualified fractional ownership program, or PAH and accepted by the principal inspector (PI) (see 

definition in subparagraph 11-4D below) to preclude recurrence of the apparent violation that has 

been voluntarily disclosed under this program. 

2) A schedule of the dates and events encompassed by the comprehensive fix must 

be established and included in a letter of correction. 

C. Satisfactory Fix. A satisfactory fix is a comprehensive fix, in which all corrective 

measures have been completed on schedule and are satisfactory to the FAA. 

D. PI. Under the Voluntary Disclosure Reporting Program (VDRP), PI refers to the 

appropriate maintenance, avionics, operations inspector, or other designated FAA official of the 

program office responsible for oversight of the area of noncompliance involved in the disclosure. 

NOTE: The designated FAA official for voluntary disclosure concerning antidrug and alcohol misuse prevention program violations is the Branch Manager, 

Compliance and Enforcement Branch, Drug Abatement Division, FAA 

Headquarters; 

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E. Qualified Fractional Ownership Programs. Fractional Ownership Programs are 

defined in 14 CFR, Part 91, Subpart K, and associated Management Specifications (MSpecs). 

Participation ofFractional Ownership Programs is limited as follows: 

1) Only program managers authorized in accordance with 14 CFR Part 91, 

Subpart K and MSpecs, may participate in the VDRP. 

2) Voluntary Disclosures of apparent violations by a fractional ownership program 

may only be submitted by the program manager, or an authorized representative. 

3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violations pertaining directly to the duties and responsibilities of the program manager, as 

defined in 14 CFR Part 91, Subpart K and MSpecs. 

11-5. VOLUNTARY DISCLOSURE POLICY. It is FAA policy that the open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs , and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances of noncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this section. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

A, In evaluating whether an apparent violation is covered by this policy, the responsible 

inspector will ensure that the following five conditions are met: 

1) The certificate holder, qualified fractional ownership program, or PAH has 

notified the FAA of the apparent violation immediately after detecting it and before the agency 

has learned of it by other means. 

2) The apparent violation was inadvertent. 

3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactory to 

the FAA. The comprehensive fix includes a follow-up self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

B. Except as specified in subparagraph 11-6B below, the FAA ordinarily will not forgo 

legal enforcement action if the certificate holder, qualified fractional ownership program, or 

PAH informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation/linspection or in association with an accident or incident. 

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C. The procedures to be followed when applying the voluntary disclosure policy are 

further described in the following paragraphs. 

11-6. PHASE I—NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. 

Except as specified below, the voluntary disclosure policy applies only when notification of an 

apparent violation is made to the FAA by the certificate holder, qualified fractional ownership 

program, or PAH immediately after the apparent violation has been discovered by that regulated 

entity, and before the FAA learns of the apparent violation by some other means. 

A. Notification by the Certificate Holder, Fractional Ownership Program, or the 

PAH of an Apparent Violation. Initial notification of an apparent violation by eligible 

regulated entities may be submitted orally, via a written hardcopy, or by electronic copy. 

However, compliance with the 10 (or 30) day limit (see subparagraph 11-8F) for submission of 

the written report will be based on the date of tlie original notification, regardless of the 

submission means or media. A recommended format for written voluntary disclosures by 

regulated entities that are not authorized use of the web-based VDRP (see subparagraph 11-6C 

below) is provided in paragraph 11-17. When a certificate holder, fractional ownership program, 

or PAH notifies the FAA of an apparent violation, contact must be made with, or directed to, the 

appropriate PI. (Note: For those operators utilizing the web-based VDRP system, this 

notification is automated upon submission of the voluntary disclosure by the regulated entity and 

no further notification is required) It is FAA policy that initial notificafion should be 

accomplished on a fimely basis, ordinarily within 24 hours of the discovery of the apparent 

violation. However, an inspector may accept disclosures that exceed the 24 hour policy when the 

inspector determines that a later submission is justified based on the specific circumstances, and 

in view of those circumstances, the submission is still considered timely. For example, a 

voluntary disclosure based on a company violation revealed in an Aviation Safety Action 

Program (ASAP) report may require more that 24 hours from the submission of that ASAP 

report in order for the responsible company entity to become aware of the informafion in the 

report and to initiate a voluntary disclosure. The FAA retains sole discretion in determining 

whether a voluntary disclosure received later than 24 hours after discovery of the violation is 

timely. The certificate holder, fractional ownership program, or PAH should therefore not delay 

notification for any reason, and should address, to the maximum extent possible, the following 

items with the PI: 

1) A brief description of the apparent violation, including an estimate of the duration 

of time that it remained undetected, as well as how and when it was discovered. 

2) Verification that noncompliance ceased after it was identified. 

3) A brief description of the immediate action taken after the apparent violation was 

identified, the immediate action taken to terminate the conduct that resulted in the apparent 

violation, and the person responsible for taking the immediate action. 

4) Verification that an evaluation is underway to determine if there are any systemic 

problems and a description of the corrective steps necessary to prevent the apparent violation 

from recurring. 

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5) Identification of the person responsible for preparing the comprehensive fix. 

6) Acknowledgment tliat a detailed written report will be provided to the PI within 

10 working days, except as noted in subparagraph 8F of this chapter. 

B. Exceptions. If the FAA has learned of an apparent violation by a certificate holder, 

fractional ownership program, or PAH from an ASAP report as described in the current edition 

of AC 120-66, Aviation Safety Action Program, a voluntary disclosure can still be accepted by 

the FAA, even though the FAA has already learned of the violafion from the ASAP. Similarly, if 

a regulated entity voluntarily agrees to conduct a joint audit (inspection) with the FAA during 

which an apparent violation is discovered either by the company or FAA members of the audit 

(inspection) team, the FAA may accept a voluntary disclosure submitted by the company, even 

though the FAA has already learned of the apparent violation during the course of the joint audit 

(inspecfion). 

C, Use of the Web-Based VDRP for Notification of an Apparent Violation. For 

authorized users of the web-based VDRP, notification will normally be made via the web tool 

discussed in paragraph 11-19. Effecfive December 8, 2006, use of this tool is required for 

voluntary disclosures submitted by certificated air carriers. Future expansion of the tool may 

include other regulated entities, as noted in paragraph 11-19. 

1) Submission of a voluntar)' disclosure via the web-based VDRP system will result 

in automated notification of the Pis assigned to that certificate. 

2) The web-based VDRP system contains provisions for indicating that the 

notification process was begun via another media. When acceptable to the PI, initial notice by an 

authorized user of the web-based VDRP may be submitted orally, via a written hardcopy, or by 

electronic copy; provided, the regulated entity enters the initial notification data via the 

web-based VDRP system within 72 hours of the original notification. However, compliance with 

the 10 (or 30) day limit for submission of the written report will be based on the date of the 

original notification, regardless of the submission means or media. 

NOTE; In the case of voluntary disclosures submitted via the web-based VDRP, 

notification of the PI is accomplished by the program upon submission of the 

voluntary disclosure by the regulated entity. No further notification is required of 

the regulated entity. 

11-7. PHASE II—FAA RESPONSE TO CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH NOTIFICATION. The PI responds with a written or 

electronic acknowledgment of the entity's initial notification. This acknowledgment includes the 

request for a written report and is sent in lieu of a letter of investigation; provided, the written 

report is completed in accordance with the voluntary disclosure reporting procedures set forth in 

this section and paragraph 11-1. The PI will open an Enforcement Investigative Report (EIR) 

that will be closed out with a letter of correction, following satisfactory development of a 

comprehensive fix and schedule of implementation agreed upon by the FAA and the entity. 

VDRP fix codes, an inspector^clerical self-disclosure package checklist, FAA Form 2150-5 self 

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8900.1 CHGO 9/13/2007 

disclosure worksheet, and a sample FAA initial notification acknowledgment letter is provided in 

paragraph 11-18. 

NOTE: When the regulated entity has submitted the voluntary disclosure via the 

web-based VDRP, action on the voluntary disclosure by the PI results in an 

automated electronic reply to the regulated entity and an automated opening of the 

Enforcement Investigative Report (EIR), to include automated assignment of the 

EIR number. When the inspector is not utilizing the web-based VDRP system, the 

inspector shall obtain an EIR number in accordance with established local office 

procedures for issuance of Enforcement Investigation Numbers. 

11-8. PHASE in—WRITTEN REPORT OF CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH'S APPARENT VIOLATION. The written report 

should be provided to the PI, by the regulated entity, within 10 working days after the initial 

notification was made, except as noted in subparagraph 11-8F below. A sample format for this 

report is provided as paragraph 11-17. In summary, the written report should include the 

following information: 

A. A list of the specific FAA regulations that may have been violated. 

B. A description of the apparent violation, including the duration of time it remained 

undetected, as well as how and when it was detected. 

C. A description of the immediate action taken to terminate the conduct that resulted in 

the apparent violation, including when it was taken, and who was responsible for taking the 

action. 

D. An explanation that shows th^ apparent violation was inadvertent. 

E. Evidence that demonstrates the seriousness of the apparent violation and the regulated 

entity's analysis of that evidence. 

F. A detailed description of the proposed comprehensive fix, outlining the planned 

corrective steps, the responsibilities for implementing those corrective steps, and a time schedule 

for completion of the fix. If a proposed comprehensive fix is not fijlly developed within 

10 working days, the pertinent regulated entity should provide at least an overview of its 

comprehensive fix plans in a written report submitted within 10 working days after the initial 

notification was made. In any event, a detailed description of the comprehensive fix should be 

submitted within 30 calendar days after initial notification. 

G. Identification of the company official responsible for monitoring the implementation 

and completion of the comprehensive fix. 

NOTE: For regulated entities authorized used of the web-based tool for VDRP 

submissions as described in paragraph 11-19, entry of the Phase III information 

will be accomplished using the web-tool. 

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11-9. PHASE IV—WRITTEN REPORT REVIEW BY THE FAA. The FAA works with 

the certificate holder, fractional ownership program, or PAH to ensure that the regulated entity 

has identified any root causes and systemic issues which led to the apparent violation. This 

collaboration helps to ensure that the corrective actions contained in the comprehensive fix are 

acceptable to the FAA. 

NOTE: Should investigation of the apparent violation result in a determination 

that no violation occurred, the EIR may be closed utilizing a Code 14 (No Action) 

in block 25 when closing a self-disclosure with "No Action," the inspector closing 

the case must indicate the reason for the closure without action as indicated 

below: 

1) When processing a voluntary disclosure on paper, the inspector should enter that 

explanation in the Corrective Action Plan Block on the FAA Form 2150-5 (or 2150 worksheet as 

applicable). 

2) When processing a self-disclosure utilizing the web-based system, the inspector is 

presented with the question, "Is the Self-Disclosure Approved or Rescinded?" To rescind the 

Self-Disclosure the inspector will select the option, "Rescinded" and, in the text box labeled, "If 

Rescinded, Explain," the inspector will enter an explanation for the closure with no action. The 

explanation for closure with no action may be a simple statement that the investigation 

established that no violation occurred, or it may contain as much detail as deemed necessary to 

explain the inspector's decision. 

3) When closing a voluntary disclosure via the manual system without action, the 

inspector has the option of entering or not entering problem codes, fix codes, and regulations 

violated. In the web-based program, if those items have already been entered and captured by the 

system, the inspector cannot delete those fields, but the report will be closed and recorded as 

having no action taken based on the explanation provided by the inspector in the explanation 

field. 

11-10. PHASE V—IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA 

SURVEILLANCE. 

A. During the implementation period, the FAA and the pertinent regulated entity should 

continue to work together. The FAA may advise and assist the entity in correcting any identified 

systemic problems. Changes will be made to the proposed comprehensive fix when the need is 

identified. Upon determining that the initial implementation of the comprehensive fix is 

satisfactory, the PI will issue a letter of correction. Should a change to the comprehensive fix be 

identified after issuance of the letter of correction, the PI will issue an amendment to the letter of 

correction that reflects this change. 

B. The FAA monitors the implementation of the corrective steps. Throughout the 

implementation period, the FAA assesses the pertinent regulated entity's corrective efforts and 

top management's awareness of these efforts. If, during this period, the FAA determines that the 

steps taken by the entity are not those documented in the comprehensive fix, the letter of 

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8900.1 CHGO 9/13/2007 

correction may be rescinded, the investigative report may be reopened, and appropriate legal 

enforcement action may be initiated. 

11-11. PHASE VI—INSPECTOR SIGNOFF. At the conclusion of the implementation period, 

the PI makes a final assessment. If all elements of the comprehensive fix have been adequately 

accomplished, the PI finds the fix satisfactory and closes the case. The case remains subject to 

reopening in the event that the agreed-upon actions, outlined in the comprehensive fix, are not 

completed to the satisfaction of the FAA. A statement of follow-up investigation, confirming that 

the comprehensive fix was satisfactorily implemented and completed, is prepared to complete 

the FAA's investigative package. 

A. The PI has the authority to close the case. Consultation with regional specialists, legal 

counsel, or other FAA personnel may be accomplished when deemed appropriate by the PI. 

B. Following completion of the agreed-upon corrective action(s), the certificate holder, 

fractional ownership program, or PAH conducts a self-audit to ensure that the action taken 

remedies the problem that gave rise to the apparent violation. 

C. If, following FAA closure of the investigative package resulting from a voluntary 

disclosure, the same or similar violations are discovered to have occurred prior to submission of 

the associated voluntary disclosure, the FAA does not reopen the case unless it determines that 

the pertinent regulated entity failed to comply with all the elements of the comprehensive fix 

agreed upon by the FAA and the entity. 

11-12. DISPUTE RESOLUTION. When disputes occur regarding the acceptance of a 

proposed comprehensive fix, or a modification thereto before the fix is considered satisfactory, 

the principal inspector and the pertinent regulated entity may request that the issue be resolved at 

the next level of management within the FAA. This procedure will provide for an independent 

assessment of the areas in disagreement. 

11-13. SEPARATE ACTIONS AGAINST AIRMEN OR OTHER INDIVIDUAL 

AGENTS. 

A. The voluntary disclosure policy applies to individual airmen or other agents of an 

employing certificate holder, fractional ownership program, or PAH when the following occurs: 

1) The apparent violation involves a deficiency of the employing entity's practices 

or procedures that causes the employing certificate holder, fractional ownership program, or 

PAH to be in violation of a covered violation of an FAA regulation. 

2) The airman or other agent of the employing entity, while acting on behalf of the 

employing entity, inadvertently violates the FAA's regulations as a direct result of a deficiency 

of the employing entity that causes the employing entity to be in violation of the regulations. 

(The voluntary disclosure policy does not apply to the airman or other agent when his/her 

apparent violation is the result of actions unrelated to the employing entity's deficiency). 

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' \ 
AC 00-58A 9/8/06 

b. Except as specified in paragraph 14 of this AC, the Voluntary Disclosure Reporting 

Program does not apply to violafions by individual airmen. 

4. BACKGROUND. Civil penalties, under the FAA's enforcement program, have always 

been considered a means to promote compliance with the FAA's regulations, not an end in 

themselves. In addition to the deterrence achieved by the appropriate use of civil penalties, tlie 

public interest is also served by positive incentives to promote and achieve compliance. Indeed, 

the FAA believes that aviation safety is well served by incentives for certificate holders, 

qualified fractional ownership programs, and PAHs to identify and correct their own instances of 

noncompliance and to invest more resources in efforts to preclude their recurrence. The FAA's 

policy of forgoing civil penalty actions when one of these entities detects violafions, promptly 

discloses the violations to the FAA, and takes prompt corrective action to ensure that the same or 

similar violations do not recur is designed to encourage compliance with the FAA's regulations, 

foster safe operating practices, and promote the development of internal evaluation programs. 

5. KEY TERMS. The following key terms and phrases are defined to ensure a standard 

interpretation and understanding of the FAA's voluntary disclosure policy. 

a. Evidence. For the purpose of voluntary disclosure, evidence generally should be in the 

form of written documentation or reports that support a certificate holder's, qualified fractional 

ownership program's, or PAH's analysis of the disclosed apparent violation and the resulting 

elements of the proposed comprehensive fix. Evidence generally comes from the following four 

elements: 

(1) Documents or manuals reviewed. 

(2) Equipment examined. 

(3) Activifies observed. 

(4) Interview data. 

b. Comprehensive Fix. 

(1) A comprehensive fix is an action, or actions, proposed by the certificate holder, 

qualified fractional ownership program, or PAH and accepted by the principal inspector (PI) (see 

definition in paragraph 5d) to preclude recurrence of the apparent violation that has been 

voluntarily disclosed under this program. 

(2) A schedule of the dates and events encompassed by the comprehensive fix must be 

established and included in a letter of correction. 

c. Satisfactory Fix. A satisfactory fix is a comprehensive fix, in which all corrective 

measures have been completed on schedule and are satisfactory to the FAA. 

d. PI. Under the Voluntary Disclosure Reporting Program (VDRP), PI refers to the 

appropriate maintenance, avionics, operations inspector, or other designated FAA official of the 

program office responsible for oversight of the area ofnoncompliance involved in the disclosure. If 

t 

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rA 
9/8/06 AC 00-58A 

NOTE: The designated FAA official for voluntary disclosure concerning antidrug and alcohol misuse prevention program violations is the Branch Manager, 

Compliance and Enforcement Branch, Drug Abatement Division, FAA 

Headquarters. 

e. Qualified Fractional Ownership Programs. Fractional ownership programs are 

defined in part 91, subpart K and associated MSpecs. Participation in the VDRP by a fractional 

ownership program is limited by the following: 

(1) Only program managers authorized in accordance with part 91, subpart K and 

MSpecs, may participate in the VDRP. 

(2) Voluntary disclosures of apparent violations by a fractional ownership program may 

only be submitted by the program manager, or an authorized representative. 

(3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violafions pertaining directly to the duties and responsibilities of the program manager, as 

defined in part 91, subpart K and MSpecs. 

6. VOLUNTARY DISCLOSURE POLICY. The FAA believes that the open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs, and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances ofnoncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this AC. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

a. In evaluating whether an apparent violafion is covered by this policy, the FAA will 

ensure that the following five conditions are met: 

(1) The certificate holder, qualified fractional ownership program, or PAH has notified 

the FAA of the apparent violation immediately after detecting it and before the Agency has 

learned of it by other means. 

(2) The apparent violation was inadvertent. 

(3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

(4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

(5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactory to 

the FAA. The comprehensive fix includes a followup self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

Par 5 Page 3 

[p 
AC 00-58A 9/8/06 

b. Except as specified in paragraph 7c below, the FAA ordinarily will not forgo legal 

enforcement action if the certificate holder, qualified fractional ownership program, or PAH 

informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation/inspection or in association with an accident or incident. 

c. The procedures to be followed when applying the voluntary disclosure policy are further 

described in the following paragraphs. 

7. PHASE I: NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. Except 

as specified below, the voluntary disclosure policy applies only when notification of an apparent 

violation is made to the FAA by the certificate holder, qualified fractional ownership program, or 

PAH immediately after the apparent violation has been discovered by that regulated entity, and 

before the FAA learns of the apparent violation by some other means. 

a. Use of the Web-Based VDRP for Notification of an Apparent Violation. For 

authorized users of the Web-based VDRI^, notification will normally be made via this Web tool 

(see Appendix 1). 

(1) For regulated entities authorized use of the Web-based VDRP, submission of a 

voluntary disclosure via the Web-based VDRP system will result in automated notification of the 

Pis assigned to that certificate. 

(2) The Web-based VDRP system contains provisions for indicating that the notification 

process was begun via another media. When acceptable to the PI, initial notice by an authorized 

user of the Web-based VDRP may be submitted orally, via a written hardcopy, or by electronic 

copy; provided, the regulated entity enters the initial notification data via the Web-based VDRP 

system within 72 hours of the original notification. However, compliance with the 10- (or 30-) 

day limit for submission of the written report will be based on the date of the original 

notification, regardless of the submission means or media. 

NOTE: For regulated entities not yet authorized use of the Web-based VDRP, 

the notification of an apparent violation will be submitted orally, via a written 

hardcopy, or by electronic copy. The format for written voluntary disclosures by 

regulated entities not authorized use of the Web-based VDRP is provided in 

Appendix 2. 

b. Notification by the Certificate Holder, Fractional Ownership Program, or the PAH 

of an Apparent Violation. When a certificate holder, fractional ownership program, or PAH 

notifies the FAA of an apparent violation, contact must be made with, or directed to, the 

appropriate PL It is FAA policy that initial notification should be accomplished on a timely 

basis, ordinarily within 24 hours of the discovery of the apparent violation. However, an 

inspector may accept disclosures that exceed the 24 hour policy when the inspector determines 

that a later submission is justified based on the specific circumstances, and in view of those 

circumstances, the submission is still considered timely. For example, a voluntary disclosure 

based on a company violation revealed in an Aviation Safety Action Program (ASAP) report 

may require more that 24 hours from the submission of that ASAP report in order for the 

responsible company entity to become aware of the information in the report and to initiate a 

voluntary disclosure. The FAA retains sole discretion in determining whether a voluntary I \£ 

^ e\ 

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9/8/06 AC 00-58A 

disclosure received later than 24 hours after discovery of the violation is timely. The certificate 

holder, fractional ownership program, or PAH should therefore not delay notification for any 

reason, and should address, to the maximum extent possible, the following items with the PI: 

(1) A brief description of the apparent violation, including an estimate of the duration of 

time that it remained undetected, as well as how and when it was discovered. 

(2) Verification that noncompliance ceased after it was identified. 

(3) A brief description of the immediate action taken after the apparent violation was 

identified, the immediate action taken to terminate the conduct that resulted in the apparent 

violation, and the person responsible for taking the immediate action. 

(4) Verification that an evaluation is underway to detennine if there are any systemic 

problems and a description of the corrective steps necessary to prevent the apparent violation 

from recun'ing. 

(5) Identification of the person responsible for preparing the comprehensive fix. 

(6) Acknowledgment that a detailed written report will be provided to the PI within 

10 working days. 

NOTE: In the case of voluntary disclosures submitted via the Web-based VDRP, 

notification of the PI is accomplished by the program upon submission of the 

voluntary disclosure by the regulated entity. No further notification is required 

of the regulated entity. 

c. Exceptions. If the FAA has learned of an apparent violation by a certificate holder, 

fractional ownership program, or PAH from an ASAP report as described in the current edition 

of AC 120-66, Aviation Safety Action Program, a voluntary disclosure can still be accepted by 

the FAA, even though the F/VA has already learned of the violation from the ASAP. Similarly, if 

a regulated entity voluntarily agrees to conduct a joint audit (inspection) with the FAA during 

which an apparent violation is discovered either by the company or FAA members of the audit 

(inspection) team, the FAA may accept a voluntary disclosure submitted by the company, even 

though the FAA has already learned of the apparent violation during the course of the joint audit 

(inspection). 

8. PHASE II: FAA RESPONSE TO CERTIHCATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH NOTIFICATION. The PI responds with a written or 

electronic acknowledgment of the entity's initial notification. This acknowledgment includes the 

request for a written report and is sent in lieu of a letter of investigation; provided, the written 

report is completed in accordance with the voluntary disclosure reporting procedures set forth in 

this AC and Appendixes 1 and 2. The PI will open an Enforcement Investigative Report (EIR) 

that will be closed out with a letter of correction, following satisfactory development of a 

comprehensive fix and schedule of implementation agreed upon by the FAA and the entity. 

NOTE: When the regulated entity has submitted the voluntary disclosure via the 

Web-based VDRP, action on the voluntary disclosure by the PI results in an 

Par 7 Page 5 

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AC 00-5 8A 9/8/06 

automated electronic reply to the regulated entity and an automated opening of 

the Enforcement Investigative Report (EIR). 

9. PHASE III: WRITTEN REPORT OF CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH'S APPARENT VIOLATION. The written report 

should be provided to the PI, by the regulated entity, within 10 working days after the initial 

notification was made. A sample format for this report is provided as Appendix 2. In summary, 

the written report should include the following information: 

a. A list of the specific FAA regulations that may have been violated. 

b. A description of the apparent violatioti, including the duration of time it remained 

undetected, as well as how and when it was detected. 

c. A description of the immediate action taken lo terminate the conduct that resulted in the 

apparent violation, including when it was taken, and who was responsible for taking the action. 

d. An explanation that shows the apparent violation was inadvertent. 

e. Evidence that demonstrates the seriousness of the apparent violation and the regulated 

entity's analysis of that evidence. 

f. A detailed description of the proposed comprehensive fix, outiining the planned 

corrective steps, the responsibilities for implementing those corrective steps, and a time schedule 

for completion of the fix. If a proposed comprehensive fix is not fully developed within 

10 working days, the pertinent regulated entity should provide at least an overview of its 

comprehensive fix plans in a written report submitted within 10 working days after the initial 

notification was made. In any event, a detailed description of the comprehensive fix should be 

submitted within 30 calendar days after initial notification. 

g. Identification of the company official responsible for monitoring the implementation 

completion of the comprehensive fix. 

and 

10. PHASE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the 

certificate holder, fractional ownership program, or PAH to ensure that the regulated entity has 

identified any root causes and systemic issues which led to the apparent violation. This 

collaboration helps to ensure that the corrective actions contained in the comprehensive fix are 

acceptable to the FAA. 

11. PHASE V: IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA 

SURVEILLANCE. 

a. During the implementation period, the FAA and the pertinent regulated entity should 

continue to work together. The FAA may advise and assist the entity in correcting any identified 

systemic problems. Changes will be made to the proposed comprehensive fix when the need is 

identified. Upon determining that the initial implementation of the comprehensive fix is 

satisfactory, the PI will issue a letter of correction. Should a change to the comprehensive fix be 

identified after issuance of the letter of correction, the PI will issue an amendment to the letter of f IQ 

correction that reflects this change. ^'' & 

Page 6 Par 8 
9/8/06 AC 00-5 8A 

b. The FAA monitors the implementation of the corrective steps. Throughout the 

implementation period, the FAA assesses the pertinent regulated entity's corrective efforts and 

top management's awareness of these efforts. If, during this period, the FAA determines that the 

steps taken by the entity are not those documented in the comprehensive fix, the letter of 

correction may be rescinded, the investigative report may be reopened, and appropriate legal 

enforcement action may be initiated. 

12. PHASE VI: INSPECTOR SIGNOFF. At the conclusion of the implementation period, the 

PI makes a final assessment. If all elements of the comprehensive fix have been adequately 

accomplished, the PI finds the fix satisfactory and closes the case. The case remains subject to 

reopening in the event that the agreed-upon actions, outlined in the comprehensive fix, are not 

completed to the satisfaction of the FAA. A statement of follow-up investigation, confirming 

that the comprehensive fix was satisfactorily implemented and completed, is prepared to 

complete the FAA's investigative package. 

a. The PI has the authority to close the case. Consultation with regional specialists, legal 

counsel, or other FAA personnel may be accomplished when deemed appropriate by the PI. 

b. Following completion of the agreed-upon corrective action(s), the certificate holder, 

fractional ownership program, or PAH conducts a self-audit to ensure that the action taken 

remedies the problem that gave rise to the apparent violation. 

c. If, following FAA closure of the investigative package resulting from a voluntary 

disclosure, the same or similar violations are discovered to have occurred prior to submission of 

the associated voluntary disclosure, the FAA does not reopen the case unless it determines that 

the pertinent regulated entity failed to comply with all the elements of the comprehensive fix 

agreed upon by the FAA and the entity. 

13. DISPUTE RESOLUTION. When disputes occur regarding the acceptance of a proposed 

comprehensive fix, or a modification thereto before the fix is considered satisfactory, the PI and 

the pertinent regulated entity may request that the issue be resolved at the next level of 

management within the FAA. This procedure will provide for an independent assessment of the 

areas in disagreement. 

14. SEPARATE ACTIONS AGAINST AIRMEN OR OTHER INDIVIDUAL AGENTS. 

a. The voluntary disclosure policy applies to individual airmen or other agents of an 

employing certificate holder, fractional ownership program, or PAH when the following occurs: 

(1) The apparent violation involves a deficiency of the employing entity's practices or 

procedures that causes the employing certificate holder, fractional ownership program, or PAH 

to be in violation of a covered violation of an FAA regulation. 

(2) The airman or other agent of the employing entity, while acting on behalf of the 

employing entity, inadvertently violates the FAA's regulations as a direct result of a deficiency 

of the employing entity that causes the employing entity to be in violation of the regulations. 

(The voluntary disclosure policy does not apply to the airman or other agent when his/her 

apparent violation is the result of actions unrelated to the employing entity's deficiency). 

Par 11 Page 7 

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E. Qualified Fractional Ownership Programs. Fractional Ownership Programs are 

defined in 14 CFR, Part 91, Subpart K, and associated Management Specifications (MSpecs). 

Participation ofFractional Ownership Programs is limited as follows: 

1) Only program managers authorized in accordance with 14 CFR Part 91, 

Subpart K and MSpecs, may participate in the VDRP. 

2) Voluntary Disclosures of apparent violations by a fractional ownership program 

may only be submitted by the program manager, or an authorized representative. 

3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violations pertaining directly to the duties and responsibilities of the program manager, as 

defined in 14 CFR Part 91, Subpart K and MSpecs. 

11-5. VOLUNTARY DISCLOSURE POLICY. It is FAA policy that the open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs , and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances ofnoncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this section. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

A. In evaluating whether an apparent violation is covered by this policy, the responsible 

inspector will ensure that the following five conditions are met: 

1) The certificate holder, qualified fractional ownership program, or PAH has 

notified the FAA of the apparent violation immediately after detecting it and before the agency 

has learned of it by other means. 

2) The apparent violation was inadvertent. 

3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactory to 

the FAA. The comprehensive fix includes a follow-up self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

B. Except as specified in subparagraph 11-6B below, the FAA ordinarily will not forgo 

legal enforcement action if the certificate holder, qualified fractional ownership program, or 

PAH informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation4inspection or in association with an accident or incident. AJFFC^ ^ ?Cfc^' ' ^ ^i ) 

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Sanctions guidance 

AC maint log 47713 - 1 pp 

CRJ 700/900 Task windows, windshields and doors - 4 pp 

CRJ700MEL-2PP 

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noncompliance and to invest more resources in efforts to preclude their recurrence. The FAA's 

policy of forgoing civil penalty actions when one of these entities detects violations, promptly 

discloses the violations to the FAA, and takes prompt corrective action to ensure that the same or 

similar violations do not recur is designed to encourage compliance with FAA regulations, foster 

safe operating practices, and promote the development of internal evaluation programs. 

11-4. KEY TERMS. The following key terms and phrases are defined to ensure a standard 

interpretation and understanding of FAA voluntary disclosure policy. 

A. Evidence. For the purpose of voluntary disclosure, evidence generally should be in 

the form of written documentation or reports that support a certificate holder's, qualified 

fractional ownership programs, or PAH's analysis of the disclosed apparent violation and the 

resulting elements of the proposed comprehensive fix. Evidence generally comes from the 

following four elements: 

1) Documents or manuals reviewed. 

2) Equipment examined. 

3) Activities observed. 

4) Interview data. 

B. Comprehensive Fix. 

1) A comprehensive fix is an action, or actions, proposed by the certificate holder, 

qualified fractional ownership program, or PAH and accepted by the principal inspector (PI) (see 

definition in subparagraph 11-4D below) to preclude recurrence of the apparent violation that has 

been voluntarily disclosed under this program. 

2) A schedule of the dates and events encompassed by the comprehensive fix must 

be established and included in a letter of correction. 

C. Satisfactory Fix. A satisfactory fix is a comprehensive fix, in which all corrective 

measures have been completed on schedule and are satisfactory to the FAA. 

D. PI. Under the Voluntary Disclosure Reporting Program (VDRP), PI refers to the 

appropriate maintenance, avionics, operations inspector, or other designated FAA official of the 

program office responsible for oversight of the area ofnoncompliance involved in the disclosure. 

NOTE: The designated FAA official for voluntary disclosure concerning antidrug and alcohol misuse prevention program violations is the Branch Manager, 

Compliance and Enforcement Branch, Drug Abatement Division, FAA 

Headquarters; 

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E. Qualified Fractional Ownership Programs. Fractional Ownership Programs are 

defined in 14 CFR, Part 91, Subpart K, and associated Management Specifications (MSpecs). 

Participation ofFractional Ownership Programs is limited as follows: 

1) Only program managers authorized in accordance with 14 CFR Part 91, 

Subpart K and MSpecs, may participate in the VDRP. 

2) Voluntary Disclosures of apparent violations by a fractional ownership program 

may only be submitted by the program manager, or an authorized representative. 

3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violations pertaining directly to the duties and responsibilities of the program manager, as 

defined in 14 CFR Part 91, Subpart K and MSpecs. 

11-5. VOLUNTARY DISCLOSURE POLICY. It is FAA policy that the open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs , and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances ofnoncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this section. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

A. In evaluating whether an apparent violation is covered by this policy, the responsible 

inspector will ensure that the following five conditions are met: 

1) The certificate holder, qualified fractional ownership program, or PAH has 

notified the FAA of the apparent violation immediately after detecting it and before the agency 

has learned of it by other means. 

2) The apparent violation was inadvertent. 

3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactory to 

the FAA. The comprehensive fix includes a follow-up self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

B. Except as specified in subparagraph 11-66 below, the FAA ordinarily will not forgo 

legal enforcement action if the certificate holder, qualified fractional ownership program, or 

PAH informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation^inspection or in association with an accident or incident. 

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8900.1 CHGO 9/13/2007 

C. The procedures to be followed when applying the voluntary disclosure policy are 

further described in the following paragraphs. 

11-6. PHASE I—NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. 

Except as specified below, the voluntary disclosure policy applies only when notification of an 

apparent violation is made to the FAA by the certificate holder, qualified fractional ownership 

program, or PAH immediately after the apparent violation has been discovered by that regulated 

entity, and before the FAA learns of the apparent violation by some other means. 

A. Notification by the Certificate Holder, Fractional Ownership Program, or the 

PAH of an Apparent Violation. Initial notification of an apparent violation by eligible 

regulated entities may be submitted orally, via a written hardcopy, or by electronic copy. 

However, compliance with the 10 (or 30) day limit (see subparagraph 11-8F) for submission of 

the written report will be based on the date of the original notification, regardless of the 

submission means or media. A recommended format for written voluntary disclosures by 

regulated entities that are not authorized use of the web-based VDRP (see subparagraph 11-6C 

below) is provided in paragraph 11-17. When a certificate holder, fractional ownership program, 

or PAH notifies the FAA of an apparent violation, contact must be made with, or directed to, the 

appropriate PI. (Note: For those operators utilizing the web-based VDRP system, this 

notification is automated upon submission of the voluntary disclosure by the regulated entity and 

no further notification is required) It is FAA policy that initial notification should be 

accomplished on a timely basis, ordinarily within 24 hours of the discovery of the apparent 

violation. However, an inspector may accept disclosures that exceed the 24 hour policy when the 

inspector determines that a later submission is justified based on the specific circumstances, and 

in view of those circumstances, the submission is still considered timely. For example, a 

voluntary disclosure based on a company violation revealed in an Aviation Safety Action 

Program (ASAP) report may require more that 24 hours from the submission of that ASAP 

report in order for the responsible company entity to become aware of the information in the 

report and to initiate a voluntary disclosure. The FAA retains sole discretion in determining 

whether a voluntary disclosure received later than 24 hours after discovery of the violation is 

timely. The certificate holder, fractional ownership program, or PAH should therefore not delay 

notification for any reason, and should address, to the maximum extent possible, the following 

items with the PI: 

1) A brief description of the apparent violation, including an estimate of the duration 

of time that it remained undetected, as well as how and when it was discovered. 

2) Verification that noncompliance ceased after it was identified. 

3) A brief description of the immediate action taken after the apparent violation was 

identified, the immediate action taken to terminate the conduct that resulted in the apparent 

violation, and the person responsible for taking the immediate action. 

4) Verification that an evaluation is underway to determine if there are any systemic 

problems and a description of the corrective steps necessary to prevent the apparent violation 

from recurring. 

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8900.1 CHGO 9/13/2007 

5) Identification of the person responsible for preparing the comprehensive fix. 

6) Acknowledgment that a detailed written report will be provided to the PI within 

10 working days, except as noted in subparagraph 8F of this chapter. 

B. Exceptions. If the FAA has learned of an apparent violation by a certificate holder, 

fractional ownership program, or PAH from an ASAP report as described in the current edition 

of AC 120-66, Aviation Safety Action Program, a voluntary disclosure can still be accepted by 

the FAA, even though the FAA has already learned of the violation from the ASAP. Similarly, if 

a regulated entity voluntarily agrees to conduct a joint audit (inspection) with the FAA during 

which an apparent violation is discovered either by the company or FAA members of the audit 

(inspection) team, the FAA may accept a voluntary disclosure submitted by the company, even 

though the FAA has already learned of the apparent violation during the course of the joint audit 

(inspection). 

C. Use of the Web-Based VDRP for Notification of an Apparent Violation. For 

authorized users of the web-based VDRP, notification will normally be made via the web tool 

discussed in paragraph 11-19. Effective December 8, 2006, use of this tool is required for 

voluntary disclosures submitted by certificated air carriers. Future expansion of the tool may 

include other regulated entities, as noted in paragraph 11-19. 

1) Submission of a voluntary disclosure via the web-based VDRP system will result 

in automated notification of the Pis assigned to that certificate. 

2) The web-based VDRP system contains provisions for indicating that the 

notification process was begun via another media. When acceptable to the PI, initial notice by an 

authorized user of the web-based VDRP may be submitted orally, via a written hardcopy, or by 

electronic copy; provided, the regulated entity enters the initial notification data via the 

web-based VDRP system within 72 hours of the original notification. However, compliance with 

the 10 (or 30) day limit for submission of the written report will be based on the date of the 

original notification, regardless of the submission means or media. 

NOTE: In the case of voluntary disclosures submitted via the web-based VDRP, 

notification of the PI is accomplished by the program upon submission of the 

voluntary disclosure by the regulated entity. No further notification is required of 

the regulated entity. 

11-7. PHASE II—FAA RESPONSE TO CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH NOTIFICATION, The PI responds with a written or 

electronic acknowledgment of the entity's initial notification. This acknowledgment includes the 

request for a written report and is sent in lieu of a letter of investigation; provided, the written 

report is completed in accordance with the voluntary disclosure reporting procedures set forth in 

this section and paragraph 11-1. The PI will open an Enforcement Investigative Report (EIR) 

that will be closed out with a letter of correction, following satisfactory development of a 

comprehensive fix and schedule of implementation agreed upon by the FAA and the entity. 

VDRP fix codes, an inspector^clerical self-disclosure package checklist, FAA Form 2150-5 self 

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8900.1 CHGO 9/13/2007 

disclosure worksheet, and a sample FAA initial notification acknowledgment letter is provided in 

paragraph 11-18. 

NOTE: When the regulated entity has submitted the voluntary disclosure via the 

web-based VDRP, action on the voluntary disclosure by the PI results in an 

automated electronic reply to the regulated entity and an automated opening of the 

Enforcement Investigative Report (EIR), to include automated assignment of the 

EIR number. When the inspector is not utilizing the web-based VDRP system, the 

inspector shall obtain an EIR number in accordance with established local office 

procedures for issuance of Enforcement Investigation Numbers. 

11-8. PHASE HI—WRITTEN REPORT OF CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH'S APPARENT VIOLATION. The written report 

should be provided to the PI, by the regulated entity, within 10 working days after the initial 

notification was made, except as noted in subparagraph 11-8F below. A sample format for this 

report is provided as paragraph 11-17. In summary, the written report should include the 

following information: 

A. A list of the specific FAA regulations that may have been violated. 

B. A description of the apparent violation, including the duration of time it remained 

undetected, as well as how and when it was detected. 

C. A description of the immediate action taken to terminate the conduct that resulted in 

the apparent violation, including when it was taken, and who was responsible for taking the 

action. 

D. An explanation that shows the apparent violation was inadvertent. 

E. Evidence that demonstrates the seriousness of the apparent violation and the regulated 

entity's analysis of that evidence. 

F. A detailed description of the proposed comprehensive fix, outlining the planned 

corrective steps, the responsibilities for implementing those corrective steps, and a time schedule 

for completion of the fix. If a proposed comprehensive fix is not fully developed within 

10 working days, the pertinent regulated entity should provide at least an overview of its 

comprehensive fix plans in a written report submitted within 10 working days after the initial 

notification was made. In any event, a detailed description of the comprehensive fix should be 

submitted within 30 calendar days after initial notification. 

G. Identification of the company official responsible for monitoring the implementation 

and completion of the comprehensive fix. 

NOTE: For regulated entities authorized used of the web-based tool for VDRP 

submissions as described in paragraph 11-19, entry of the Phase III information 

will be accomplished using the web-tool. 

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8900.1 CHGO 9/13/2007 

11-9. PHASE IV—WRITTEN REPORT REVIEW BY THE FAA. The FAA works with 

the certificate holder, fractional ownership program, or PAH to ensure that the regulated entity 

has identified any root causes and systemic issues which led to the apparent violation. This 

collaboration helps to ensure that the corrective actions contained in the comprehensive fix are 

acceptable to the FAA. 

NOTE: Should investigation of the apparent violation result in a determination 

that no violation occurred, the EIR may be closed utilizing a Code 14 (No Action) 

in block 25 when closing a self-disclosure with "No Action," the inspector closing 

the case must indicate the reason for the closure without action as indicated 

below: 

1) When processing a voluntary disclosure on paper, the inspector should enter that 

explanation in the Corrective Action Plan Block on the FAA Form 2150-5 (or 2150 worksheet as 

applicable). 

2) When processing a self-disclosure utilizing the web-based system, the inspector is 

presented with the question, "Is the Self-Disclosure Approved or Rescinded?" To rescind the 

Self-Disclosure the inspector will select the option, "Rescinded" and, in the text box labeled, "If 

Rescinded, Explain," the inspector will enter an explanation for the closure with no action. The 

explanation for closure with no action may be a simple statement that the investigation 

established that no violation occurred, or it may contain as much detail as deemed necessary to 

explain the inspector's decision. 

3) When closing a voluntary disclosure via the manual system without action, the 

inspector has the option of entering or not entering problem codes, fix codes, and regulations 

violated. In the web-based program, if those items have already been entered and captured by the 

system, the inspector cannot delete those fields, but the report will be closed and recorded as 

having no action taken based on the explanation provided by the inspector in the explanation 

field. 

11-10. PHASE V—IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA 

SURVEILLANCE. 

A. During the implementation period, the FAA and the pertinent regulated entity should 

continue to work together. The FAA may advise and assist the entity in correcting any identified 

systemic problems. Changes will be made to the proposed comprehensive fix when the need is 

identified. Upon determining that the initial implementation of the comprehensive fix is 

satisfactory, the PI will issue a letter of correction. Should a change to the comprehensive fix be 

identified after issuance of the letter of correction, the PI will issue an amendment to the letter of 

correction that reflects this change. 

B. The FAA monitors the implementation of the corrective steps. Throughout the 

implementation period, the FAA assesses the pertinent regulated entity's corrective efforts and 

top management's awareness of these efforts. If, during this period, the FAA determines that the 

steps taken by the entity are not those documented in the comprehensive fix, the letter of 

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8900.1 CHGO 9/13/2007 

correction may be rescinded, the investigative report may be reopened, and appropriate legal 

enforcement action may be initiated. 

11-11. PHASE VI—INSPECTOR SIGNOFF. At the conclusion of the implementation period, 

the PI makes a final assessment. If all elements of the comprehensive fix have been adequately 

accomplished, the PI finds the fix satisfactory and closes the case. The case remains subject to 

reopening in the event that the agreed-upon actions, outlined in the comprehensive fix, are not 

completed to the satisfaction of the FAA. A statement of follow-up investigation, confirming that 

the comprehensive fix was satisfactorily implemented and completed, is prepared to complete 

the FAA's investigative package. 

A. The PI has the authority to close the case. Consultation with regional specialists, legal 

counsel, or other FAA personnel may be accomplished when deemed appropriate by the PI. 

B. Following completion of the agreed-upon corrective action(s), the certificate holder, 

fractional ownership program, or PAH conducts a self-audit to ensure that the action taken 

remedies the problem that gave rise to the apparent violation. 

C. If, following FAA closure of the investigative package resulting from a voluntary 

disclosure, the same or similar violations are discovered to have occurred prior to submission of 

the associated voluntary disclosure, the FAA does not reopen the case unless it determines that 

the pertinent regulated entity failed to comply with all the elements of the comprehensive fix 

agreed upon by the FAA and the entity. 

11-12. DISPUTE RESOLUTION. When disputes occur regarding the acceptance of a 

proposed comprehensive fix, or a modification thereto before the fix is considered satisfactory, 

the principal inspector and the pertinent regulated entity may request that the issue be resolved at 

the next level of management within the FAA. This procedure will provide for an independent 

assessment of the areas in disagreement. 

11-13. SEPARATE ACTIONS AGAINST AIRMEN OR OTHER INDIVIDUAL 

AGENTS. 

A. The voluntary disclosure policy applies to individual airmen or other agents of an 

employing certificate holder, fractional ownership program, or PAH when the following occurs: 

1) The apparent violation involves a deficiency of the employing entity's practices 

or procedures that causes the employing certificate holder, fractional ownership program, or 

PAH to be in violation of a covered violation of an FAA regulation. 

2) The airman or other agent of the employing entity, while acting on behalf of the 

employing entity, inadvertently violates the FAA's regulations as a direct result of a deficiency 

of the employing entity that causes the employing entity to be in violation of the regulations. 

(The voluntary disclosure policy does not apply to the airman or other agent when his/her 

apparent violation is the result of actions unrelated to the employing entity's deficiency). 

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^ 

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AC 00-58A 9/8/06 

b. Except as specified in paragraph 14 of this AC, the Voluntary Disclosure Reporting 

Program does not apply to violations by individual airmen. 

4. BACKGROUND. Civil penalties, under the FAA's enforcement program, have always 

been considered a means to promote compliance with the FAA's regulations, not an end in 

themselves. In addition to the deterrence achieved by the appropriate use of civil penalties, the 

public interest is also served by positive incentives to promote and achieve compliance. Indeed, 

the FAA believes that aviation safety is well served by incentives for certificate holders, 

qualified fractional ownership programs, and PAHs to identify and correct their own instances of 

noncompliance and to invest more resources in efforts to preclude their recurrence. The FAA's 

policy of forgoing civil penalty actions when one of these entities detects violations, promptiy 

discloses the violations to the FAA, and lakes prompt corrective action to ensure that the same or 

similar violations do not recur is designed to encourage compliance with the FAA's regulations, 

foster safe operating practices, and promote the development of internal evaluation programs. 

5. KEY TERMS. The following key terms and phrases are defined to ensure a standard 

interpretation and understanding of the FAA's voluntary disclosure policy. 

a. Evidence. For the purpose of voluntary disclosure, evidence generally should be in the 

form of written documentation or reports that support a certificate holder's, qualified fractional 

ownership program's, or PAH's analysis of the disclosed apparent violation and the resulting 

elements of the proposed comprehensive fix. Evidence generally comes from the following four 

elements: 

(1) Documents or manuals reviewed. 

(2) Equipment examined. 

(3) Activities observed. 

(4) Interview data. 

b. Comprehensive Fix. 

(1) A comprehensive fix is an action, or actions, proposed by the certificate holder, 

qualified fractional ownership program, or PAH and accepted by the principal inspector (PI) (see 

definition in paragraph 5d) to preclude recurrence of the apparent violation that has been 

voluntarily disclosed under this program. 

(2) A schedule of the dates and events encompassed by the comprehensive fix must be 

established and included in a letter of correction. 

c. Satisfactory Fix. A satisfactory fix is a comprehensive fix, in which all corrective 

measures have been completed on schedule and are satisfactory to the FAA. 

d. PI. Under the Voluntary Disclosure Reporting Program (VDRP), PI refers to the 

appropriate maintenance, avionics, operations inspector, or other designated FAA official of the 

program office responsible for oversight of the area ofnoncompliance involved in the disclosure. \p 

^^^^' ^^^^^^^^^ M Par 3 
9/8/06 AC 00-58A 

NOTE: The designated FAA official for voluntary disclosure concerning antidrug and alcohol misuse prevention program violations is the Branch Manager, 

Compliance and Enforcement Branch, Drug Abatement Division, FAA 

Headquarters. 

e. Qualified Fractional Ownership Programs. Fractional ownership programs are 

defined in part 91, subpart K and associated MSpecs. Participation in the VDRP by a fractional 

ownership program is limited by the following: 

(1) Only program managers authorized in accordance with part 91, subpart K and 

MSpecs, may participate in the VDRP. 

(2) Voluntary disclosures of apparent violations by a fractional ownership program may 

only be submitted by the program manager, or an authorized representative. 

(3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violations pertaining directly to the duties and responsibilities of the program manager, as 

defined in part 91, subpart K and MSpecs. 

6. VOLUNTARY DISCLOSURE POLICY. The FAA believes that the open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs, and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances ofnoncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this AC. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

a. In evaluating whether an apparent violation is covered by this policy, the FAA will 

ensure that the following five conditions are met: 

(1) The certificate holder, qualified fractional ownership program, or PAH has notified 

the FAA of the apparent violation immediately after detecting it and before the Agency has 

learned of it by other means. 

(2) The apparent violation was inadvertent. 

(3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

(4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

(5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactory to 

the FAA. The comprehensive fix includes a followup self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

^ ' \ ^ 

Par 5 Page 3 
AC 00-58A 9/8/06 

b. Except as specified in paragraph 7c below, the FAA ordinarily will not forgo legal 

enforcement action if the certificate holder, qualified fractional ownership program, or PAH 

informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation/inspection or in association with an accident or incident. 

c. The procedures to be followed when applying the voluntary disclosure policy are further 

described in the following paragraphs. 

7. PHASE I: NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. Except 

as specified below, the voluntary disclosure policy applies only when notification of an apparent 

violation is made to the FAA by the certificate holder, qualified fractional ownership program, or 

PAH immediately after the apparent violation has been discovered by that regulated entity, and 

before the FAA learns of the apparent violation by some other means. 

a. Use of the Web-Based VDRP for Notification of an Apparent Violation. For 

authorized users of the Web-based VDRP, notification will normally be made via this Web tool 

(see Appendix 1). 

(1) For regulated entities authorized use of the Web-based VDRP, submission of a 

voluntary disclosure via the Web-based VDRP system will result in automated notification of the 

Pis assigned to that certificate. 

(2) The Web-based VDRP system contains provisions for indicating that the notification 

process was begun via another media. When acceptable to the PI, initial notice by an authorized 

user of the Web-based VDRP may be submitted orally, via a written hardcopy, or by electronic 

copy; provided, the regulated entity enters the initial notification data via the Web-based VDRP 

system within 72 hours of the original notification. However, compliance with the 10- (or 30-) 

day limit for submission of the written report will be based on the date of the original 

notification, regardless of the submission means or media. 

NOTE: For regulated entities not yet authorized use of the Web-based VDRP, 

the notification of an apparent violation will be submitted orally, via a written 

hardcopy, or by electronic copy. The format for written voluntary disclosures by 

regulated entities not authorized use of the Web-based VDRP is provided in 

Appendix 2. 

b. Notification by the Certificate Holder, Fractional Ownership Program, or the PAH 

of an Apparent Violation. When a certificate holder, fractional ownership program, or PAH 

notifies the FAA of an apparent violation, contact must be made with, or directed to, the 

appropriate PI. It is FAA policy that initial notification should be accomplished on a timely 

basis, ordinarily within 24 hours of the discovery of the apparent violation. However, an 

inspector may accept disclosures that exceed the 24 hour policy when the inspector determines 

that a later submission is justified based on the specific circumstances, and in view of those 

circumstances, the submission is still considered timely. For example, a voluntary disclosure 

based on a company violation revealed in an Aviation Safety Action Program (ASAP) report 

may require more that 24 hours from the submission of that ASAP report in order for the 

responsible company entity to become aware of the information in the report and to initiate a 

voluntary disclosure. The FAA retains sole discretion in determining whether a voluntary 

^ ^ 

Page 4 Par 6 
9/8/06 AC 00-58A 

disclosure received later than 24 hours after discovery of the violation is timely. The certificate 

holder, fractional ownership program, or PAH should therefore not delay notification for any 

reason, and should address, to the maximum extent possible, the following items with the PI: 

(1) A brief description of the apparent violation, including an estimate of the duration of 

time that it remained undetected, as well as how and when it was discovered. 

(2) Verification that noncompliance ceased after it was identified. 

(3) A brief description of the immediate action taken after the apparent violation was 

identified, the immediate action taken to terminate the conduct that resulted in the apparent 

violation, and the person responsible for taking the immediate action. 

(4) Verification that an evaluation is underway to determine if there are any systemic 

problems and a description of the corrective steps necessary to prevent the apparent violation 

from recurring. 

(5) Identification of the person responsible for preparing the comprehensive fix. 

(6) Acknowledgment that a detailed written report will be provided to the PI within 

10 working days. 

NOTE: In the case of voluntary disclosures submitted via the Web-based VDRP, 

notification of the PI is accomplished by the program upon submission of the 

voluntary disclosure by the regulated entity. No further notification is required 

of the regulated entity. 

c. Exceptions. If the FAA has learned of an apparent violation by a certificate holder, 

fractional ownership program, or PAH from an ASAP report as described in the current edition 

of AC 120-66, Aviation Safety Action Program, a voluntary disclosure can still be accepted by 

the FAA, even though the FAA has already learned of the violation from the ASAP. Similarly, if 

a regulated entity voluntarily agrees to conduct a joint audit (inspection) with the FAA during 

which an apparent violation is discovered either by the company or FAA members of the audit 

(inspection) team, the FAA may accept a voluntary disclosure submitted by the company, even 

though the FAA has already learned of the apparent violation during the course of the joint audit 

(inspection). 

8. PHASE II: FAA RESPONSE TO CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH NOTIFICATION. The PI responds with a written or 

electronic acknowledgment of the entity's initial notification. This acknowledgment includes the 

request for a written report and is sent in lieu of a letter of investigation; provided, the written 

report is completed in accordance with the voluntary disclosure reporting procedures set forth in 

this AC and Appendixes 1 and 2. The PI will open an Enforcement Investigative Report (EIR) 

that will be closed out with a letter of correction, following satisfactory development of a 

comprehensive fix and schedule of implementation agreed upon by the FAA and the entity. 

NOTE: When the regulated entity has submitted the voluntary disclosure via the 

Web-based VDRP, action on the voluntary disclosure by the PI results in an 

Par 7 Page 5 

/ > 
AC 00-5 8A 9/8/06 

automated electronic reply to the regulated entity and an automated opening of 

the Enforcement Investigative Report (EIR). 

9. PHASE HI: WRITTEN REPORT OF CERTIFICATE HOLDER, FRACTIONAL 

OWNERSHIP PROGRAM, OR PAH'S APPARENT VIOLATION. The written report 

should be provided to the PI, by the regulated entity, within 10 working days after the initial 

notification was made. A sample format for this report is provided as Appendix 2. In summary, 

the written report should include the following information: 

a. A list of the specific FAA regulations that may have been violated. 

b. A description of the apparent violation, including the duration of time it remained 

undetected, as well as how and when it was detected. 

c. A description of the immediate action taken to terminate the conduct that resulted in the 

apparent violation, including when it was taken, and who was responsible for taking the action. 

d. An explanation that shows the apparent violation was inadvertent. 

e. Evidence that demonsttates the seriousness of the apparent violation and the regulated 

entity's analysis of that evidence. 

f A detailed description of the proposed comprehensive fix, outlining the planned 

corrective steps, the responsibilities for implementing those corrective steps, and a time schedule 

for completion of the fix. If a proposed comprehensive fix is not fully developed within 

10 working days, the pertinent regulated entity should provide at least an overview of its 

comprehensive fix plans in a written report submitted within 10 working days after the initial 

notification was made. In any event, a detailed description of the comprehensive fix should be 

submitted within 30 calendar days after initial notification. 

g. Identification of the company official responsible for monitoring the implementation and 

completion of the comprehensive fix. 

10. PHASE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the 

certificate holder, fractional ownership program, or PAH to ensure that the regulated entity has 

identified any root causes and systemic issues which led to the apparent violation. This 

collaboration helps to ensure that the corrective actions contained in the comprehensive fix are 

acceptable to the FAA. 

11. PHASE V: IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA 

SURVEILLANCE. 

a. During the implementation period, the FAA and the pertinent regulated entity should 

continue to work together. The FAA may advise and assist the entity in correcting any identified 

systemic problems. Changes will be made to the proposed comprehensive fix when the need is 

identified. Upon determining that the initial implementation of the comprehensive fix is 

satisfactory, the PI will issue a letter of correction. Should a change to the comprehensive fix be 

identified after issuance of the letter of correction, the PI will issue an amendment lo the letter of / /^ 

correction that reflects this change. '^ 0^ 

Page 6 Par 8 
9/8/06 AC 00-58A 

b. The FAA monitors the implementation of the corrective steps. Throughout the 

implementation period, the FAA assesses the pertinent regulated entity's corrective efforts and 

top management's awareness of these efforts. If, during this period, the FAA determines that the 

steps taken by the entity are not those documented in the comprehensive fix, the letter of 

correction may be rescinded, the investigative report may be reopened, and appropriate legal 

enforcement action may be initiated. 

12. PHASE VI: INSPECTOR SIGNOFF. At the conclusion of the implementation period, the 

PI makes a final assessment. If all elements of the comprehensive fix have been adequately 

accomplished, the PI finds the fix satisfactory and closes the case. The case remains subject to 

reopening in the event that the agreed-upon actions, outlined in the comprehensive fix, are not 

completed to the satisfaction of the FAA. A statement of follow-up investigation, confirming 

that the comprehensive fix was satisfactorily implemented and completed, is prepared to 

complete the FAA's investigative package. 

a. The PI has the authority to close the case. Consultation with regional specialists, legal 

counsel, or other FAA personnel may be accomplished when deemed appropriate by the PI. 

b. Following completion of the agreed-upon corrective action(s), the certificate holder, 

fractional ownership program, or PAH conducts a self-audit to ensure that the action taken 

remedies the problem that gave rise to the apparent violation. 

c. If, following FAA closure of the investigative package resulting from a voluntary 

disclosure, the same or similar violations are discovered to have occurred prior to submission of 

the associated voluntary disclosure, the FAA does not reopen the case unless it determines that 

the pertinent regulated entity failed to comply with all the elements of the comprehensive fix 

agreed upon by the FAA and the entity. 

13. DISPUTE RESOLUTION. When disputes occur regarding the acceptance of a proposed 

comprehensive fix, or a modification thereto before the fix is considered satisfactory, the PI and 

the pertinent regulated entity may request that the issue be resolved at the next level of 

management within the FAA. This procedure will provide for an independent assessment of the 

areas in disagreement. 

14. SEPARATE ACTIONS AGAINST AIRMEN OR OTHER INDIVIDUAL AGENTS. 

a. The voluntary disclosure policy applies to individual airmen or other agents of an 

employing certificate holder, fractional ownership program, or PAH when the following occurs: 

(1) The apparent violation involves a deficiency of the employing entity's practices or 

procedures that causes the employing certificate holder, fractional ownership program, or PAH 

to be in violation of a covered violation of an FAA regulation. 

(2) The airman or other agent of the employing entity, while acting on behalf of the 

employing entity, inadvertently violates the FAA's regulations as a direct resuh of a deficiency 

of the employing entity that causes the employing entity to be in violation of the regulations. 

(The voluntary disclosure policy does not apply to the airman or other agent when his/her 

apparent violation is the result of actions unrelated to the employing entity's deficiency). 

Par 11 Page 7 

a^ 
8900.1 CHGO 9/13/2007 

E. Qualified Fractional Ownership Programs. Fractional Ownership Programs are 

defined in 14 CFR, Part 91, Subpart K, and associated Management Specifications (MSpecs). 

Participation ofFractional Ownership Programs is limited as follows: 

1) Only program managers authorized in accordance with 14 CFR Part 91, 

Subpart K and MSpecs, may participate in the VDRP. 

2) Voluntary Disclosures of apparent violations by a fractional ownership program 

may only be submitted by the program manager, or an authorized representative. 

3) Voluntary disclosures by fractional ownership programs are limited to apparent 

violations pertaining directly to the duties and responsibilities of the program manager, as 

defined in 14 CFR Part 91, Subpart K and MSpecs. 

11-5. VOLUNTARY DISCLOSURE POLICY. It is FAA policy that die open sharing of 

apparent violations and a cooperative as well as an advisory approach to solving problems will 

enhance and promote aviation safety. Certificate holders, qualified fractional ownership 

programs, and PAHs will receive a letter of correction in lieu of civil penalty action for covered 

instances ofnoncompliance that are voluntarily disclosed to the FAA in accordance with the 

procedures set forth in this section. Once the letter of correction is issued, the case will be 

considered closed unless the agreed-upon comprehensive fix is not satisfactorily completed by 

the appropriate entity. 

A. In evaluating whether an apparent violation is covered by this policy, the responsible 

inspector will ensure that the following five conditions are met: 

1) The certificate holder, qualified fractional ownership program, or PAH has 

notified the FAA of the apparent violation immediately after detecting it and before the agency 

has learned of it by other means. 

2) The apparent violation was inadvertent. 

3) The apparent violation does not indicate a lack, or reasonable question, of 

qualification of the certificate holder, qualified fractional ownership program, or PAH. 

4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate 

the conduct that resulted in the apparent violation. 

5) The certificate holder, qualified fractional ownership program, or PAH has 

developed or is developing a comprehensive fix and schedule of implementation satisfactor}' to 

the FAA. The comprehensive fix includes a follow-up self-audit to ensure that the action taken 

corrects the noncompliance. This self-audit is in addition to any audits conducted by the FAA. 

B. Except as specified in subparagraph 11-6B below, the FAA ordinarily will not forgo 

legal enforcement action if the certificate holder, qualified fractional ownership program, or 

PAH informs the FAA of the apparent violation during, or in anticipation of, an FAA 

investigation4inspection or in association with an accident or incident. AJ^—" ^ ^Cfc»"' ^i^ ^ 

UNCONTROLLED COPY WHEN DOWNLOADED 

Check FSIMS to verify this version is current prior to use 

^y7/rf '^^ 2 t3 

^^^^ p Regional let 

AIRCRAFT MAINTENANCE MANUAL - PART I 

SYSTEM DESCRIPTION SECnON 

OnA/C1000M0999, 15001-15990 

TASK 30-40-00-001-A01 

WINDOWS, WINDSHIELDS AND 

DOORS 

INTRODUCTION 

The windshield and side windows use 

electrical heating for anti-icing and de-fogging. 

The side windows have anti-fogging only. 

The windshield wiper system uses electric 

motors to drive wiper blade assemblies for the 

pilot and co-pilot windshields. 

GENERAL DESCRIPTION 

Figure 30-40-00-000001. 

The windows and windshields consists of the 

following systems: 

• Windshield and Side Window Anti-ice 

Systems 

• Windshield Wiper System. 

WINDSHIELD AND SIDE WINDOW ANTI-ICE 

SYSTEMS 

The flight compartment windshields and side 

windows are electrically heated. The power 

supply for the windshield is 200 Vac (two 

phase) for anti-icing and 115 Vac for 

defogging.The side windows are supplied with 

115 Vac'for anti-fogging only. All windshields 

and side windows have temperature control 

and overheat sensors for control and overheat 

protection. A spare sensor is also available in 

each window to be used should one of the 

other sensors fail. 

The amount of heat supplied to the 

windshields and side-windows is controlled by 

four temperature controllers, one for each 

window. Overheat or loss of heat is monitored 

for the related window by Its controller. A test 

switch loca^d between thve two. control 

. • . • . I •• • -Ui•^•" • 

EFFECTIVITY: See first page of 

TASK 30.40-00-001-A01 

switches is used to test the controllers and the 

window heaters. The windshield/side window 

heater controllers provide electrical power 

switching, control, monitoring and indication 

for the windshield heating elements contained 

within the windshield and side windows. 

Two switches located on the anti ice control 

panel are used to control the system. The left 

switch controls the left windshield and side 

window. The right switch controls the right 

windshield and side window. The heat control 

switches have three positions; OFF/RESET, 

LOW, and HI. In the LOW position, window 

and windshield on the selected side are 

heated at a low level. When HI Is selected, the 

side window Is heated at low level and the 

windshield Is heated at high level. The 

OFF/RESET position is used to reset or turn 

the system off. 

WINDSHIELD WIPER SYSTEM 

The pilot and co-pilot windshield wipers are 

selected from independent switches in the 

flight compartment and are controlled by an 

electronic control unit. 

30-40-00 Page 1 

Jan 20/2008 
^700/goo _ 

^^^TjT ^ Regional let 

AIRCRAFT MAINTENANCE MANUAL - PART I 

SYSTEM DESCRIPTION SECTION 

BUILT-IN TEST 

Testing of the controllers and associated 

circuits is performed by the test switch, located 

on the anti-Ice control panel. Prior to 

perfonning the test, the left and right 

windshield switches must be placed In the LO 

or HI position. 

The test checks the temperature controllers, 

sensors, and heaters as an operational 

system. EICAS UR WINDOW HEAT and L/R 

WINDSHIELD HEAT caution messages are 

displayed during the test. The integrity of the 

following circuits is also checked: 

• The warm-up circuit is functional 

• The normal circuit is functional 

• The overheat protection circuit Is functional 

and the temperature sensor is not shorted. 

After approximately 8 seconds, the controllers 

terminate the test by removing the EICAS 

messages and revert to normal operation, if 

successful. If a controller detects a failure the 

messages remain displayed. 

EICAS INDICATION 

Figure 30-40-00-000001. 

The heater controllers interface with the 

EICAS system to provide system failure status 

messages to the crew. Discrete signals from 

each controller are connected to the EICAS 

DCUs. Logic circuits are built within the DCUs 

to determine th^ type of messages to be 

displayed. To prevent nuisance messages 

being generated when aircraft bus bars are 

shed, the DCU logic Is designed to provide 

message blanking when either AC bus 1 or AC 

bus 2 power is not connected. 

EICAS MESSAGES 

The list below details the messages that the 

EICAS system displays for the windshield heat 

system: 

MESSAGE 

LWSHLD 

HEAT 

WINDOW 

HEAT 

R WSHLD 

HEAT 

R 

WINDOW 

HEAT 

TYPE 

Cautioni Failure of left windshield 

heat with AC bus 1 

powered. Also posted 

during Test for 8 sees 

Cautior 

Caution 

Cautior 

LOGIC 

Failure of left window 

heat. Also posted during 

Test for 8 seconds 

Failure of right windshield 

heat with AC bus 2 

powered. Also posted 

during Test for 8 seconds 

Failure of right window 

heat with AC bus 2. Also 

posted during Test for 8 

seconds 

TRAINING INFORMATION POINTS 

• When a spare sensor element is used, 

documented evidence must be in place. This 

allows for advance planning of aircraft 

windshield replacement at a suitable 

maintenance base 

• During windshield replacement, verify the 

element resistance values before 

installation 

• Bubbles in windshield/side window interiayer 

indicate signs of overtieatlng. Refer to 

maintenance manual prior to further flight 

• On the windshield power terminal block 

ensure the nuts and/or screws do not bottom 

out. 

WINDSHIELD WIPER SYSTEM 

Figure 30-40-00-000004. 

The windshield wiper system removes 

rainwater and/or snow from the pilot and 

copilot windshields. This system is useful 

EFFECTIVITY: See first page of 

TASK 30-40-00-001-A01 30-40-00 Page^ 

Jan 20/2008 
^^^^^ ^ fiegionol/et 

AIRCRAFT MAINTENANCE MANUAL - PART I 

SYSTEM DESCRIPTION SECTION 

NOTE 

Left side shown, right side 

is almost the same. 

^^-- ^ 

BOLT 

INBOARD 

RETAINER 

STRUCTURAL 

STRAPS 

INBOARD PLY 

CORE PLY 

!NTERLAYER 

©-© 

'^r• 

Side Window 

Figure 56-10-00-000002 

EFFECTIVITY: See first page of 

TASK56-10-D0-001-A01 

56-10-00 Page 3 

Jan 20/2008 
^700/gog ^ 

^^^^• ^ Regional let 

AIRCRAFT MAINTENANCE MANUAL - PART I 

SYSTEM DESCRIPTION SECTION 

INBOARD 

RETAINER 

' ^MBf ^ </ OUTBOARD 

^.^^y^[;^[][v^Sv^ RETAINER 

POLYSULFIDE 

PVB 

INTERPLAYER 

URETHANE 

DE-ICING 

FILM 

HERCULITE H 

®G17\SS 

NOTE 

Left side shown, right side 

is almost the same. 

B - B 

Windshield 

Figure 56-10-00-000001 

EFFECTIVITY: See first page of 

TASK56-10-00-001-A01 56-10-00 Page 2 

Jan 20/2008 
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Aviation Safety Action Program (ASAP) for Pilots 

Memorandum of Understanding 

e. The ERG should also make recommendations to GOJET for corrective action for systemic 

Issues. For example, such corrective action might include changes to GOJET flight operations 

procedures, aircraft maintenance procedures, or modifications to the training curriculum for 

pilots. Any recommended changes that affect GOJET will be forwarded through the ASAP 

manager to the appropriate department head for consideration and comment, and, if 

appropriate, implementatfon. The FAA will work with GOJET to develop appropriate corrective 

action for systemic Issues. The ASAP Manager will track the Implementation of the recommended 

corrective action and report on associated progress as part of the regular ERG meetings. Any 

recommended corrective action that is not Implemented should be recorded along with the 

reason it was not Implemented. 

f. When the ERG becomes aware of an issue involving the medical qualification or medical 

certification of an airman, the ERG must Immediately advise the appropriate Regional Flight 

Surgeon about the issue. The ERC will work with the Regional Flight Surgeon and the certificate 

holder's medical department or medical consultants to resolve any medical certification or 

medical qualification Issues or concerns revealed in an ASAP report, or through the processing of 

that report. The FAA ERC member must follow the dlrectlon(s) of the Regional Flight Surgeon 

with respect to any medical certification or medical qualification issue(s) revealed in an ASAP 

report. 

g. Any corrective action recommended by the ERC for a report accepted under ASAP must be 

completed to the satisfaction of all members of the ERG, or the ASAP report will be excluded from 

the program, and the event will be referred to the FAA for further action, as appropriate. 

h. Use of the GOJET ASAP Report: Neither the written ASAP report nor the content of the 

written ASAP report will be used to initiate or support any company disciplinary action, or as 

evidence for any purpose in an FAA enforcement action, except as provided in paragraph lla(3) 

of this MOU. The FAA may conduct an independent Investigation of an event disclosed In a 

report 

11. FAA ENFORCEMENT. 

a. Criteria for Acceptance. The following criteria must be met in order for a report to be 

covered under ASAP: 

(1) The employee must submit the report in accordance with the time limits specified under 

paragraph 6 of this MOU; 

(2) Any possible noncompliance with 14 CFR disclosed in the report must be Inadvertent 

and must not appear to Involve an intentional disregard for safety; and, 

Rev. 1 January 5, 2008 Page 6 
Respondent's Exhibit List 

# Description ID IN 

R-1 ERC Mtg - confidentiality reqmt - 1 pp x x 

R-2 Inspector Sta x x 

m» 
Aviation Safety Action Program 

ERC Meeting - CONFIDENTIALITY REQUIREMENT 

The material contained within this report is confidential and privileged 

information, and may be used only in conjunction with the GoJet Airlines Aviation 

Safety Action Program, for use during the Event Review Committee meeting on, 

June 12, 2008. 

Use of this report outside the confines of this ERC meeting requires unanimous 

consensus of the ERC. At the beginning of this meeting this co\/er sheet will be 

signed and tumed over to the ASAP Manager. At the conclusion of the meeting, 

all holders of this report must surrender their copy to the pilot union ERC 

Representative, who will destroy the report. 

By signing the form below, each participant in this ERC meeting agrees to abide 

by the rules in the GoJet Airlines ASAP Memorandum of Understanding (MOU). 

Visitors to the ERC meeting are bound by the rules contained in the MOU, and 

particularly understand that all proceedings are confidential and not to be 

discussed outside the confines of the meeting. No records of the proceedings of 

the meeting may be created, except by the ASAP Manger, without specific 

written permission of all three voting members of the ERC. The ASAP Manager 

as evidence of this commitment will retain a copy of this signed cover page. 

Warning: 

The information in this document may be protected from disclosure under 49USC, 

section 40123 and 14CFR part 193. 

ERC Meeting Date: 

ERC Meeting Participant's 

Name: 

Role (Voting Member, 

Visitor, Reporter): 

06/12/2008 

1/ y:Ur - ^/ t 
Inspector Statement 

On June 12, 2008, during an ASAP meeting it was brought to my attention that on May 31, 

2008 GoJet Airlines improperly deferred the pilot's windshield anti-ice controller (MEL item 

30-41-01) on aircraft N155GJ, although the discrepancy noted in the logbook (L Window 

Heat Caution) was for the pilot's (left) side window heat. The pilot's left side window heal 

is not deferrable according to GoJet's MEL. In addition to deferring the wrong item, the 

aircraft logbook pages showed that CioJei flew one flight in this condition. 

On June 12, 2008,1 also interviewed Mr. Ernie Spencer, the GoJet maintenance controller 

who authorized the deferral of the pilot's windshield anti-ice controller. During the interview 

he stated that he had determined the pilot's windshield heat was the problem. This 

determination was based on conversations he had with the aircraft captain and on-demand 

maintenance personnel called out to look at GoJet's aircraft. This determination was made, 

despite the EICAS message displayed during the flight which was for the left side window. 

The logbook pages also showed that on May 31, 2008, during the next flight (the flight flown 

with the windshield anti-ice controller deferred) the aircraft EICAS system indicated the left 

side window heat had another problem. At this time GoJet was aware the wrong anti-ice 

controller had been deferred. On June 13, 2008 I sent a letter of investigation to GoJet 

informing them this matter was under investigation, as the FAA had not received a selfdisclosure, sven though GoJet was aware of the situation since May 31, 2008. 

Following this incident 1 discussed with Mr. Jeff Craig, GoJet's Chief Inspector, the need for 

aoditional personnel in GoJet's Maintenance Control. (In addition to this incident there were 

three other incidents that occurred within a month of this incident (and others prior to these) 

where it appeared the lack of personnel was direcfly related to improper maintenance being 

accomplished on GoJet's aircraft. 1 informed him if GoJet increased the number of 

maintenance controllers on duty at one time and/or hired a maintenance controller supervisor, 

that possibly the FAA could close the enforcement out with a Letter of Correction. On June 

26, 2008 I received a letter from Mr. Craig stating he had received the Letter of Investigation 

dated June 13, 2008 and wanted to schedule a meeting to discuss this situation, i called him 

that same day and asked if GoJet had discussed the idea of adding staff to their maintenance 

control. Mr. Craig stated he had discussed it with other people within GoJet and Trans States 

Holdings and they did not want to add any personnel to maintenance control. At this point I 

told him if they didn't want to increase their maintenance control personnel, there wasn't 

anything else to discuss and the FAA would go ahead with enforcement in lieu of a letter of 

correction I did not hear back from Mr Cr^ig reg?^'jing this incident. 

On September 12, 2008,1 reviewed all the log pages for aircraft N155GJ, dated May 31, 

2008 thru June 30, 2008. On June I, 2008 maintenance personnel swapped the left window 

overheat sensor with the spare sensor. There were no other discrepancies related to the left 

window heat or left windshield heat noted after this in the log pages reviewed. 

d lary J. Cooper 

Aviation Safety Inspector