L , I I p.- — 

Cobham Avionics 

Chelton Avionics Inc. 

Dba Wulfsberg Electronics 

6400 Wilkinson Drive 

Prescott, Az. 86334 

T: (928) 708-1550 

F: (928) 541-7627 

PAA.-2oVO-0\3S 

February 05, 2010 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

Dear Sirs: 

Subject: Exemption Petition for 14CFR21.621 

Reference: Similar Recently Submitted Exemption - Tracking Number: 80a6b7c7 

Chelton Avionics, Inc. dba Wulfsberg Electronics Division (hereafter Wulfsberg) in accordance with 

14CFR11.81 hereby requests an exemption to 14CFR21.621 Transferability and Duration, "ATSO 

authorization or letter of TSO design approval issued under this part is not transferable and is effective 

until surrendered, withdrawn, or otherwise terminated by the Administrator". 

Chelton Avionics, Inc. is a Delaware corporation and is doing business as Wulfsberg Electronics Division 

in Prescott, Arizona. Wulfsberg is 100% owned by Cobham pic. Cobham pic also owns Northern Airborne 

Technology Ltd. and 99% of its Intellectual Properties. Both Northern Airborne Technology Ltd. And 

Chelton Avionics, Inc. operate as a subdivision under the Cobham Avionics and Surveillance division of 

Cobham pic (a publicly held company listed in the London Stock Exchange). 

Cobham is restructuring the entities owned by Cobham pic, which includes Wulfsberg Electronics Division 

and Northern Airborne Technology Ltd. under Chelton Avionics, Inc. dba Wulfsberg Electronics Division. 

Wulfsberg is in the process of consolidating operations in Prescott, Arizona to provide consistent methods 

of business processing. Northern Airborne Technology Ltd. will remain an entitiy, however intellectual 

properties and assets belong to Cobham Pic. The previously approved TSOAs will be held by Wulfsberg 

with approvals being managed by the FAA LA ACO and FAA Phoenix MIDO offices. It is the intention of 

Wulfsberg to continue supporting the products produced by Northern Airborne Technology Ltd. with 

continued new production, design support, repair servicing and maintaining responsibility for all records 

and difficulties of previously produced products. 

Wulfsberg desires to transfer TSO approvals from Northern Airborne Technology Ltd. Cobham Pic owned 

site to allow for the continued manufacture of the TSO articles under the existing TSO approvals. The 

TSO articles will be manufactured and tested to the original approved specifications and drawings. FAA 

8150-lB provides the following instructions for an applicant to petition for an exemption for the transfer 

of a TSO authorization. 

8150.18 

11. a. (2) In cases where an applicant desires approval to manufacture an article to an earlier 

version of a TSO (see paragraph 19 of this order), the appropriate means is via a request for an 

exemption, as outlined in 14 CFR Part 11. 

Chelton Avionics, Inc. dba Wulfsberg Electronics Division w.cobham.com 
8150.1B Par 19 infers that the intent is to permit continued production of older TSO articles. 

"In either case, the intent is to permit continued production, in most cases of older TSO articles used on 

existing type certificated aircraft." 

In a similar situation, the FAA exemption approval #9572 indicated "the rule was not intended to prevent 

one company from buying another, or from one company assuming majority ownership of another." 

Wulfsberg is proposing a change of ownership and TSO approval transfers identified below, that is 

believed not to violate the intent of 14CFR21.621. 

Wulfsberg desires to transfer TSO C50c and C139 design and production approvals from Northern 

Airborne Technology Ltd. (a Cobham pic. owned facility in Kelowna, Canada) to Chelton Avionics, Inc. 

dba Wulfsberg Electronics Division in Prescott, Arizona. Each of these TSOA were previously approved 

through the NYACO to TCCA to Northern Airborne Technology Ltd. 

Each of these TSO Articles except for the DACS as noted in the table below, has been approved for reissuance with simultaneous surrender of the TSOA by Northern Airborne Technology Ltd. to TCCA. 

Wulfsberg has been manufacturing these TSO'd articles throughout 2009 under the approved TSOA. It 

was not until a recent December 2009 telecom between the LAACO, SACO, FAA HQ in DC with AIR-120 

and AIR-130 Representatives, Phoenix (vjIDO representatives and both Seattle and Prescott company 

representatives that we were told by HQ that we needed to submit for an exemption. At that time all of 

the products below except for the DACS Models were being manufactured in Prescott under the TSOA 

and being shipped. This has continued to date and working with the LAACO, we hope to resolve this 

through the approval of the prior similar exemption and of this exemption for the products listed below. 

The product list and respective existing TSO follows: 

NAT Kelowna Model Description Applicable TSO(s) 

Current LAACO TSOA Approvals 

250 

251 

240 

802 

806 

807 

3110-XXX 

AA34-3XX 

245 

246 

247 

270 

N301A-XXX 

437 

631 

Passenger Speal<er Amplifier 

Paging Amplifier 

Paging Amplifier 

Switch Panel controller 

Switch Panel controller 

Switch Panel controller 

Audio Controller Panel 

Universal Radio Interface 

Speaker Amplifier 

Isolation Amplifier 

Audio Mixing Amplifier 

Universal Interface Amplifier 

Audio controller 

Audio Control Amplifier 

Aural Warning Generator 

C50c 

C50c 

C50c 

C50c 

G50c 

C50c 

C50c 

C50c 

C50c 

C50c 

C50c 

C50c 

C50c 

C50c 

C50c 

In addition we wish to transfer the TSO Design Approval held by NAT Ltd, Kelowna, CANADA to 

Wulfsberg for the following product: 

NAT Kelowna Model Description Applicable TSO(s] 

Current TSO Design Approvals held by NAT Ltd., Kelowna, CANADA) 

DACS 

(comprising ACP5(x-xxx), 

AMU50-(xxx). RMOI-(xxx) 

Digital Audio 

Communication System 

CI 39 

The Initial (Manufacturing for the DACS Products wil 

FAA Phoenix MIDO approved QA System. 

be in the Prescott, Arizona facility under the current 

Chelton Avionics, Inc. dba Wulfsberg Electronics Division w.cobham.com 
Wulfsberg is a current TSOA holder for the following TSOs: 

1. C41c 

2. C66c 

3. C113 

4. C34e, C35d, C36e, C40c 

5. C146a, ClOb, C9c, C8d, C6d, C2d 

6. C113 

7. C41c, C66b, C74c, C27c, C38c, C34c, C35d, C36c, C40b 

8. C74c 

9. C37d, C38d 

Wulfsberg has held TSO approvals for design and production for 8 years and has shipped over 19,000 

TSO and PI^IA articles operated by the flying public with no safety violations. Many of the articles are 

classified as "essential equipment" for aircraft. Wulfsberg operates under a Phoenix FAA MIDO approved 

quality system that would continue to be used and improved with FAA MIDO approval of changes and 

operation. This will ensure the articles are built and tested to equivalent aircraft safety levels as 

provided by the previous TSO holders. 

Allowing Wulfsberg to proceed under the requested exemption to continue to meet customer needs by 

providing TSO articles under their previously approved TSOs would result in continued flow of these TSO 

articles to customers. The public has interest In the customer base being supported by these TSO 

articles. The customer base consists of government aircraft in the military training area, law 

enforcement agencies, homeland security efforts, active military units, emergency response groups. We 

also have a base of commuter aircraft manufacturers, business aircraft manufacturers, general aviation 

manufacturers, modification centers, and other civil aviation customers that we support. 

If Wulfsberg is required to pursue a new TSO approval for the listed TSO products it would also require 

customers to update design approvals to allow the articles to be installed due to the necessary change in 

part number. The time/cost required to develop, review and process a new TSO approval would interrupt 

the flow of TSO articles to customers. Such a delay would be unacceptable to our customers as they do 

not have the ability to reschedule their time critical missions. Missed or delayed missions would result in 

reduced public safety. 

Wulfsberg believes good cause exists for not publishing a summary of the petition in the Federal 

Register, because this would result in a delay of the FAA acting on this petition and would be detrimental 

to Wulfsberg and Wulfsberg customers. 

Sincerely, 

Jim Buehring 

Certification Manager 

Chelton Avionics, Inc. dba Wulfsberg Electronics Division 

6400 Wilkinson Drive, 

Prescott Arizona, 86301 

T: 928 708-1527 j im. buehring@cobham. com 

F; 928 708-1511 www.cobham. com/avionic s 

Chelton Avionics, Inc. dba Wulfsberg Electronics Division w.cobham.com