### December 16, 2013

US Department ofTransportation Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE. WASHINGTON, D.C. 20590 USA 

## SPAVIATION,Inc.**~----------~~~~** 800-466-3538 ExecutiveAircraftCharter**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 ofTitle 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 attachmentto this letterthe necessary informationto support our petition. Should you have any question, please do not hesitate to contact me atyour convenience
Respectfully,

Stephen D. Rowell Director of Maintenance 510-358-5726



### 8517 EarhartRoad, Suite 300 Oakland, California Office (510)-695-2796 Fax (510)-783 3587

## Petition for Exemption
In accordance withtherequirements of14 CFR §11.81(a)-(g), weprovidethefollowing detailed informationin support ofourpetition: 14 CFR 11.81(a)- Contactinformation: StephenD. Rowell 8517 EarhartRoad, Suite 300 Oakland, California, 94621 510-358-5726 steverowell@spaviation.com 14 CFR 11.81(b)

- Specific section from whichreliefis sought: For Falcon F2000EX, N626NT, werequest relieffrom 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 anyparameter listed inparagraph (c) ofthis section that does not meet the requirements ofAppendix D or F ofthis part, unless the certificate holder possesses test and analysis procedures and the test results that have been approvedbythe FAA. All records oftests, analysis and procedures used to complywiththis section must bemaintained as part ofthe correlation documentationrequiredby § 135.152 (f)(l)(iii) or (t)(2)(iii) ofthispart as applicable. 14 CFR 11.8l(c)- Extent and reason for seekingrelief: 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 waitingtimebeforebeing accepted ina Service Center for retrofit. The amount ofaircraft retrofitted monthly is limited worldwide, by the large amount ofequipment to supply. Finally, this retrofit requires a significant downtime to adapt to scheduled maintenance checks in a way to maintain reasonable operational use ofour aircraft. After review, we plan to retrofit our aircraft with EASY II upgraded avionics during the month ofApril 2014.

### 14 CFR 11.81(d)- Public interest I

### benefit: Being unable to operate N626NT would have a significant economic burden on us. Denial ofthis petition would not be inthe public's interest and would significantly reduce the operational capability ofthe 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 wouldnothave 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. Ifthis petition is denied, then commercial flight operations ofFalcon 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 ofthe airplane. This exemption deals only with the recording ofpitch 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 ofReliefSought: 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 ofApril, 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 ofsmall businesses, small organizations, and small governmentaljurisdictions. Granting ofthis petitionwould have no effect onthe recordkeeping and reporting burdens for any involvedparties.,• 

# FALCON SERVICEADVISORY 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 ofall 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 offiltered flight data. This Rule is effective as ofApril 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 ofcompliance with this final rule. The following compliance schedule is required: • Before October20, 2011, operators must determine ifthe 8 critical parameters listed above are filtered. If any ofthose 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 SERVICEADVISORY 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 anyway, otherthan changes necessary to convert the signal from analog to digital, to reformat a digital signal into a DFDR compatible format orto 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 orfiltering 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 ofthe 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 ofthe 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 SERVICEADVISORY 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. 

# IFalcon 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 holderfor 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 oftoday, no European Regulation requires removing the filtering offlight on European registered aircraft. In 2012, European Aviation SafetyAgency (EASA) has published the final rules for flight data recording within the Implementing Rules AIR OPS EU 965 Part CAT with the Acceptable Means ofCompliance (AMC), CAT.IDE.A 190. These rules do not include such requirements.



# A DASSAULT

## <'~ r.ALCONCUSTOU£RSFRYICE Page 3 

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# FALCON SERVICEADVISORY 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 ofthe 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 ofyour 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 FAR11.81, the following letter is an example ofwhat operator may write

to the FAA for its petition for exemption: Nota: For

### a word version ofthis letter, please refer to the attachedfile. Place] [Date] US Department ofTransportation Docket Operations WestBuilding Ground Floor, Room W12-140



### Page 4/8

# FALCON SERVICEADVISORY FSA-31-30-006-R03-B

:Pleasecontact [Name/Surname] mailto [Mail Address] 1200 New Jersey Avenue, SE. WASHlNGTON, D.C. 20590 USA
Tel: Fax:

: SUBJECT: [AircraftType & Registration]- Petition for Exemption Applicableto: Flightdata recorders: filtered dataRegulation :Reference: DocketNo FAA-2006-26135- Flight data recorders: filtered data Regulation, Final Rule

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# FALCON SERVICEADVISORY FSA-31-30-006-R03-B

.-..**-~-·-·---·-----------------------·-·-·-·-·-------------·-·---·-----------------------·-·-------------------------·-·-·""1** :DearSir orMadam: :Inaccordance withthe provisions ofTitle 14, Code ofFederal Regulations (14 CFR) §11.61, [name oC ·Operator], for [aircrafttype & registration], we submit a petition for an exemption from a section of 14· :cFRPart 135.156.
. :Youwill find in attachmentto this letterthe necessary informationto support ourpetition.
:Shouldyouhave any question, please do nothesitate to contactus atthe following address: :[Name/surname] ·[Address] :[Phone 

### I fax:] :mailto: [mail address]

PetitionForExemption 

# :In accordance with therequirements of 14 CFR §11.81(a)-(g), we pro vide the following detailed: :information in support ofourpetition: :14 CFR 11.81(a)- Contactinformation: :[Name/surname] :[Address]
· [Phone I fax:] :mailto: [mail address]

: 14 CFR 11.81(b)- Specific section from whichreliefis sought: :For [Aircrafttype & Registration number], we requestrelieffrom the following portion of 14 CFR: §135.156, Arndt 135-120, Flightdatarecorders: filtered data (d) Compliance. Compliance is required as follows: (4) After April21, 2014, no aircraft flight datarecordi ng systemmay filter any: parameterlisted in paragraph (c) ofthi s sectiont hat do es not meett he re quirements of· AppendixDo r F ofthis part, unless the certificatehoi derpo ssesses test and ana lysis: procedures an d the test results thath ave been approved b y the FAA. All records o f tests, : analysis and procedures used to comply with this section mustbe maintained as partoft he· correlationdocum entation required b y § 135 .152 (f)(1)(iii) o r (f)(2)(iii) of this part a s: applicable.



### :

# ~~ .DASSAULT
•

## ~~ FALCONCUSTrJt.fERSERVICE Page 6 

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# FALCON SERVICEADVISORY FSA-31-30-006-R03-B

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### -----------·-·-·----., :14CFR 11.8l(c)- Extent and reason for seekingrelief: :For [Aircrafttype & Registration], we are requesting an ex emption from compliance withthe above: ·listedportion oftheflight datarecorders. Compliance with the regulations requires retrofit with EASy· :IIupgraded avionics Load. Consideringthe large amount ofFalcon aircraft beingretrofitted with EASy: :II upgraded avionics, there is asignificant waiting time before being accepted in a Service Center for: ·retrofit. The a mount of aircraftretrofitted monthly is limited worldwide, by the I arge amount of· :equipmentsto supply. Finally,this retrofitrequires a significant downtime to ad aptto schedule d: :maintenance checks in a way to maintain reasonable operational use ofour aircraft. Afterreview, we: :planto retrofit our aircraft with EASY II upgraded avionics [date].
: 14 CFR 1 1.81 (d) -Public interest Ibenefit: :Beingunable to operate [our airplane(s)] wouldhave a significant economic burden onus. Denial of:
·this petition woul d not be in t he public's interest and would significantly redu ce the operational · :capability ofthe affected aircraft, rei egating these business aircraftto a stat e ofred uced capability: : :indeed, Flight Data Recorder removal of data filtering is covered in EASy II global avionics upgrade: :offering others functionalities such ADS-BOut, FANSIA, ATNBJ orLPV. :Forthe period in which the exemption would be in effect, there would nothave 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: :mandatedby 14CFR §§135.156 Amendment 135-120. This exemption, ifgranted, would allow usto : ·benefitfrom the commercial use of[aircraft type & registration] between April, 2 1, 20 14 and [date·
· :beforebeginning ofthe retrofit]. ·



# . . ·Ifthis petition is denied, then commercial flight operations of[aircrafttype & registration] will haveto. :beinterrupted until EASy II upgraded avionics retrofit is applied. · :Grantingthi s exemption would not affect nor degradetheinherentsafety ofthe airpl ane. This: :exemption deals only with therecording ofpitch control surface position (parameter 15), lateral: :control s urface pos ition (parameter 16), yaw control sur face pos ition (param eter I 7) and : :cockpitflight control inputforces (parameter 88); ittherefore 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 ofReliefSought: [operator], seek exemption from section 14 CFRpart 135.156 to allow· [aircrafttype& Registration] to operate with filtered data from April, 21, 2014 to [date ofthe: beginning ofthe retrofit].

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# FALCON SERVICEADVISORY FSA-31-30-006-R03-B

:14 CFR 11.8l(g)- Additional information:
:Grantingt his p etition wou ld have no effect on the regu Jatory burden o f small bu sinesses, sm all : :organizations, small governmentaljurisdictions.
:Granting ofthis petition would have no effect on the recordkeeping and re porting hurdens for any :

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

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