8909 Purdue Road, Suite 300, Indianapolis, Indiana 46268 Tele: 317 471 2256 Fax: 317 48 4 2404 www.republicairlines.com December 5 , 2013

U.S. Department of Transportation Docket Operations West Building Ground Floor
Room W12

- 140 1200 New Jersey Avenue, SE. Washington, DC 20590

RE: Request for temporary exemption from the FAA’s Filtered Flight Data Final Rule, Docket N o. FAA

– 2006

– 26135

Dear Sir/Madam

,
Republic Airlines respectfully petitions, pursuant to Sections 11.61 and 11.63 of the Federal Aviation Regulations ("FARs"), for a temporary exemption from the regulatory requirements of FARs 121.346(d)(3)(i) and 121.346 (d)(4) which become effective April 21, 2014. These regulations require certain flight parameters be captured by the FDR without filtering such that they can be used for an accurate reconstruction of events during an investigation.

Republic Airlines opera tes the Bombardier Aerospace DHC

- 8

- 400 Series Model 402 aircraft (subsequently referred to as Q400) . The input to the Flight Data Recorder (FDR) on the Bombardier Q400 aircraft is analyzed by a FDR Signal Conditioning Unit (FSCU). The FSCU, manufactured b y Honeywell, applies a software algorithm to average certain input parameters, thereby reducing the volume of data that must be recorded. This averaging was determined to be contrary to the new requirements. At this time the only data being filtered by th e software based sampling averaging algorithm is:

• Parameter (12): Pilot and Copilot Pitch Control Input Position

• Parameter (13): Pilot and Copilot Lateral Control Input Position

• Parameter (14): Rudder Pedal Control Input Position

• Parameter (88): Pilot and Copilot Control Wheel Force

• Parameter (88): Pilot and Copilot Elevator Control Column Force

• Parameter (88): Pilot and Copilot Left and Right Rudder Pedal Force

The technical solution has been developed and a compliance plan has been established. While th e compliance plan includes certification of hardware prior to the regulatory deadline, there will be insufficient parts availability for operators to install the new hardware on the entire fleet prior to the regulatory deadline. Based on the current schedu le, and availability of rotating spares being shared with other Q400 operators , provided by Bombardier and Honeywell, Republic Airlines estimates it can complete the fleet wide upgrade by July 21, 2014. Due to a lack of parts availability, caused by manufa cturer constraints. Republic Airlines is seeking a temporary exemption to FARs 121.346(d)(3)(i) and 121.346(d)(4) through July 21, 2014. Further details regarding the design and implementation strategy can be found within the enclosed Bombardier Aerospace and Honeywell supportive documents.Approval of the exemption requested is in the public interested inasmuch as many of the airplanes in the Republic Airlines fleet will not be in compliance with the FARs 121.346(d)(3)(i) and 121.346(d)(4), as of April 21, 2014, and will be removed from service until compliance can be achieved. This will result in severe disruption to the travelling public, creating the need to cancel flights and re

- accommodate passengers. This exemption will not adversely impact safety of flight. The changes to the regulation are intended to improve the ability to investigate accidents. Improving the ability to investigate accidents provides an opportunity to make changes to future rules and regulations which could have a direct impact o n safety. The changes, by themselves, do not directly impact safety of flight.

Republic Airlines respectfully requests that the exemption be granted expeditiously. A delay in granting this would result in a hardship to Republic Airlines and our customers due to noncompliant and subsequently grounded aircraft. Thank you for your consideration of this request. Please don’t hesitate to contact me if you have any questions or concerns

I look forward to your response.

Sincerely,

James Boothe Director of Quality Assurance Republic Airlines
317

- 471

- 2256 jboothe@republicairlines.com

Enclosures:
Bombardier Letter Honeywell Quality Assurance Coordination MemoAEROSPACE

123 Garratt Blvd Downsview, Ontario

Ca nada M3K 1Y5

www.bombardier.com

TEL 416

- 633

- 7310

FAX 416

- 375

- 4525 November 22nd , 2013

File: 8

- 21

- 1 Rev.

-

ATTENTION: FAA

, Regulations Republic Airlines & Horizon Air

SUBJECT: DHC

- 8 Series 400 FAA 14 CFR Part 121.346 Flight Data Recorders: Filtered Data

- Request of three months exemption for compliance from FAA

R EFERENCE : Honeywell Quali ty Assurance CM CSB

- 104980 Rev 2, Nov 22 nd , 2013

To whom it may concern

,

T he purpose of this letter is to sup port Horizon Air and Repub l ic Airlines of requesting FAA for granting a three month exemptio n after April 2 1, 2014 for demonstrating compliance with FAA

14 CFR Part 121.346 Flight Data Recorders: Filtered Data.

BACKGROUND

DHC

- 8 Series 400 System Description :

The DHC

- 8 Series 400 aircraft is equipped with a Solid

- State Flight Data Recording sys tem

, which is basic to the avionics installation. It comprises of a Solid

- Sta te Flight Data Recorder (SSFDR), an acceleration (impact) switch, which interfaces with the Flig ht Data Processing System (FDPS) residing within the Input Output Module (IOP), a test circuit, an input power interlock arrangement and the flight

- deck Caution panel.

The SSFDR system operates by receiving mandatory and non

- mandatory parameters from the

FDPS and discrete from aircraft systems at a configuration module programmable 512 /128 words per second via an ARINC 717 databus. The unit store s 25 hours of data in a crash

survivable memory module for subsequent retrieval and analysis.

The SSFDR design, installation and recording database are compliant with the requirements of

EUROCA E Documents ED

- 55 and FAA 14 CFR Part 121.343 and 121.344.

In order t o accommodate additional parameters required by the FAA 14 CFR Part 121 aircraft in

2010 , a Flight Data Recorder Signal Conditioning Unit (FSCU p/n 1152862

- X ) was designed

and manufactur ed by Honeywell to install o n the DHC

- 8 Series 400 aircraft.

The FSCU was introduced to comply with the FAA 14 CFR Part 121.344 requirement to record the following parameters: DHC

- 8 Series 400 Operators2 - Pilot Pitch Control (Column) Position

- Copilot Pitch Control (Column) Posit ion

- Pilot Lateral Control (Handwheel) Position

- Copilot Lateral Control (Handwheel) Position

- Yaw Control (Rudder Pedal) Position

The FSCU is included in the basic installation on the DHC

- 8 Series 400 aircraft and an extension of the IOP Flight Data C oncentrator (FDC) functionality. The FSCU is a microprocessor based box with data control functionality performed by software. It processes and formats position data received from sensors installed in the flight controls, and outputs the

data for recordin g by the FDR.

The FSCU provides excitation voltages to the position sensing potentiometers. These sensors

convert the mechanical movement of the associated control position to a voltage signal, which is

transmitted back to the FSCU.

The FSCU processes th e voltage signals and converts them into ARINC 429 format for

transmission to the IOP. The IOP in its function as Flight Data Concentrator (FDC) includes

these data in the FDR frame format, which are transmitted to the FDR for storage.

The FSCU system pow er is supplied through an interlock system. In order to comply with the recording requirements of ED

- 55 and the airworthiness regulations, power to the FSCU is not applied automatically when aircraft power is first turned on. The FSCU is enabled only when

one or more of the following conditions is true:

- Red anti

- collision lights are switched ON, or

- White anti

- collision lights are switched ON, or

- Both engines are running, or

- Weight

- off

- Wheels is sensed, or

- Cockpit FDR Test switch is set to GND TES T.

FAA Title 14 CFR Part 121 Amendment:

FAA amended Title 14 Code of Federation Part 121 to revise Section 121.344a (e) and add Section 121.346 on April 20, 2010 regarding Flight Data Recorders

– Filtered Data

.

Section 121.346 (a) to (c) detailed the af fected parameters and criteria regarding filtering. Section 121.346 (d) stated the details about compliance time as follow:

(d) Compliance:

(1) No later than October 20, 2011, each operator must determine, for each airplane on its operations specification s, whether the airplane’s DFDR system is filtering any of the parameters listed in paragraph (c) of this section. The operator must create a record of this determination for each airplane it operates, and maintain it as part of the correlations

documentat ion required by 121.344(j ) (

3) of this part.3 (2) For airplanes that are not filtering any listed parameter, no further action is required unless the airplane’s DFDR system is modified in a manner that would cause it to meet the definition of filtering on any l ist parameter.

In order to support our DHC

- 8 Series 400 aircraft operator in the United States to demonstrate compliance with Section 121.346(d)(1) by October 20, 2011 , BA , together with the FSCU supplier, Honeywell, has analyzed the FDR parameters descri bed in Section 121.344(a)(12) through (17), (42) or (88), as required by Section 121.346(c) to determine if the recorded signal value is filtered and does not meet the requirements of Appendix M of Part 121.

During BA and H oneywell analysis of the relev ant FDR parameters on the DHC

- 8 Series 400, it

has been determined that the data collected from the force sensors are fed into the FSCU have been filtered by the Flight Data Recorder Signal Conditioning Unit (FSCU) to minimize the potential effect of senso r signal noise prior to FSCU ARINC 429 transmission.

Honeywell responded that the following parameters were filtered by a software based sampling averaging algorithm.

Parameter (12): Pilot and Copilot Pitch Control Input Position Parameter (13): Pilo t and Copilot Lateral Control Input Position Parameter (14): Rudder Pedal Control Input Position Parameter (88): Pilot and Copilot Control Wheel Force Parameter (88): Pilot and Copilot Elevator Control Column Force Parameter (88): Pilot and Copilot Lef t and Right Rudder Pedal Force

A Service Letter DH8

- 400

- SL

- 31

- 007 dated 9 September 2011 was sent to all our affected

DHC

- 8 Series 400 operators in the United States to summarize the results of the FDR parameters review and provide all relevant informatio n for recording as per Section 121.346(d)(1).

SCHEDULE

Plans for compliance with Section 121.346 (d):

Section 121.346 (d)(3) stated the details about compliance if FDR filtering has been observed:

(3) For airplanes found to be filtering a parameter listed in paragraph (c) of this section, the operator must either: (i) No later than April 21, 2014, remove the filtering or (ii) No later than April 22, 2013, submit the necessary procedure and test results required by paragraph (c)(2) of this section.

It has been deter mined that the FSCU filters force parameters destined for FDR recording. BA

has engage d with the FSCU supplier, Honeywell, to examine a solution for removal of the filtering from the current design.4 Between January to July 2012, several significant tec hnical impediments and business issues
were raised. First, it was unclear from the initial analysis if current FSCU software filtering functionality could be removed without additional supporting hardware modification. Second

, pr evious compliance to FAA 14 CFR Part 121 Appendix M in Year 2010 regulations requiring force sensor parameter sampling rate increased from 4 Hz to 8 Hz had consumed the maj ority of spare processing time . Third, r emoval of the software averaging functionality may allo w unacceptabl e sensor noise to be recorded requiring a dditional logic to remove nois e but ensure no data lag would add complexity to the design solution

.

Based on the above issues

, Honeywell had further review ed impact to system and commences developing three potent ial solutions:

Option 1: Complete Redesign of the FSCU creating a new box

Option 2: New design to communicate the yoke position with the Data Recorder

Option 3: Modification of the existing FSCU

At the beginning of S eptember 2012, BA and Honey well were evaluating the option stated

above.

Option 1: Complete Redesign of the FSCU creating a new box. New FSCU would have simplified signal chain maximizing accuracy and speed. Based on Honeywell relocation during development period a sub tier supplie r Curtis Wright to design, build and test new FSCU. Bombardier considered options as high cost, medium technical but high schedule risk. To be considered with option 3.

Option 2: New design to communicate the yoke position with the Data Recorder

The option of bypassing the FSCU with the yoke force sensor data to increase FSCU spare processing capacity. Option proved to be technical complex as data would have to be time stamped and merged with remaining FSCU processed data. Bombardier felt very compl ex solution involving multiple suppliers with unknown technical and schedule risk. Option was rejected.

Option 3: Modification of the existing FSCU FSCU modification if proven viable would have been most cost effective with moderate

schedule risk ho wever due to technical issues identified was considered too great a risk by BA to pursue as a sole means of compliance. Bombardier requested Honeywell to evaluate further with option 1.

November 2012, Honeywell confirmed no hardware modification of the existing FSCU (option 3)

was required t o remove signal averaging function. There was however significant risk of unacceptable sensor noise recorded. Bombardier requested Honeywell to develop a modified FSCU prototype based on the current box design for aircraft evaluation.5 There is increasing concerned that the FSCU redesign effort by Curtis Wright may not support the FAA retrofit campaign by April 21, 2014

.

During first quarter of 2013, a prototype FSCU with modified software is developed by Honeywel l (option 3)

.

Bombardier conducts formal functional and EMI ground based testing of the modified Honeywell

test unit , April 2013 . FDR record ed data is deemed acceptable. Honeywell was informed to officially develop, test, certify and proceed with option 3.

To expedite aircraft fleet implementation Honeywell reviewed the development of an in

- field FSCU software loading tool. This technique has proven to be difficult to implement by Honeywell and is not currently under consideration. This has negativel y impacted the aircraft impl ementation schedule as an FSCU rotation pool will be the sole means of aircraft upgrade.

Since June 2013, an aggressive development schedule supporting certification of new FSCU p/n 1152862

- 5 prior to April 21, 2014 mandate h as been generated:

Honeywell preparation of Drawings, software requirement development July

– August 2013

Honeywell build production software, prepare test cases, update Engineering documents i.e. software accomplishment summary,

interface control docum ent, version description document etc September

– October

2013

Honeywell building production FSCU October

– November

2013

Production FSCU and Software verification and validation by Honeywell October

- December

2013

Official release of Engineering docu ments after verification and validation, Certificate of Conformity and shipment of pr oduction unit to BA by Honeywell review software documents, update of wiring drawing, preparing modsum package

, facilitate customer certification testing on aircraft and p repare certification reports. December 2013 to January 2014

BA to perform production first article inspection . BA and Honeywell to release respective Service Bulletins. January

– February 2014

Honeywell update of Component Maintenance Manual. February 2 014

BA update aircraft maintenance manual and parts catalog February 2014

JUSTIFICATION6 Reasons for exemption requested:

Per the schedule above , the new updated FSCU will not be available for aircraft in

- service

retrofit until Feb 17, 201 4

.

There are total of 86 aircraft being affected with two major operators in the United States, primarily Horizon Air and Republic Airlines . The set up time required removing, replacing, closing up and return ing to service of t he FSCU is approximately 6 hours . T he intent is to perform 1 upgrade per night at Horizon and Republic’s facilities. There is an additional concern that some older in field FSCUs to be upgraded will be required to be brought up to the current production standard causing additional rework at Honeywell. This will a ffect the rotational unit pool turnaround times. It is estimated that based on 5 aircraft updates per week 4 months will be required to complete the fleet upgrade.

With the existing schedule it is anticipated that all 86 affected D HC

- 8 Series 400 will be retrofitted to comply with Se ction 121.346 by July 21st 2014.

BA’s position :

Therefore, we kindly request FAA for granting our operator with a three month exemption after April 21, 2014 on the compliance of Section 121.346.

If yo u have any further questions, please contact Christina Yung at 416

- 375

- 4038 or christina.yung @aero.bombardier.com.

R egards,

Chris Watkiss Manager , Airworthiness

– Toronto

## Quality Assurance Coordination Memo Honeywell International Inc.

This information is considered proprietary and confidential to Honeywell. If you are not the intended recipient, you are hereby notified that any form of dissemination of this communication is st rictly prohibited. If this information wa s sent to you in error, please immediatel y notify us by phone.

1 of 3 Product Name Q400 / Dash 8 FSCU Ref. Number CSB-104980
Customer: Bombardier

 Initial Issue Date 09/27/2013

Attention: Issue # / Date Rev 2 11/22/2013 Cord Memo Type Upgrade Campaign Originator: Carlotta Bowman – Product Support Program Manager, Deer Valley Status: Open

Distribution:
Bombardier: Tudor Madaras Honeywell: Mark Guenther
Roberto Diaz Atienza
Marius Dobre

SUBJECT: PM NIC/PROC Module

Product Information Platform/Program Q400 / Dash 8 FSCU Software Change Affected Part Name, Part Number FSCU, 1152862-1, -2, -3, and -4 change to 1152862-5 Affected Sub-detail Name, No. N/A

Scope of Product Affected All fielded units (86) in the United States of America ar e to be upgraded and modification included in all forward-fit equipment.

Description of Non-Conformance The specification of the existing Honeywell (HW) Flight Data Recorder Signal Conditioning Unit (FSCU) did not include requirements which comply with the new FAA regulation (FAR 121.346). With current design, the FSCU is filtering data by averaging samples, and this is not acceptable under the new mandate.

Current software filtering must be removed and the FSCU mu st continue to meet FAA-mandated acquisition speed and accuracy. The FAA Mandate FAR 121.346 amended in 2010 pr ohibiting filtered flight dat a being recorded; Affects Part 121, 125, 135 operations; compliance required by April 21, 2014.

System Effects FAA considers a signal filtered when an original sens or signal is changed in any way, other than changes necessary to:

• Accomplish analog to digital conversion of the signal

• Format a digital signal into a DFDR compatible format, or

• Eliminate a high frequency component of a signal outside the operational band width of the sensor The rule requires that, for the flight control related parameters, the DFDR system either:

• record unfiltered data

• record filtered data that meet t he required accuracy specifications, or

• record filtered data that can be reconstructed to recover the original unfiltered sensor signal values

Disposition/Recommendations This is not a Flight Safety Issue. Honeywell’s plan is to hav e all (86) units returned to the Toronto Service Center for upgrad e.

## Quality Assurance Coordination Memo Honeywell International Inc.

This information is considered proprietary and confidential to Honeywell. If you are not the intended recipient, you are hereby notified that any form of dissemination of this communication is st rictly prohibited. If this information wa s sent to you in error, please immediatel y notify us by phone.

2 of 3 Root Cause Investigation and Corrective Action(s)



### Root cause: FAA Mandate: FAR 121.346 amended in 2010 prohibiting filtered f light data being recorded; Affects Part 121, 125, 135 operations; compliance required by April 21, 2014



### Corrective Action: Current software filtering must be removed, but allow the FSCU to continue meeting FAA-mandated acquisition speed and accuracy

Honeywell Actions Upgrade (86) units, plus incl ude forward-fit equipment.

Initially it was believed that modification of the current FSCU would be problematic. Therefore Honeywell originally investigated a solution which involved the development of a completely new FSCU. However, program leadtime for Certification was well in excess of the April 2014 mandated date of compliance. Subsequently, additional review and testing of the current FSCU determined that a modifica tion of the Software was possible to meet the new FAA requirements.

A FSCU S/W development, certification and field implementation plan has been established and compressed where possible without adding un-acceptable risk. However, the overall program leadtime curre ntly exceeds the April 2014 incorporation date with current program completion by July 2014.

The following are key program Milestones for reference whic h commence with the initial testing, which confirmed the viability of the change to the current FSCU and concluding in Ju ly with the completion of all the aircraft modifications.

Software Change Implementation: Software Solution Accomplished Milestones: 1) A/C level confidence test was succ essfully completed – (Apr 2013) 2) BA sent Memo to HW summarizing test results – (May 2013) 3) HW submitted ECP – (Jul 2013) 4) BA approved ECP – (Aug 2013) 5) HW submitted improved Project Schedule – (Aug 2013) 6) Build & Test Production Verification and Validation – (Oct 2013) 7) Delivery of HW Black Label – (Nov 2013)

Software Solution Go Forward Milestones/ Next Steps: 1) BA Aircraft Testing Dec 2013 2) Rotation Units (10) to Support Rework Campaign Jan 2013 3) HW Release Service Bulletin Feb 2014 4) BA Release Aircraft Level SB Feb 2014 5) Upgrade Campaign Complete Jul 2014

Upon completion of the engineering development portion of this program, Honeywell will proceed with the following key program steps for the implementation of the software change on current in-service units. Once the software change is released and approved, it will also be incorporated in production for forward fit equipment.

1) Release New Software Change 2) Production and Test Validation and Verification

## Quality Assurance Coordination Memo Honeywell International Inc.

This information is considered proprietary and confidential to Honeywell. If you are not the intended recipient, you are hereby notified that any form of dissemination of this communication is st rictly prohibited. If this information wa s sent to you in error, please immediatel y notify us by phone.

3 of 3 3) Release Service Bulletin 1. SB will introduce new FSCU software. Additionally, it will include all concurrent requirements to bring units to the currently released -4 configuration. 4) Upgrade (86) FSCUs 1. Issue rotable units to operators (6 to Horizon, 4 to Republic)
2. Removed units will be returned to Toronto SC for software upgrade (covert to -5)

Upgrade Plan :

References

Preliminary List of Affected Operator Units requiring Upgrade:

Horizon Total = 51 -1 units Qty 14 -2 units Qty 8 -3 units Qty 16 -4 units Qty 13

Republic Total = 34 -3 units Qty 19 -4 units Qty 13

Concurrent Requirements:

Honeywell SB 1152862-31-01, Modification of P/N 1152862-1 to P/N 1152862-2 Honeywell SB 1152862-31-02, Modification of P/N 1152862-2 to P/N 1152862-3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

455555555555555551

4 9 14 19 24 29 34 39 44 49 54 59 64 69 74 79 84 85

33433433433433433433433432

3 6 10 13 16 20 23 26 30 33 36 40 43 46 50 53 56 60 63 66 70 73 76 80 83 85

Tuesday Operator ships exchanged parts to Honeywell for upgrade Operator Action Wednesday Honeywell ships upgraded parts to Operator Honeywell Action QTY: 10 Rotable Units (6 Horizon & 4 Republic)

Week Day Description Monday & Tuesday Toronto R&O upgrades units received earlier week Honeywell Action

Nominal Case Thursday & Friday Toronto R&O upgrades units received on Tuesday Honeywell Action Friday Operator ships exchanged parts to Honeywell for upgrade Operator Action

Total Units

Worst Case

Total Units

WEEK Saturday Honeywell ships upgraded parts to Operator Honeywell Action

1 Cycle = 6 Days