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 certi fi 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) classi fies the updating of self-contained, front instrument panelmounted Air Traf fi c Control (ATC) navigational software databases as Preventative Maintenance, thereby requiring that the function be completed by the holder of a mechanic or repairman certi fi 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 certi fi 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 quali fi cations program, provided on an initial and recurrent basis. This aircraft speci fi 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 speci fi c to the aircraft in which they fl y. Further, the training is supplemented by on-board aircraft instructions which provide speci fi 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 traf fi 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 Traf fi 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 quali fi 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 noti fi 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