U.S. Department 

of Transportation 

Federal Aviation 

Administration 

February 10, 2014 

Northwest Mountain Region 

Office of Regional Counsel 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Tel: (425) 227-1847 

Fax: (425) 227-1007 

kyle.lomazow@faa.gov 

VIA FACSIMILE AND CERTIFIED MAIL- RETURN RECEIPT REQUESTER E c E I v ED 

Attn: Hearing Docket Clerk, AGC-430 

Hearing Docket 

Federal Aviation Administration 

(Wilbur Wright Bldg.) 

800 Independence Avenue S.W. 

Washington, D.C. 20591 

FEB I 8 2014 

FAA- 20I :J- 1°79 HEARING DOCKET 

Re: In the Matter of JETTECH, LLC, FAA Case No. 2012NM030058 

Enclosed is an original and one copy of a request for hearing and Complaint in the abovereferenced proceeding. 

The Federal Aviation Administration (FAA) requests that the hearing in this matter be held in 

Denver, Colorado, and expects that the hearing will last one (I) day. 

For scheduling purposes, FAA attorney, Kyle E. Lomazow will be unavailable in year 2014: July 23 

through August 11. 

Please address all communications for the FAA to the undersigned at: 

Sincerely, 

KEL!mas 

Federal Aviation Administration 

Northwest Mountain Region, ANM-7 

1601 Lind Avenue S.W. 

Renton, Washington 98057 

Telephone: (425) 227-1847 

FAX: (425)227-1007 

Enclosures: Request for Hearing (Appeal) 

Complaint 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

KYLE E. LOMAZOW 

FAA OFFICE OF REGIONAL COUNSEL 

1601 LIND AVE., SW 

RENTON, WASHINGTON 98057 

TELEPHONE: (425)227-1847 

FACSIMILE: (425)227-1007 

RECEIVED 

FEB 1 8 2014 

HEARING DOCKET 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF HEARINGS 

WASHINGTON, D.C. 

In the Matter of: 

FAA Case No. 2012NM030058 

JETTECH, LLC 

Judge Not Assigned 

JUDGE NOT ASSIGNED: 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 Code of Federal Regulations (C.P.R.) Section 

13.208), and states as follows: 

I. 

On January 8, 2014, JETTECH, LLC, was advised through a Final Notice of Proposed 

Civil Penalty that the FAA proposed to assess a civil penalty in the amount of $27,500. On 

42 January 25, 2014, JETTECH, LLC, through its legal counsel, submitted a written request for a 

43 

44 hearing. 

45 

46 

47 II. 

48 

49 

50 

1. JETTECH is now, and at all times mentioned herein was, the holder of Approved 

Repair Station Certificate No. ZYJR157B. 

51 

52 

53 COMPLAINT 

FAA v. JETTECH, LLC. 

FAA Case No. 20 12NM030058 

Page2of8 

KYLE E. LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

II. 

12. 

JETTECH is required to conduct its operations pursuant to its FAA approved Repair 

Station Manual (RSM). 

Paragraph A003 of JETTECH's Operations Specifications (OpSpecs) authorizes 

JETTECH to conduct maintenance and alterations on airframes, radios and 

instruments listed on its Capabilities List. 

JETTECH is required to conduct its operations in accordance with its RSM prepared 

pursuant to 14 C.F.R. Section 145.207(a) and 14 C.F.R. Section l45.211(b). 

Section 1.7 of JETTECH's RSM authorizes JETTECH to perform maintenance, 

preventative maintenance, or alterations on articles listed on its Capabilities List. 

Section 5.4 of JETTECH' s RSM states that JETTECH must use only FAA approved 

technical data when it accomplishes a major repair or alteration. 

OnApril10, 2012, JETTECH performed a major alteration on N150BV, a Cessna 

Model 525 civil aircraft, by installing a Garmin GTN 750 Series, avionics system, and 

a GARMIN GDL satellite receiver. 

On April10, 2012, JETTECH approved N150BV for return to service after 

performing the major alterations in accordance with data that was not approved by the 

Administrator. 

On Aprill3, 2012, Nl50BV was operated on a flight from Broomfield, Colorado to 

Oakland, California. · 

Nl50BV was operated on Aprill3, 2012 after the major alterations mentioned in 

paragraph 7 were completed in accordance with data that was not approved by the 

Administrator. 

When JETTECH performed the major alterations, the Cessna Model 525 was not 

listed on JETTECH's current Capabilities List and therefore JETTECH performed 

maintenance on an article for which it was not rated. 

The above-mentioned Garmin GTN installation did not use FAA approved technical 

data for the following reasons: 

COMPLAINT KYLE E. LOMAZOW, FAA ATTORNEY 

FAA v . .TETTECH, LLC. TEL: (425) 227-1847; FAX: (425) 227-1007 

FAA Case No. 2012NM030058 

Page 3 of8 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

13. 

14. 

15. 

16. 

Installation ofthe Garmin GDL Satellite Receiver: 

a. This installation was performed pursuant to Supplemental Type Certificate (STC) 

SA01487SE-D. 

b. This particular installation deviated from the STC data in that the installation 

included an antenna and it was interfaced with the GTN installation. 

c. As a result, FAA approval was required for the modified data, which JETTECH 

failed to obtain. 

Installation ofthe Garmin GTN 750 Series Avionics System: 

d. This installation was performed referencing STC Number SA02019SE-D as a 

basis for the installation data. 

e. The Cessna Model525 is not on this STC's approved aircraft list. 

f. JETTECH failed to gain approval for this installation and failed to revise the 

aircraft operating limitations by seeking approval for the issuance of an FAA 

approved Airplane Flight Manual (AFM) supplement as required by the STC. 

In performing the maintenance referenced in paragraph 10, JETTECH failed to 

comply with its RSM in that it did not use FAA approved technical data in 

performing a major alteration. 

On April16, 2012, five (5) days after the above-mentioned installation of the GTN 

avionics system had already been completed and N150BV had been approved for 

return to service, JETTECH sent the Denver Flight Standards District Office (FSDO) 

a data package requesting field approval for the Garruin GDL satellite receiver and the 

Garruin GTN 750 Series avionics installation. 

This data package included duplicate copies of three (3) FAA Form 3 37's, which 

identified the alterations described above, and sought approval for the technical data 

used, and a request for approval of the associated AFM. 

Additionally, since JETTECH had already performed the installation without first 

receiving field approval from the FAA, the above-mentioned Form 337's did not 

include a stamped statement indicating FAA field approval as required by 

JETTECH's RSM. 

COMPLAINT KYLE E. LOMAZOW, FAA ATTORNEY 

FAA v. JETTECH, LLC. TEL: (425) 227-1847; FAX: (425) 227-1007 

FAA Case No. 2012NM030058 

Page4of8 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

2. 

III. 

1. By reason of the foregoing facts and circumstances, JETTECH, LLC. violated the 

following sections of the Federal Aviation Regulations (14 C.F.R.): 

a. 

b. 

c. 

d. 

e. 

f. 

Section 43 .5(b ), in that in that it approved for return to service an aircraft which 

had undergone maintenance and alteration and for which it failed to execute, in a 

manner prescribed by the Administrator, an alteration form authorized by or 

furnished by the Administrator. 

Section 43.5(c), in that it approved for return to service an aircraft that had an 

alteration that resulted in a change in the aircraft operating limitations or flight 

data contained in the approved aircraft flight manual, and it failed to ensure that 

those operating limitations or flight data were appropriately revised and set forth 

as prescribed in Section 91.9 of this Chapter 1 of Title 14 C.F .R. 

Section 145.20l(b), in that it maintained or altered an article for which it is not 

rated. 

Section 145.20l(c)(l), in that it approved an article for return to service when the 

maintenance, preventative maintenance, or alteration was not performed in 

accordance with the applicable approved technical data or data acceptable to the 

FAA. 

Section 145.20l(c)(2), in that it approved for return to service an article after a 

major repair or major alteration when the major repair or major alteration was not 

performed in accordance with applicable approved technical data. 

Section 145.207(a), in that it failed to follow the FAA-accepted repair station 

manual it prepared. 

In accordance with Sections 4630l(a) and (d) of Title 49 of the United States Code 

(U.S.C.) (Transportation) [49 U.S.C. Sections 4630l(a) and (d)], JETTECH, LLC. is liable for a 

civil penalty not to exceed $1,100 for each of the violations noted. 

46 3. Under the facts and circumstances of this case, a civil penalty of$27,500 is appropriate. 

47 

48 

49 

50 

51 

52 

53 COMPLAINT 

FAA v. JETTECH. LLC. 

FAA Case No. 2012NM030058 

Page 5 of8 

KYLE E. LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

WHEREFORE, the Agency, by counsel, respectfully requests that the Administrative 

Law Judge enter an order that JETTECH, LLC. be assessed a civil penalty in the amount of 

$27,500. 

Respectfully submitt d this lOth day ofFebruary, 2014. /~--

16 Kyle E. Lo ow 

17 FAA Atto ey 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 COMPLAINT 

FAA v.JETTECH, LLC. 

FAA Case No. 2012NM030058 

Page 6 of8 

KYLE E. LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 ~S~R 

2 

3 In accordance with Section 13.209 of the Federal Aviation Regulations, JETTECH, LLC, must 

4 answer this Complaint not later than thirty (30) days from the time it is served on it. Failure to 

5 file an Answer within thirty (30) days without good cause shall be deemed an admission of the 

6 truth of each allegation contained in the Complaint [14.C.F.R. Section 13.209(±)]. 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 COMPLAINT 

FAA v. !ETTECH, LLC. 

FAA Case No. 2012NM030058 

Page 7 of8 

KYLE E. LOMAZOW, FAA ATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint has been served via Facsimile and Certified Mail -

Return Receipt Requested this date, to the following: 

Federal Aviation Administration (Original and one copy) 

Attn: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building800 Independence Avenue SW 

Washington, D.C. 20591 

Fax: (202) 493-5142 

Michael L. Poindexter, Esq. 

Law Offices of Michael L. Poindexter 

2132 Montane Drive E. 

Golden, CO 80401 

TEL: (303) 526-1980 

FAX: (303) 526-1981 

2 1 Dated this lOth day ofFebruary, 2014. 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 COMPLAINT 

FAA v . .TETTECH, LLC. 

FAA Case No. 2012NM030058 

Page 8 of8 

M~~~- Office ofRegional Counsel (ANM-7) 

Federal Aviation Administration 

1601 Lind Ave. SW 

Renton, WA 98057 

(425) 227-2925 

KYLE E. LOMAZOW, F AAATTORNEY 

TEL: (425) 227-1847; FAX: (425) 227-1007 
U.S. Department 

of Transporta~on 

Federal Aviation 

Administration 

January 8, 2014 

Northwest Mountain Region 

Office of Regional Counsel 

Colorado, Idaho, Montana, 

Oregon, Utah, Washington, 

Wyoming 

1601 Lind Avenue SW. 

Renton, Washington 98057 

Tel: (425) 227-1847 

Fax: (425) 227-1007 

kyle.lomazow@faa.gov 

FAA Case No. 2012NM030058 

VIA FIRST-CLASS AND CERTIFIED MAIL- RETURN RECEIPT REQUESTED 

To: President 

JETTECH, LLC 

1 0122 Allport Court 

Broomfield, CO 80021 

FINAL NOTICE OF PROPOSED CIVIL PENALTY 

On August 19, 2013, JETTECH, LLC (JETTECH) was advised through a Notice of Proposed 

Civil Penalty (Notice) that the Federal Aviation Administration (FAA) proposed to assess a 

civil penalty in the amount of$27,500. 

After considering all the information presently a part of this proceeding, including the 

information presented at the informal conference of December 11, 2013, it appears that: 

1. JETTECH is now, and at all times mentioned herein was, the holder of Approved 

Repair Station Certificate No. ZYJR157B. 

2. JETTECH is required to conduct its operations pursuant to its FAA approved 

Repair Station Manual (RSM). 

3. ParagraphA003 of JETTECH's Operations Specifications (OpSpecs) authorizes 

JETTECH to conduct maintenance and alterations on airframes, radios and 

instruments listed on its Capabilities List 

4. JETTECH is required to conduct its operations in accordance with its RSM 

prepared pursuantto 14 Code of Federal Regulations (C.P.R.) Section 145 .207(a) 

and 14 C.P.R. Section 145.2ll(b). 

5. Section 1.7 of JETTECH's RSM authorizes JETTECH to perform maintenance, 

preventative maintenance, or alterations on articles listed on its Capabilities List 

6. Section 5.4 of JETTECH's RSM states that JETTECH must use only FAA 

approved technical data when it accomplishes a major repair or alteration. 

7. On AprillO, 2012, JETTECH performed a major alteration on Nl50BV, a Cessna 

Model525 civil aircraft, by installing a Garmin GTN 750 Series, avionics system, 

and a GARMlN GDL satellite receiver. 

COMPLAINT 
JETTECH, LLC -FAA Case No 2012NM030058 

January 8, 2014 

Page 2 of5 

8. On AprillO, 2012, JETTECH approved Nl50BV for return to service after 

performing the major alterations in accordance with data that was not approved by 

the Administrator. 

9. On April13, 2012, Nl50BV was operated on a flight from Broomfield, Colorado 

to Oakland California. 

10. N150BV was operated on April13, 2012 after the major alterations mentioned in 

paragraph 7 were completed in accordance with data that was not approved by the 

Administrator. 

11. When JETTECH performed the major alterations, the Cessna Model 525 was not 

listed on JETTECH' s current Capabilities List and therefore JETTECH performed 

maintenance on an article for which it was not rated. 

12. The above-mentioned Garmin GTN installation did not use FAA approved 

technical data for the following reasons: 

Installation of the Garmin GDL Satellite Receiver: 

a. Tills installation was performed pursuant to Supplemental Type Certificate 

(STC) SA01487SE-D. 

b. This particular installation deviated from the STC data in that the 

installation included an antenna and it was interfaced with the GTN 

installation. 

c. As a result, FAA approval was reqnired for the modified data, which 

JETTECH failed to obtain. 

Installation ofthe Garmin GTN 750 Series Avionics System: 

d. Tills installation was performed referencing STC Number SA02019SE-D 

as a basis for the installation data. 

e. The Cessna Model 525 is not on this STC's approved aircraft list. 

f. JETTECH failed to gain approval for this installation and failed to revise 

the aircraft operating limitations by seeking approval for the issuance of 

an FAA approved Airplane Flight Manual (AFM) supplement as required 

by the STC. 

13. In performing the maintenance referenced in paragraph 10, JETTECH failed to 

comply with its RSM in that it did not use FAA approved technical data in 

performing a major alteration. 

COMPLAINT 
JETTECH, LLC- FAA Case No 2012NM030058 

January 8, 2014 

Page 3 of5 

14. On Aprill6, 2012, five (5) days after the above-mentioned installation of the 

GTN avionics system had already been completed and Nl50BV had been 

approved for return to service, JETTECH sent the Denver Flight Standards 

District Office (FSDO) a data package requesting field approval for the Garmin 

GDL satellite receiver and the Garmin GTN 750 Series avionics installation. 

15. This data package included duplicate copies of three (3) FAA Form 337's, which 

identified the alterations described above, and sought approval for the technical 

data used, and a request for approval of the associated AFM. 

16. Additionally, since JETTECH had already performed the installation without first 

receiving field approval from the FAA, the above-mentioned Form 337's did not 

include a stamped statement indicating FAA field approval as required by 

JETTECH's RSM. 

By reason of the foregoing circumstances, it appears that JETTECH violated the following 

sections of the Federal Aviation Regulations (14 C.F.R.). 

a. Section 43.5(b ), in that in that it approved for return to service an aircraft 

which had undergone maintenance and alteration and for which it failed to 

execute, in a manner prescribed by the Administrator, an alteration form 

authorized by or furnished by the Administrator. 

b. Section 43.5(c), in that it approved for return to service an aircraft that had an 

alteration that resulted in a change in the aircraft operating limitations or flight 

data contained in the approved aircraft flight manual, and it failed to ensure 

that those operating limitations or flight data were appropriately revised and 

··set forth as prescribedinSection-91~9-ofthis Chapter-1 of-Title-14-C.F:R.- -

c. Section 145.201(b ), in that it maintained or altered an article for which it is 

not rated. 

d. Section 145.201(c)(l), in that it approved an article for return to service when 

the maintenance, preventative maintenance, or alteration was not performed in 

accordance with the applicable approved technical data or data acceptable to 

the FAA. 

e. Section 145.201(c)(2), in that it approved for return to service an article after a 

major repair or major alteration when the major repair or major alteration was 

not performed in accordance with applicable approved technical data. 

f. Section 145.207(a), in that it failed to follow the FAA-accepted repair station 

manual it prepared. 

COMPLAINT 
JETTECH, LLC- FAA Case No 2012NM030058 

January 8, 2014 

Page 4 of5 

Under 49 United States Code (U.S.C.) Section 46301(a) and (d), with modifications set 

forth at 14 C.F.R. Part 13, Subpart H, JETTECH is subject to a civil penalty not to exceed 

$11,000 for each of the violations noted. We propose to assess a civil penalty in the amount 

of $27,500. 

Unless JETTECH mails or personally delivers, in writing, its request for a hearing in this 

matter, on or before fifteen (15) days after JETTECH receives this Final Notice of Proposed 

Civil Penalty (Final Notice), we will issue an Order Assessing Civil Penalty and JETTECH 

will have no further right to a hearing. If JETTECH does not submit a written request for a 

hearing, JETTECH must pay the proposed civil penalty. 

A request for a hearing must be sent to: 

Federal Aviation Administration 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building 

800 Independence Avenue SW 

Washington, DC 20591 

A copy must also be sent to the undersigned FAA attomey at the following address: 

Federal Aviation Administration 

Office of Regional Counsel- ANM-7 

Northwest Mountain Region 

1601 Lind Avenue, SW 

Renton, WA 98057 

JETTECH' s request must be dated and signed, in accordance with Section 13.16 of the Federal 

Aviation Regulations, sent to JETTECH with the Final Notice (14 C.F.R. Section 13.16). 

JETTECH may pay the proposed penalty by submitting a certified check or money order 

payable to the "Federal Aviation Administration," to the Office of Regional Counsel, 

Northwest Mountain Region, 160 I Lind A venue SW., Renton, Washington 98057. 

In the alternative, JETTECH may pay its civil penalty with a credit card, debit card, or bank 

account debit using the Internet. To pay electronically, visit the web site at http://www.pay.gov. 

Under the Search Public Forms option type in "FNM-FINEl." Click on "FAA Civil Penalty 

Payments," click on ''Northwest Mountain Region," which will bring JETTECH to the "FAA 

Civil Penalty Payments-Northwest Mountain Region" page. JETTECH must complete the 

requested information and click "submit" to pay by credit card or debit card. To use the bank 

account debit JETTECH will need its bank routing number, account number, and check number. 

COMPLAINT 
JETTECH, LLC-FAA Case No 2012NM030058 

January 8, 2014 

PageS of5 

If JETTECH has any questions regarding this Final Notice, please contact FAA Attorney, 

Kyle E. Lomazow attelephone number (425) 227-1847. 

DWIGHT S. WILLIAMS 

-omiCoo~ /; _____ / 

y-- BY: ?.y 

Ieyle~~azow 

FA~omey 

t/ 

KEL!mas 

C0~1PLAINT 
January 25, 2014 

Federal Aviation Administration 

Attention: Hearing Docket Clerk, AGC-430 

Wilbur Wright Building 

800 Independence Avenue SW 

Washington DC 20591 

Federal Aviation Administration 

Office of Regional Counsel-ANM-7 

Northwest Mountain Region 

1601 Lind Avenue, SW 

Renton W A 98057 

Re: Request for Hearing 

FAA Case No. 2012NM030058 

Dear Sir/Madam: 

Regional Counsel 

JAN 2 9 'LG\4 

~l-1 

On behalf of JETTECH, LLC I hereby request a hearing on all charges stated in the Final Notice of Proposed 

Civil Penalty issued on January 8, 2014. Please address all future correspondence in this matter to JETTECH's 

attorney at the following address: 

Michael L. Poindexter, Esq. 

Law Offices of Michael L. Poindexter 

2132 Montane Dr. E. 

Golden CO 80401 

__....-",._....-._ 

Vezy trur{yours, .. ) / .. 

. ( 

i( 2.:--~ 

John R. "Rob" Irwin 

President 

1) JETTECH, LLC 

11757 W KEN CARYL AVE F-503 LITTLETON, CO 80127 303-697-4262 (OFFICE) 303-697-8080 (FAX) 

http://www.j ettechllc.net