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January 27, 2014

Dear Sir or Madam:

In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) §11.61, Jet Aviation 

Flight Services, Inc. (KKVA618M), for Dassault 900LX & EXEASy / N261CH & N918JM, we submit a 

petition for an exemption from a section of 14 CFR Part 135.156.

You will find in attachment to this letter the necessary information to support our petition.

Should you have any question, please do not hesitate to contact us at the following address:

Darrell Hunter

112 Charles Lindbergh Dr.

Teterboro NJ 07608

317-839-0192 / fax: 866-684-4760

Petition for Exemption: Docket No FAA-2006-26135 / Flight Data Recorders

In accordance with the requirements of 14 CFR §11.81(a)-(g), we provide the following detailed

information in support of our petition:

14 CFR 11.81(a) - Contact information:

Darrell Hunter

112 Charles Lindbergh Dr.

Teterboro NJ 07608

317-839-0192 / fax: 866-684-4760

14 CFR 11.81(b) - Specific section from which relief is sought:

For Dassault 900LX N261CH & Dassault 900 EXEASy N918JM, we request relief from the following 

portion of 14 CFR:

§135.156, Amdt 135-120, Flight data recorders: filtered data

(d) Compliance. Compliance is required as follows:

(4) After April 21, 2014, no aircraft flight data recording system may filter any parameter 

listed in paragraph (c) of this section that does not meet the requirements of Appendix D or F of 

this part, unless the certificate holder possesses test and analysis procedures and the test results 

that have been approved by the FAA. All records of tests, analysis and procedures used to 

comply with this section must be maintained as part of the correlation documentation required by 

§ 135.152 (f) (1) (iii) or (f) (2) (iii) of this part as applicable.

14 CFR 11.81(c) - Extent and reason for seeking relief:

For Dassault 900LX N261CH & Dassault 900 EXEASy N918JM, we are requesting an exemption from 

compliance with the above listed portion of the flight data recorders. Compliance with the regulations 

requires retrofit with EASy II upgraded avionics Load. Considering the large amount of Falcon aircraft 

being retrofitted with EASy II upgraded avionics, there is a significant waiting time before being accepted 

in a Service Center for retrofit. The amount of aircraft retrofitted monthly is limited worldwide, by the large 

amount of equipment’s to supply. Finally, this retrofit requires a significant downtime to adapt to 

scheduled maintenance checks in a way to maintain reasonable operational use of our aircraft. After 

review, we plan to retrofit our aircraft with EASY II upgraded avionics N918JM July 2014 / N261CH 

September 2014.
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14 CFR 11.81(d) - Public interest / benefit:

Jet Aviation Flight Services is a Part 135 Air Carrier certificated in accordance with 14 CFR Part 135. Jet 

Aviation Flight Services operated aircraft, to include Dassault 900LX N261CH & Dassault 900 EXEASy 

N918JM, are offered for charter services to the public. Jet Aviation Flight Services charter clientele are 

primarily business leaders that find it necessary to charter an aircraft in order to maximize their time and 

availability to operate their business. Charter aircraft allow business executives and key personnel the 

flexibility to quickly react and meet obligations to advance their business, thereby strengthening the 

company’s position and help to provide a stable job market, which in turn strengthens US economy.

Considering that a temporary exemption to allow operations with filtered parameters has no direct impact 

on the safety of that individual aircraft, denial of service to these business leaders to quickly react, grow 

their companies and provide much needed jobs, would be an undue burden on the public as a whole.

14 CFR 11.81(e) - Information supporting this petition:

This petition for exemption is related to the Flight Data recorder: data filtering to be removed, as

mandated by 14 CFR §§135.156 Amendment 135-120. This exemption, if granted, would allow us to

benefit from the commercial use of Dassault 900LX N261CH & Dassault 900 EXEASy N918JM between 

April, 21, 2014 and September 2014 / July 2014. If this petition is denied, then commercial flight 

operations of Dassault 900LX N261CH & Dassault 900 EXEASy N918JM will have to be interrupted until 

EASy II upgraded avionics retrofit is applied. Granting this exemption would not affect nor degrade the 

inherent safety of the airplane. This exemption deals only with the recording of pitch control surface 

position (parameter 15), lateral control surface position (parameter 16), yaw control surface position 

(parameter 17) and cockpit flight control input forces (parameter 88); it therefore has no impact on 

operational safety.

14 CFR 11.81(f) - Federal Register summary:

Petitioner: Jet Aviation Flight Services

Affected Regulations: 14 CFR §135.156(d) (4), Amdt 135-120.

Summary of Relief Sought: Jet Aviation Flight Services, seek exemption from section 14 CFR part 

135.156 to allow Dassault 900LX N261CH & Dassault 900 EXEASy N918JM to operate with filtered data 

from April, 21, 2014 to N918JM July 2014 / N261CH September 2014.

14 CFR 11.81(g) - Additional information:

Granting this petition would have no effect on the regulatory burden of small businesses, small

organizations, and small governmental jurisdictions.

Granting of this petition would have no effect on the recordkeeping and reporting burdens for any

involved parties.

Respectfully,

Darrell Hunter

Director of Quality Assurance