1

December	20,	2013

Docket	Management	Facility

US	Department	of	Transportation

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

Washington,	DC	20590

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.	(JAFS),	for	Dassault	Falcon	900LX	(N261CH)	and	900EXEASy	

(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:

Jet	Aviation	Flight	Services,	Inc.,	Air	Carrier	Certificate	Number	KKVA618M	

112	Charles	A.	Lindbergh	Drive	Teterboro	Airport	New	Jersey	07608

317-839-0192

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:

Jet	Aviation	Flight	Services,	Inc.,	Air	Carrier	Certificate	Number	KKVA618M	

112	Charles	A.	Lindbergh	Drive	Teterboro	Airport	New	Jersey	07608

317-839-0192

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

For	N261CH	&	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,
2

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	N261CH	&	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	(Dassault	SB	F900EX-400-R3	or	SB	900EX-414-R4.	

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.

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

Jet	Aviation	Flight	Services,	Inc.	(JAFS)	is	a	Part	135	Air	Carrier	certificated	in	accordance	with	14	

CFR	119.	Jet	Aviation	Flight	Services	operates	nearly	35	business	jet	aircraft	and	expects	to	increase	

that	number	to	over	40	in	2014.	This	qualifies	Jet	Aviation	Flight	Services,	Inc.	as	a	large	Air	Carrier.

Being	unable	to	operate	these	aircraft	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	N261CH	&	N918JM	between	April,	21,	2014	and	July	2014	

(N918JM)	and	September	2014	(N261CH).

If	this	petition	is	denied,	then	commercial	flight	operations	of	N261CH &	N918JM	will	have	to

be	interrupted	until	EASy	II	upgraded	avionics	retrofit	is	applied.
3

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,	Inc.	

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

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

part	135.156	to	allow	Dassault	Falcon	900LX	(N261CH)	and	900EXEASy	(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,	small	governmental	jurisdictions.

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

involved	parties.

Respectfully	submitted,

Darrell	Hunter

Director	of	Quality	Assurance

Jet	Aviation	Flight	Services,	Inc.