December 16, 2013 

US Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

WASHINGTON, D.C. 20590 USA 

SP AVIATION, Inc. ~----------~~~~ 800-466-3538 

Executive Aircraft Charter Service.~ 

SUBJECT: Falcon F2000EX, N626NT- Petition for Exemption Applicable to: Flight. data recorders filtered 

data. Regulation Reference: Docket No FAA-2006-26135- Flight data recorders: Filtered data Regulation, 

Final Rule 

Dear Sir or Madam: 

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

Inc., for Falcon F2000EX, N626NT, 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 me at your convenience 

Respectfully, 

Stephen D. Rowell 

Director of Maintenance 

510-358-5726 

8517 Earhart Road, Suite 300 Oakland, California Office (51 0)-695-2796 Fax (510)-783 3587 
Petition for Exemption 

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: 

Stephen D. Rowell 

8517 Earhart Road, Suite 300 

Oakland, California, 94621 

510-358-5726 

steverowell@spaviation.com 

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

For Falcon F2000EX, N626NT, we request relief from the following portion of 14 CFR: 

§135.156, Amendment 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)(l )(iii) or 

(t)(2)(iii) of this part as applicable. 

14 CFR 11.8l(c)- Extent and reason for seeking relief: 

For Falcon F2000EX, N626NT, 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 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 during the month of April 

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

Being unable to operate N626NT would have a significant economic burden on us. 

Denial of this petition would not be in the public's interest and would significantly reduce 

the operational capability of the affected aircraft, relegating these business aircraft to a 

state of reduced capability: indeed, Flight Data Recorder removal of data filtering is 

covered in EASy II global avionics upgrade offering others functionalities such ADS-B 

Out, FANS1A, ATNB1 or LPV. For the period in which the exemption would be in 

effect, there would not have any safety degradation. 

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 Falcon F2000EX, 

N626NT after the effective date April 21, 2014 in the event the service kit is delayed by 

the OEM. Falcon F2000EX, N626NT is tentatively scheduled to have this modification 

completed by April 17, 2013 by Western Aircraft located in Boise ID. If this petition is 

denied, then commercial flight operations of Falcon F2000EX, N626NT 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: SP Aviation, Inc. 

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

Summary of Relief Sought: SP Aviation, Inc. seeks exemption from section 14 CFR Part 

135.156 to allow Falcon F2000EX, N626NT to operate with filtered data beyond the 

effective date of April, 21, 2014 until such time service kit becomes available from the 

OEM. 

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. 
,• 

FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

FAA Mandate for Digital Flight Data Recording 

Oct 20, 13 I Classification: Maint&Ops 

F10 F20 F200 F50 F900 F2000 F7X 

- -5 - EX - EX EASy ox LX - EX EASy ox LX s LXS 

X X X X X X X X 

11 PURPOSE OF REVISION 

Revision Date Description 

3 10/20/13 Describes the exemption policy, if compliance with the FAA 

Mandate is not possible before April 21, 2014. 

Further engineering evaluation has determined that Falcon 

900EX EASy I 900DX I 900LX series aircraft in EASy II first 

certification configuration will require EASy II second certification 

to meet the requirements for the removal of all DFDR parameter 

filtering. 

Z REASON 

On February 19, 2010 the Federal Aviation Administration (FAA) has published the "Filtered 

Flight Data" Final Rule 75 FR 7345 related to the recording of filtered flight data. This Rule is 

effective as of April 20, 2Q10. 

This final rule applies to every Falcon aircraft operated under 14 CFR Part 135 and equipped 

with a Flight Data Recorder. It prohibits the filtering on the 8 following parameters: 

• Pitch control position. 

• Lateral control position. 

• Yaw control position. 

• Pitch control surface position. 

• Lateral control surface position. 

• Yaw control surface position. 

• Throttle/power lever position. 

• All cockpit flight control input forces (control wheel, control column, rudder pedal). 

Advisory Circular (AC) No. 20-1418 Appendix 5 addresses the means of compliance with 

this final rule. The following compliance schedule is required: 

• Before October 20, 2011, operators must determine if the 8 critical parameters listed 

above are filtered. If any of those parameters are filtered, then the operator must 

recordwhich parameters are affected. If not, no further action is to be taken, unless a 

future change is made to its Digital Flight Data Recorder (DFDR) system. 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

• Before April 22, 2013, operators that report filtered parameters may choose to 

demonstrate to its FAA certificate holding district office that filtered data can be 

reconstructed. 

• Before April 21, 2014, operators that report filtered parameters must remove the filtering. 

<f' FOLLOW UP/ TECHNICAL FINDINGS 

As defined in FAA AC 20-1418 Appendix 5, a signal is filtered when the original sensor 

signal has been changed in any way, other than changes necessary to convert the signal 

from analog to digital, to reformat a digital signal into a DFDR compatible format or to 

eliminate a high frequency component of a signal that is outside the operational bandwidth of 

the sensor. 

An original sensor signal is a direct electronic output from a sensor or a system that accepts 

and processes multiple sensor inputs (Air Data Computer, flight control system on F7X). 

The DFDR (Digital Flight Data Recorder) does not filter any parameter, but only records 

them. 

The signal changes or filtering may be processed by the acquisition unit: Flight Data 

Acquisition Unit (FDAU) dedicated to DFDR, Data Acquisition Unit (DAU) integrated in the 

avionics or Custom 110 modules in the MAU on EASy aircraft. 

Analysis of the 8 mandatory signals and their processing upstream the DFDR has been 

performed for each Falcon model equipped with an acquisition unit certified through a 

Dassault modification. This analysis also applies to DFDR installations through Dassault 

Falcon Jet STC, because these installations are the same as certified by Dassault 

modification. 

This analysis has determined that on the aircraft listed in the table below, the following 

parameters are filtered by software with a cut-off frequency inside the operational bandwidth 

of the sensor: 

• 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) (only for Falcon 900EXy in EASy 

Step 3+) 

Falcon 900EX EASy I 900DX I In EASy Step 3+ (load 21) and EASy II 151 certification 

900LX (load 24.2) software, equipped with a DFDR as per 

Dassault modification M3349. 

Falcon 2000 EASy I 2000DX I In EASy Step 31oad 12, load 14.2 or 14.4 software, 

2000LX equipped with a DFDR as per a Dassault modification 

M2508, M2515 or M3059. 

Consequently, these airplanes do not comply with the FAA Final rule. 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

All the other Falcon airplanes, not listed in this table and with a DFDR installation through a 

Dassault modification or a Dassault Falcon Jet STC comply with the FAA Final Rule. 

I Falcon 900EX EASy I 900DX I 900LX in EASy II 2"d certification (load 26.0), Falcon 2000 

EASy I 2000DX I 2000LX in EASy II (load 16.0), Falcon 2000S I LXS comply with this rule. 

Dassault Aviation recommends that Falcon operators whose airplanes are equipped with a 

data acquisition unit and I or a FOR installed by Supplemental Type Certificate (STC) should 

contact the STC holder for disposition. 

~ CORRECTIVE ACTION 

The DFDR parameters 15, 16, 17 and 88 software filtering has been suppressed in the EASy 

II load for Falcon 2000EX EASy I DX I LX (A/C with M3254 or SB F2000EX-300) and in the 

EASy II 2"d certification load. for Falcon 900EX EASy I DX I LX (A/C with M5595 or SB 

F900EX-400 Revision 3, F900EX-414 Revision 4). 

The reconstruction of filtered data as acceptable means of compliance for the FAA (before 

April 2014 ) is not achievable on Falcon aircraft, which have not incorporated the EASy II 

software listed above because there is no way to demonstrate by test and analyses that 

filtered data can be reconstructed with the accuracy requested by the Final rule. 

Therefore, operators whose aircraft have filtered parameters and are operated under 14 CFR 

Part 135 must continue to record them until the filtering is removed through EASy II Service 

Bulletin F2000EX-300, F900EX-400-R3 or F900EX-414-R4, no later than April 21, 2014. 

'"; INFORMATION 

1. EUROPEAN REGULATION 

I As of today, no European Regulation requires removing the filtering of flight on European 

registered aircraft. 

In 2012, European Aviation Safety Agency (EASA) has published the final rules for flight data 

recording within the Implementing Rules AIR OPS EU 965 Part CAT with the Acceptable 

Means of Compliance (AMC), CAT.IDE.A 190. These rules do not include such 

requirements. 

A DASSAULT <'~ r.ALCONCUSTOU£RSFRYICE 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

2. EXEMPTION POLICY 

In order to support customers which are not able to remove the DFDR parameter filtering 

before the April 21, 2014 deadline, the below guidance is provided to help apply for an 

exemption in accordance with FAR11.63 & FAR11.81. 

In accordance with FAR11.63, submission of the petition must be done 120 days before the 

exemption takes effect meaning December, 22, 2013. 

To submit a petition for exemption: 

(1) By electronic submission, submit your petition for exemption to FAA through the 

Internet at http://www.regulations.gov/#!home, the Federal Docket Management 

System Web site. For additional instructions, you may visit 

http://www.faa.gov/regulations policies/rulemakinq!petitionlmedia/Send Petition.pdf, 

with Docket FAA-2006-26135 instead of FAA-2007 -0001, while performing step 2. 

(2) By paper submission, send the original signed copy of your petition for rulemaking 

or exemption to this address: U.S. Department of Transportation, Docket Operations, 

West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE, 

Washington, DC 20590. 

l

in accordance with FAR 11.81, the following letter is an example of what operator may write 

to the FAA for its petition for exemption: 

Nota: For a word version of this letter, please refer to the attached file. 

Place] [Date] 

US Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

:Please contact [Name/Surname] 

mailto [Mail Address] 

1200 New Jersey Avenue, SE. 

WASHlNGTON, D.C. 20590 USA 

Tel: Fax: 

: SUBJECT: [Aircraft Type & Registration]- Petition for Exemption 

Applicable to: Flight data recorders: filtered data Regulation 

:Reference: Docket No F AA-2006-26135- Flight data recorders: filtered data Regulation, Final Rule 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

.-.. -~-·-·---·-----------------------·-·-·-·-·-------------·-·---·-----------------------·-·-------------------------·-·-·""1 

:Dear Sir or Madam: 

:In accordance with the provisions of Title 14, Code of Federal Regulations (14 CFR) §11.61, [name oC 

·Operator], for [aircraft type & registration], we submit a petition for an exemption from a section of 14 · 

:cFRPart 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: 

:[Name/surname] 

·[Address] 

: [Phone I fax:] 

: mailto: [mail address] 

Petition For Exemption 

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

: information in support of our petition: 

:14 CFR 11.81(a)- Contact information: 

:[Name/surname] 

:[Address] 

· [Phone I fax:] 

: mail to: [mail address] 

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

:For [Aircraft type & Registration number], we request relief from the following portion of 14 CFR: 

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

(d) Compliance. Compliance is required as follows: 

(4) After April21, 2014, no aircraft flight data recordi ng system may filter any: 

parameter listed in paragraph (c) of thi s section t hat do es not meet t he re quirements of· 

Appendix Do r F of this part, unless the certificate hoi der po ssesses test and ana lysis: 

procedures an d the test results that h ave been approved b y the FAA. All records o f tests, : 

analysis and procedures used to comply with this section must be maintained as part oft he· 

correlation docum entation required b y § 135 .152 (f)(1)(iii) o r (f)(2)(iii) of this part a s: 

applicable. 

: ~~ .DASSAULT • ~~ FALCONCUSTrJt.fERSERVICE 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

·-·-·-·-·---·-----·-·-·-·-·-·---·-·-·-·-·-----------------·-·---·---·-----·-·-·-·-----·-·-·-·---·-·-.. -----------·-·-·----., 

:14 CFR 11.8l(c)- Extent and reason for seeking relief: 

:For [Aircraft type & Registration], we are requesting an ex emption from compliance with the above: 

·listed portion ofthe 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 as ignificant waiting time before being accepted in a Service Center for: 

·retrofit. The a mount of aircraft retrofitted monthly is limited worldwide, by the I arge amount of· 

: equipments to supply. Finally, this retrofit requires a significant downtime to ad apt to schedule d: 

: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 [date]. 

: 14 CFR 1 1 .81 (d) -Public interest I benefit: 

:Being unable to operate [our airplane(s)] would have a significant economic burden on us. Denial of: 

· this petition woul d not be in t he public's interest and would significantly redu ce the operational · 

:capability of the affected aircraft, rei egating these business aircraft to a stat e of red uced capability: : 

:indeed, Flight Data Recorder removal of data filtering is covered in EASy II global avionics upgrade: 

:offering others functionalities such ADS-BOut, FANS I A, ATNBJ or LPV. 

:For the period in which the exemption would be in effect, there would not have any safety degradation. 

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

:This petition for exemption is r elated tot he Flight Data recorder: data filtering to be re moved, as: 

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

·benefit from the commercial use of [aircraft type & registration] between April, 2 1, 20 14 and [date· 

· :before beginning of the retrofit]. · 

. . ·If this petition is denied, then commercial flight operations of [aircraft type & registration] will have to. 

:be interrupted until EASy II upgraded avionics retrofit is applied. · 

:Granting thi s exemption would not affect nor degrade the inherent safety of the airpl ane. This: 

:exemption deals only with the recording of pitch control surf ace position (parameter 15), lateral: 

:control s urface pos ition (para meter 16), yaw control sur face pos ition (param eter I 7) and : 

:cockpit flight control input forces (parameter 88); it therefore has no impact on operational safety. 

: 14 CFR 11.81(t)- Federal Register summary: 

Petitioner: [Operator's Name] 

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

Summary of Relief Sought: [operator], seek exemption from section 14 CFR part 135.156 to allow· 

[aircraft type & Registration] to operate with filtered data from April, 21, 2014 to [date of the: 

beginning of the retrofit]. 

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FALCON SERVICE ADVISORY 

FSA-31-30-006-R03-B 

:14 CFR 11.8l(g)- Additional information: 

: Granting t his p etition wou ld have no effect on the regu Jatory burden o f small bu sinesses, sm all : 

:organizations, small governmental jurisdictions. 

: Granting of this petition would have no effect on the recordkeeping and re porting hurd ens for any : 

:l!!.~.s>.i.Y.~~-P-~!:!L~~:-·-·-·---·-·-·-·-·-·-·-·-·-·-·-·-·---·-·-·-·---·-·-·-·-·-·-·-·---·-·-·-·---·-·-·-·-·-·-·-·-·-·-·---·~ 

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