14MAY 2014

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

Room W12

- 140 1200 New Jersey Ave. SE. Washington, D.C. 20590

RE: ISPA 254T Petition for Exemption:

Dear Sir/Madam

,

Springfield Aircraft Charter & Sales, Inc . respe ctfully petitions the FAA for

authorization to deviate from 14 CFR §135.89(b)(3) (Pilot Requirements: Use of Oxygen) by establishing equivalent levels of safety operating under 14 CFR §121.333 (c)(2)(i)(A) (Supplemental Oxygen for Emergency Descent....)

By granting authorization to Springfield Air to operate under 14 CFR §121.333 (c)(2)(i)(A), Springfield Air will realize significant savings in on

- board oxygen duration, thereby enhancing operational safety when conducting extended over

water /remote missio ns. This reduction in enroute oxygen use is paramount when flight planning extended operations ov er remote and/or oceanic areas by increasing the amount of available oxygen at the Equal Time P oint (ETP) for cabin depressurization emergencies.

In some case s, the ability to remain at FL2 50 for extended periods of time, post loss of cabin pressure

, is mandatory to prevent incurring a wet footprint or for terrain clearance requirements in areas of exceedingly high terrain.

The current Springfield Aircraft fl eet make up is such that aircraft system oxygen is available to all crew/ passengers and the passenger masks are approved for

co ntinuous use up to FL 250. Because of this capability, Springfield Air is able to improve overall safety by descending to FL250 (i nitially) during an aircraft depressurization , rather than a continuous descent to 10,000 feet. This strategy

serves two purposes:• Enhanced terrain separation clearance

- there are few geographic areas around the world that would penetrate the FL250 capa bility of our aircraft. By limiting the initial descent during a depressurization to FL250, the crew

is able to regroup and evaluate terrain/obstacle clearance before commencing further descent.

• Extended ETP envelope

- most 14 CFR 121 Air Carriers plan a d escen t to FL100 after experiencing a depressurization, incurring huge penalties in

enroute fuel flow and a drastic increase in diversion times as a result. Additionally, when conducting oceanic or remote operations, the aircraft is

now limited in diversion capability due to the low altitude

, high fuel flow

, and resultant low true airspeed . Conversely, Springfield Air ’s aircraft are able to level at FL250, above significa nt terrain and weather, and hold higher Mach/true airspeed, thereby reducing diversion t ime s to the alternate airport.

The relief from 14 CFR §135.89(b)(3) simply delays, for a short period, the onset of single crewmember oxygen depletion while manning the flight deck. 14 CFR

121 aircraft operate predominantly between FL 330

- 370 , whereas cor porate aircraft are designed to start cruise at FL390

- FL410 and continue optimiz ed climb schedules to as high as FL510.

The stark reality is that few corporate aircraft can make designed range profiles below FL410, our fleet included. In fact, the GV’s Q RH handbook fligh t planning chart (See below ) starts at FL390 and continues up to FL490. The difference in hourly fuel burn between FL350 and FL450 ( See below ) is almost 1,000 pounds per hour; over a typical 10

- 12 hour flight its obvious to see the importa nce altitude plays in efficiency and range.Illustration Showing Initial Level OffIllustration Showing Length of Time at Initial Level Off Altitude Below

FL410Illustration Depicting Fuel Flow Difference Between FL350 and FL450Analyzing a mid size, mid range, corporate aircraft co nducting a flight from SFO

H NL with 6 passengers and 2 crew (oceanic/remote operations) and close to the limit of what the aircraft is capable of. The aircraft cannot, under most circumstances, descend to FL100 a fter a depressurization and make land with the required reserve s, i.e.

, incurring a wet footprint. Under this scenario, once reaching FL100, the aircraft must slow to max range cruise just to make land taking roughly 3+51. However, by stopping descent at F L250 to expend on board

oxygen (120 minutes) , then commencing descent to F100 the aircraft ea s ily makes land over 1.7 hours sooner, at roughly 2+10. Reducing crew and passenger exposure to extended diversion times during emergency situations is paramount t o a successful (and survivable) outcome to an emergency. See examples below

Results for descent to FL100

-

Results for descent to FL250 for 120 minutes

-The significance of this scenario is the fact that prior to reaching FL410, upon passing FL3 50 , at least one crewmember must be depleting the oxygen system. Under the above scenario, the oxygen reserve (fully serviced bottle) at FL250 is approximately 161 minutes (3140 liters of O2) , minus what the crew consumes prior to the ETP. To prevent a wet f ootprint scenario, the aircraft must arrive at the ETP with approximately 2,640 liters of oxygen (120 minutes at FL250 for 2 crew and 6 pax). Estimating an average consumption rate of 3 liters/min ( per single crew member at a typical pressurized cabin alti tude) for the 146 minutes it takes to

arrive at the ETP and that crewmember has depleted 438 liters of available oxygen. Leaving roughly 2702 liters of oxygen remaining (3140 liters of fully serviced O2 system). This leaves a difference of only 62 liters o f oxygen. Bear in mind that these numbers are based on a fully serviced bottle at 1800psi.

Where relief from 14 CFR §135.89(b)(3) will come into play is by delaying the depletion of oxygen until reaching higher flight levels (above FL410). In this case, we would expect to be above FL350

, but below FL410

, for approximately 30 minutes, thereby saving roughly 90 liters of oxygen.

When we discuss longer

- range missions in the GV

, where initial level off altitudes at high gross weights are below FL410 for, i n some cases, several hours

, we could realize savings of roughly 300

- 500 liters of oxygen. This is a significant factor in mitigating compound emergencies and reducing risk to those on board. By complying with 14 CFR §121.333 (c)(2)(i)(A), flight crews wil l be better prepared to deal with a loss of cabin pressure by having the maximum amount of available oxygen when it is needed the most

- to execute a rapid descent to a safe altitude and extend diversion cruise capability at a higher altitude.

In establi shing safety benchmarks, it is also important to note that both fleet aircraft types Springfield Air currently operates include an automatic Emergency Descent Mode designed to augment/protect the initiation of an emergency descent

should the crew become in capacitated. Both the GV and CE750, with autopilot engaged, will initiate a 90

- degree left turn, descending at Vmo/Mmo to 15,000 and

level off. The following illustrations describe these modes of operation on the respective aircraft.GV Emergency Descen t Mode

-CE750 Emergency Descent Mode

It is also important to note the redundancy built into both the GV and CE750 pressurization systems , which are certi fied under 14 CFR 25 Transport C ategory Federal regulations (same as 121 air carriers)

. Both aircraft have two sources of engine bleed air

, either of which is sufficient to meet the demands of the aircraft. Additionally, both aircraft are equipped with dual air conditioning packs, each of which is capable of supplying sufficient pressurizatio n air in the event one unit fails. Both aircraft are equipped with an isolation valve that will allow one engine to supply bleed air to both packs in the event of an engine failure, bleed leak, or other cause for single source bleed supply. GV Schematic to follow

-Both aircraft are equipped with dual pressure vessel bulkheads between the cabin and baggage compartments. If the baggage door seal were to fail, the secondary pressure vessel and check valves automatically isolate the baggage compartment

a nd maintain normal cabin pressure. CE750 Procedure

-Both aircraft pressurization controllers are triple redundant with an automatic, manual, and emergency mode of control that are supplied power from multiple

redundant sources.In terms of warnin g systems available to advise the flight crew of impending failure or increasing cabin altitude both aircraft are equipped with multiple set points for both warning and caution messaging, including aural advisories.

The p assenger oxygen system auto matically deploys at approximately 13,500 feet,

and above a cabin alti tude of FL370 , crew oxygen masks automatically provide pressure breathing rather than just 100% oxygen.

As a result of the multiple levels of redundancy in the pressurization system, o ne of the only means of a truly “rapid” or “explosive” decompression would be a significant structural failure of a cabin door, cabin or cockpit window, or failure the aluminum skin structure or ribbing. To date, there has never been such a

failure on eith er aircraft since their certification in the late 90’s.Springfiel d Air’s fleet are also equipped with TSO’d (C78a, C89a, C99a) quick donning on

- demand oxygen masks of the same make/model. More importantly, the same operating procedures for both O2 ma sks are employed. Furthermore, these systems are certified under 14 CFR 25

, § 25.1441

- 25.1453, the very same regulations Part 121 Air Carrier aircraft are manufactured thereby positively establishing equivalent levels of safety.

Example of Crew Oxygen M asks

-In summation, Springfield Air is not seeking relief from 14 CFR §135.89(b)(3) as a means to circumvent Federal regulations , quite the contrary. Due to the diverse and complex nature of Springfield Air flight operations, through intense

ope rational analysis, it has been deemed vital to flight safety to mitigate oxygen depletion to conserve, as much as feasible, emergency oxygen reserves in the event an aircraft experiences a loss of cabin pressure and is forced to descend to

lower altitudes. Springfield Air believes it has demonstrated a valid need for the exemption to increase public safety based on analysis and risk mitigation/prevention techniques from our Safety Management System analysis

. It is truly in the interest of public safety that this exe mption to adopt 14 CFR §121.333 (c)(2)(i)(A) be granted to Springfield Air.

Springfield Air invites comments, questions, and feedback with regard to the petition for exemption.

Sincerely yours,

Louie	DeSantis Assistant	Director	of	OperationsPursuant	to	the	requirements	of	CFR	14 § 11.81

-

a) Springfield	Aircraft	Charter	&	Sales

Air	Carrier	Certificate	ISPA254T
10	NW	Richards	Road,	Suite	108 Kansas	City,	MO	64116

1

- 888

- 218

- 2085

b) 14 CFR §135.89(b)(3)

- Pilot Requirements: Use of oxygen “ Whenever a pressurized aircraft is operated at altitudes above 35,000 feet MSL, at least one pilot at the controls shall wear, secured and sealed, an oxygen mask required by paragraph (b)(2)(i) of this section”

c) Springfield Air seeks relief from 14 CFR §135.89(b)( 3) by establishing equivalent levels of safety operating under 14 CFR §121.333 (c)(2)(i)(A) Supplemental Oxygen for Emergency Descent and for First Aid “ (i) The one pilot need not wear and use an oxygen mask at or below the following flight levels if each flight crewmember on flight deck duty has a quick

- donning type of oxygen mask that the certificate holder has shown can be placed on the face from its ready position, properly secured, sealed, and supplying oxygen upon demand, with one hand and within five seconds:

(a) For airplanes having a passenger seat configuration of more than 30 seats, excluding any required crewmember seat, or a payload capacity of more than 7,500 pounds, at or below flight level 410. ”

d) *See supporting material petition above

e) *See supp orting material petition above

f) See summary on subsequent page

-Summary for Federal Register (14 CFR §11.81) (f)

Petitioner: Springfield Aircraft Charter & Sales (ISPA254T)

Rule for which exemption sought: 14 CFR §135.89(b)(3)

Springfield Air cra ft Charter & Sales is seeking relief from the 14 CFR §135.89(b)(3) FL350 oxygen requirement to delay the depletion of the aircraft oxygen system until FL410 in accordance with 14 CFR §121.333 (c)(2)(i)(A).

Springfield Aircraft Charter & Sales requests wo rldwide effectivity for exemption

since roughly 60% of our flight operations occur outside the continental United

States

, and this exemption is most needed on long

- range international missions.