Skyknight Air Services, Inc. 

5115 NWl f Terr, 39B 

Ft Lauderdale, FL 33309 

Watermakers Air, Inc. 

2545 NW55*'' Court, Hanger 26 

Ft Lauderdale, FL 33309 

Dolphin Atlantic, Inc. 

702 SW 34'" Street 

Ft Lauderdale, FL 33315 

Davonair, Inc. 

9725 NWS^ " Street, Suite 503 

Doral, FL 33178 

Exemption Sought: 

Exemption Request: 

Reason for Relief: 

Safety: 

History: 

PETITION FOR EXEMPTION TO 135.183(a) 

Relief from 14 CFR 135.183 (a) 

Authorization for Sl<yl<niglit Air Services, Inc., Watermakers Air, Inc., Doipliin Atlantic, Inc., and 

Davonair, Inc. to conduct air-carrier operations witli passengers for liire beyond gliding 

distance from land. We request the adoption of ICAO Annex 6, Part 1, which allows 15 minutes 

at cruise power setting (41 n.m. for the Cessna 208B with Cargo Pod) beyond the power-off 

gliding distance to land per C-208B AFM Figure 3.1. 

To ensure compliance with 14 CFR 135.183(a) in high-density environments where ATC 

Approach and Departure fixes and altitudes may place turbine-powered single-engine aircarrier operators with passengers for hire, beyond the power-off gliding distance of land. ATC 

currently requires the above listed operators to descend to an altitude which puts them 

beyond the glide to land distance because it is "necessary for landing." 14 CFR 135.183(b) does 

however provide an exemption to 135.183(a) which reads: "No person may operate a land 

aircraft carrying passengers over water unless it is necessary for talieoff or landing." 

The Pratt and Whitney PT6-114A turbine-powered engine in the Cessna Caravan has over 18 

Million Fleet hours and an extraordinary documented safety record. 

ICAO has already certified the Pratt & Whitney Canada powered PT6-114A engine in the Cessna 

Caravan for such over-water operations. (See excerpts below) 

ICAO International Standards and Recommended Practices 

Operation of Aircraft 

Annex 6 to the convention on International Civil Aviation 

Part 1 International Commercial Air Transport - Aero planes 

Eighth Edition July 2001 with amendment 29 

6. 

6.1 

Route limitations over water 

Operators of single-engine turbine-powered aero planes carrying out operations at night 

and/or in IMC should mal^e an assessment of route limitations over water. The distance that 

the aero plane may be operated from a land mass suitable for a safe forced landing should be 
determined. This equates to the glide distance from the cruise altitude to the safe forced 

landing are following engine failure, assuming still air conditions. States may add to this and 

additional distances taking into account the likely prevailing conditions and type of operations. 

This should take into account the likely sea conditions, the survival equipment carried, the 

achieved engine reliability and the search and rescue services available. 

6.2 Any additional distance allowed beyond the glide distance should not exceed a distance 

equivalent to 15 minutes at the aero plane's normal cruise speed. 

Engine Reliability 

The Caravan engine reliability is more than 200% the ICAO requirement. 

Reference: Appendix 3 Additional requirements for operations of single-engine turbine powered aero 

planes at night and/or in Instrument Meteorological Conditions (IMC). 

Paragraph 1.1 Turbine engine reliability. Turbine engine reliability shall be shown to have a 

power loss rate of less than 1 per 100.000 engine hours. 

The Caravan's P&W PT6-114A engine has accumulated over 18 million fleet hours and 

continues to add 1,000,000 hours annually. Current P&W MTBUR (Mean Time Between 

Unscheduled Removal Rate) is 1 per 250,000 hours of operation. This is more than twice the 

ICAO requirement. 

Additional P&W PT6-114A historical data 

-27,910 Hours on Highest Time Engine 

-9,000 Hours. Highest TBO. FedEx routinely operates this engine 9000 hours between 

overhauls. 3,600 Hours is the basic engine TBO. 

-2,184 Engines produced with 1,799 installed 

Advance in Engine reliability over past 40 years 

Over the last 40 years, the reliability of jet & turbine engines has increased dramatically. 

Nowhere is this more evident than in the Airline industry where in the past only jetliners with 3 

or 4 engines crossed the oceans. Now jets with only 2 engines routinely cross the oceans. 

Initially, the 2 engine jets had small wet footprints, but as the reliability of engines increased 

and safe flying hours accumulated by the millions, the wet footprint was increased significantly. 

The ICAO regulators have recognized this and recommended a wet footprint for the Caravan 

detailed in point 3 below. 

ICAO recommended wet footprint for Single Engine Turbine over water flights 

Reference: Attachment I Additional requirements for operations of single-engine turbinepowered aero planes at night and/or in Instrument Meteorological Conditions (IMC) 

Paragraph 6 Route limitations over water 
Paragraph 6.1 Paraphrased "Power off gliding distance to a safe landing area from cruise 

altitude in still air conditions." 

Paragraph 6.2 Paraphrased "additional distance beyond the power off gliding distance in 6.1 

above should not exceed a distance equivalent to 15 minutes at aero planes' normal cruise 

speed. 

The equivalent distance of 15 minutes at cruise speed is 41 miles with a 165 knot cruise speed 

giving the Caravan a 41 mile wet footprint. 

tes. Inc. 

Signature 

Name and Date 

Dolphin Atlantic, Inc. 

Signature 

Name and Date ^ 

Name and Date 

Dav9;nair, Inc. 

Signature 

Name and Date 

ig._i^-?b 

* \ ^ * MY COMMISSION IDD 330452 

,^^0* ^ EXPIRES: October 10,2013 

"''foh ^ BondKl Thru B«)g»( Notary SxvicM