Michael Daigneault

Director, Flight Standards 

CitationShares Management, LLC

5 American Lane

Greenwich, CT 06831

(203) 542-3996

mdaigneault@citationair.com

February 28, 2011

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Ave, S.E.

West Building Ground Floor, Room W12-140

Washington, DC 20590

Submitted via www.regulations.gov

Subject: Petition for Exemption from 14 CFR 43.3 (g)

References: 14 CFR 14 CFRs 43.3 (g) and 43 Appendix A item (c) (32)

Dear Sir or Madam,

SPECIFIC SECTIONS 

CitationShares Management LLC, (hereafter referred to as CitationShares) air carrier certifi cate numbers 

Z5FA890K and Z5FKNE03, requests exemption from the requirements of 14 CFRs 43.3 (g) relating to required 

navigation database updates. 

EXTENT OF RELIEF REQUESTED

This Petition for Exemption seeks permanent relief for all CitationShares operated aircraft (currently 

CE-525B, CE-550B, CE-560XL, CE-680 and CE-750) from CFR Part 43 rules establishing that all navigation 

database updates must be accomplished by the holder of mechanic or repairman certifi cate.

FEDERAL REGISTER

CitationShares requests a waiver of the 120 day fi ling requirement and the publishing of a summary of the 

petition in the Federal Register. Any delay in the granting of this exemption will needlessly encumber FAA resources 

and result in additional delay of relief.

SUMMARY

14 CFR Part 43 Appendix A item (c) (32) classifi es the updating of self-contained, front instrument panelmounted Air Traffi c Control (ATC) navigational software databases as Preventative Maintenance, thereby requiring 

that the function be completed by the holder of a mechanic or repairman certifi cate. This rule is contrary to safe 

operating practices considering the variety of mechanics that will be contracted to perform the update. Contracted 

mechanics may be completely unfamiliar with the process for updating the navigation database and often request 

guidance on the update of such systems fi rst and most often from our pilots, as the pilots are the most experienced in 

the operation of the navigation system.

Current CFR part 65 regulations do not establish any required certifi cation or training standards with regards 

to the updating of navigation databases. Navigation database update processes will vary among different aircraft types 

and at times different avionics packages installed within the same aircraft type. 

Currently, CitationShares is in a somewhat unique position as it does not maintain a cadre of fi eld mechanics. 

All hands-on mechanics performing of the navigation database updates are contracted by CitationShares to outside 

vendor shops who perform the work at the time the maintenance is required on an as needed basis only. Conversely, 
our pilots are direct employees of CitationShares which enables us to establish a training and qualifi cations program, 

provided on an initial and recurrent basis. This aircraft specifi c training has been created with the aid of, and then 

subsequently approved by both our Director of Maintenance and Director of Operations. The curriculum covers 

in detail the navigation database updates for each of the various aircraft that we operate. This allows us to provide 

training to each of our pilots which is specifi c to the aircraft in which they fl y. Further, the training is supplemented 

by on-board aircraft instructions which provide specifi c guidelines including photographs for the establishment of 

standard update procedures and maintenance fl ight log corrective action sign-offs.

PUBLIC BENEFIT

The current requirements established for updating the navigation databases increases the number of occasions 

where the aircraft must be fl own with an expired navigation database. Our crews MEL their aircraft approximately 

200 times each year due to expired navigation databases. This needlessly encumbers our own resources as well as the 

air traffi c control system. A current navigation database would ensure that our pilots could comply with all current 

RNAV SIDs, STARs and IAPS thereby decreasing the burden on the National Airspace System and reducing the 

workload upon Air Traffi c Controllers. By performing the updates as we propose, our aircraft would no longer be 

forced to fl y with expired navigation databases.

RNAV and GPS approaches constitute the most accurate and sometimes the only instrument approach 

procedures served by many of the airports our aircraft frequent. Minimizing the instances that the aircraft is fl own 

with an expired navigation database, will increase our ability to provide a valuable service to our customers and 

increase safety by providing crews the option of fl ying the most accurate navigation mode available for a given 

airport. 

AFFECT ON SAFETY OF FLIGHT

Presently there is a lesser degree of quality control when a mechanic is contracted to update the navigation 

database. Considering the variety of avionics packages that exist in the aircraft we fl y there is an increased likelihood 

that the mechanic will be unfamiliar with the system that they must update. Providing initial and recurrent training of 

contract employees is challenging at best as it would be impossible to predict which mechanics will be contracted to 

perform the navigation database update. 

We have no authority to require that these mechanics undergo any type of training regarding the updating of 

navigation databases and we have no way of knowing what experience the mechanic has with the particular avionics 

system. The reality is that the mechanic may have little to no experience with the various navigation systems installed 

onboard our aircraft. This fact increases the margin of error. 

Modern navigation update procedures are designed to make update failures apparent to trained end users. Our 

formal training program will ensure that the only individuals authorized to perform the updates are trained specifi cally 

for that avionics system thereby decreasing the margin of error further still. Our proposed training program covers 

such elements as successful updates, possible update failures and required corrective action sign-offs. The risk of 

human error during installed updates would be minimized because each pilot will be qualifi ed to perform the updates 

on his or her particular aircraft only. A record of the initial and annual recurrent online training is maintained and all 

crewmembers are immediately notifi ed of changes to the navigation database update process via our online training 

program. We strongly feel that our training and update processes are safer and more comprehensive and therefore in 

the best interest of public safety. 

Our online training program and navigation database training courses have been made available for FAA 

review at www.citationairtraining.com. Please contact our training support at 203-542-3959 for the username, 

password and with any login questions. After logging into the system, select “My Courses” then “Navigation 

Database Update”. User computers must have pop-up blocker function of their web browser turned off. The module 

will begin to play within 5-10 seconds. 

Sincerely,

Michael Daigneault