WIPLINE FLOATS • SKIS • MODIFICATIONS • AIRCRAFT SALES

AVIONICS • INTERIOR • MAINTENANCE • PAINT REFINISHING

1700 Henry Ave – Fleming Field (KSGS), South St. Paul, MN 55075

Ph: 651.451.1205 Fax: 651.457.7858

www.wipaire.com 

### February 12, 2013

U.S. Department of Transportation

Docket Operations

West Building, Ground Floor, Room W12-140

1200 New Jersey Ave., SE.

Washington, DC 20590

On behalf of Wipaire, Inc. I he reby file this petition for exempti on pursuant to Title 14, Code of

Federal Regulations (14 CFR) Section (§)11.61(b).

Our company name and mailing address is as follows:

Wipaire, Inc.

1700 Henry Ave. - Fleming Field

South St. Paul, MN 55075

Telephone: 651-451-1205

Contact: Mr. Richard S. Ad ler, Certification Engineer

E-mail: radler@wipaire.com

Wipaire is petitioning for exemption from §§ 23. 3(a) and 135.113 of 14 CFR with respect to the

limitation on seating configuration, less pilot seats, of nine or less. The exemption would permit

an increase in the maximum number of passenge r seats to ten, while maintaining the TC

approved maximum seats, including crew, of el even, for Wipaire modified Cessna Caravan and

Grand Caravan aircraft. An additional exempti on is requested to allow for supplemental type

approval for operations in the 208B Grand Caravan w ith an eleven to thirteen passenger seating

configuration (maximum fourt een seats, including crew).

As required by §§11.81(d) and 11.81(e), it will be shown that the granting of this petition will

not adversely affect safety, a nd is in the public interest. Additionally, per §11.81(h), Wipaire

requests that the privileges of this exempti on be extended outside of the United States, as

operators of aircraft so equippe d are located world-wide and thes e operators’ countries of origin

often rely on the US a pproval basis as their own.

We seek relief for all Cessna Aircraft Compa ny Model 208 Caravan aircraft modified by the

installation of Wipaire, Inc. STC SA1311GL for Model 8000 or 8750 Straight or Amphibious

Seaplane Floats. Wipaire also requests that su ch exemption be applicable to Cessna Model 208B

Grand Caravan aircraft at such time as th ey are amended to STC SA1311GL. Approval

activities are currently underway for th e 208B under FAA Project Number SA7716CH-A.Page 2 

### Regulatory Background

On July 7, 1970, the FAA issued Notice No. 70- 25 (35 FR 10911) proposing to upgrade the level

of airworthiness of small airplanes intended for operations under Part 135. This action was based

upon a stated trend toward an increase in the num ber and types of airplanes designed to carry

relatively large numbers of passengers. As stated in the notice and final rule:

“ At the time that the 12,500 pounds weight limitation on small airplanes was established in

1953, civil airplanes were well below or well above that weight. In recent years, it has become

apparent that the significance of that weight limitation as a line of demarcation between Parts

23 and 25 has changed. Many small airplanes with weights of, or close to, 12,500 pounds have

been produced by manufacturers for private, executive, and air taxi use. Some of these

airplanes have turbine engines and must carry large fuel loads to achieve a practical range at

high speeds and altitudes.

... More important, however, is the sudden trend toward an increase

in the number and types of small airplanes designed to carry relatively large numbers of

passengers. The FAA considers that continued applicability of Part 23 to small airplanes designed

to carry 10 or more passengers is no longer in the interest of safety. Future generations of these

small airplanes should adhere to the level of safety afforded by the requirements of Part 25

irrespective of whether operations are conducted under Part 135 or Part 91. ” ([Federal

Register: February 11, 1971 (Volume 36, Number 29)]

[Page 2862 ], Docket No. 10405)



### Amendment 23-10 limiting the number of seats, ex cluding pilot seats, to nine or less became

effective March 13, 1971. It is interesting to note that the FAA we nt on to make it clear that the

limitation was specific to the number of seats, not necessarily passengers;

“ In response to several comments, the title of proposed Sec. 23.1583(l) has been changed to

read "Maximum passenger seating configuration" in order to make it clear that the operating

limitation on passenger seats is intended to implement the change to the applicability provisions

of Sec. 23.1. In establishing the seating capacity as a limitation it was not intended to include the

pilot's seat and, in the case of airplanes having dual flight controls, the second pilot's seat.

Furthermore, it was not intended to prevent the present practice of two small children

"doubling up" on a seat or an adult holding an infant.”



### Between the issuance of Notice 70-25 and Fina l Rule for 23-10, the FAA Flight Standards

Service issued Notice 70-611, pr oposing to delete §135.53, “Passenger occupancy of pilot seat”.

This change was specifically intended to allow the operation of small ai rcraft with ten seats

occupied by passengers, with one of those seats being the right side pilot seat:

[14 CFR Part 135]

(Docket No. 10748: Notice 70

‐ 61)

PASSENGER OCCUPANCY PILOT SEAT

Notice of Proposed Rule MakingPage 3 The Federal Aviation Administration is considering amending Part 135 of the Federal Aviation

Regulations to delete § 135.53 which prohibits a passenger from occupying a pilot seat in an

aircraft with a passenger seating configuration of more than eight. Interested persons are

invited to participate in the making of the proposed rule by submitting such written data, views,

or arguments as they may desire. Communications should identify the regulatory docket or

notice number and be submitted in duplicate to: Federal Aviation Administration, Office of the

General Counsel, Attention: Rules Docket. GrC

‐ 24, 800 Independence Avenue SW., Washington,

DC 20590. All communications received on or before January 29, 1971, will be considered by the

Administrator before taking action on the proposed rule. The proposal contained in this notice

may be changed In the light of comments received. All comments submitted will be available,

both before and after the closing date for comments, in the Rules Docket for examination by

interested persons. The prohibition of § 135.53 that no passenger may occupy a pilot seat in an

aircraft with a passenger seating configuration of greater than eight was based primarily upon

the assumption that a passenger so situated could be a distraction, either intended or

accidental, to the pilot. However, upon further consideration of this rule in the light of actual

operating experience by certificate holders it appears that it may be unduly restrictive.

Therefore, it is proposed that § 135.53 be deleted. Deletion of the present rule would permit a

passenger to occupy a pilot seat in airplanes with a seating configuration, excluding any pilot

seat, of less than 10 and thereby allow a maximum of 10 passengers to be carried with but one

pilot.

PROPOSED RULEMAKING

In consideration of the foregoing, it is proposed to amend Part 135 of the Federal Aviation

Regulations by deleting and reserving § 135.53 "Passenger occupancy of pilot seat."

This amendment is proposed under the authority of sections 313(a) and 601 of the Federal

Aviation Act of 1958 (49 U.S.C. 1354 and 1421) and section 6(c) FEDERAL REGISTER, VOL. 35, NO.

252—WEDNESDAY, DECEMBER 30, 1970 19797 of the Department of Transportation Act (49

U.S.C. 1655(c)).

Issued in Washington, D.C., on December 23, 1970.

Edward C. Hodson,

Acting Director,

Flight Standards Service.



### The final rule for amendment of §135.53, released in October, 1971, after the final rule for

Amendment 23-10, contains revised wording maki ng the carriage of 10 passengers, with one

passenger occupying the righ t hand pilot seat, prohibited in ai rcraft type certificated after

October 15, 1971:

PART 135—AIR TAXI OPERATORS

AND COMMERCIAL OPERATORS OF

SMALL AIRCRAFT

Passenger Occupancy of Pilot SeatPage 4 The purpose of this amendment to § 135.53 of the Federal Aviation Regulations is to permit a

passenger to occupy a pilot seat in an aircraft type certificated prior to the effective date of the

amendment with a passenger seating configuration greater than eight. This amendment is

based on a notice of proposed rulemaking (Notice 70

‐ 51) published in the Federal Register on

December 20, 1970 (35 F R, 19796). Twenty

‐ six comments were received in response to the

notice. It is the position of the FAA that with respect to aircraft currently used in Part 135

operations a prohibition against passengers occupying a pilot seat is unduly restrictive inasmuch

as the rationale therefor, namely, that a passenger could intentionally or inadvertently interfere

with the pilot, does not appear to be supported by actual operating experience. The comments

indicated that the position taken by the FAA in this regard is correct. However, based on the

comments received and further FAA study, we believe that the prohibition against passenger

occupancy of a pilot seat in the subject aircraft should be retained with respect to aircraft type

certificated after the effective date of the amendment. In the absence of operating experience

to indicate otherwise, we believe that occupancy of a pilot seat by a passenger may be unsafe

with respect to newer and more sophisticated aircraft. In light of the above, the amendment

adopted herein differs from the proposals in the notice to the extent that the prohibition

against passenger occupancy of a pilot seat in an aircraft with a passenger seating configuration

greater than eight is continued in force with respect to aircraft type certificated after the

effective date of the amendment, but is made inapplicable to those type certificated before that

date. It should be noted that § 135.53 applies only to an 11

‐ seat configuration (including the

pilot seats); aircraft with fewer seats have always been permitted to carry passengers in the

pilot seat and have done so safely. For aircraft with a greater number of seats. § 135.52 requires

them to be operated with two pilots thus making the pilot seat unavailable to passengers.

Interested persons have been afforded an opportunity to participate in the making of this

amendment, and due consideration has been given to all relevant matter presented. Since this

amendment is relaxatory, I find that good cause exists for making it effective on less than 30

days' notice. In consideration of the foregoing, §135.53 of the Federal Aviation Regulations is

amended, effective October 15, 1971, to read as follows:

§ 135.53 Passenger occupancy of pilot seat.

No certificate holder may operate an aircraft type certificated after October 15, 1971, that has a

passenger seating configuration, excluding any pilot seat, for more than eight passengers if any

person other than the pilot in command, a second in command pilot, a company check airman,

or an authorized representative of the Administrator, the National Transportation Safety Board,

or the Post Office Department occupies a pilot seat.

§§ 313(a), 601, Federal Aviation Act of 1958 49 U.S.C. 1354( a), 1421; sec. 6(c), Department of

Transportation Act, 49 U.S.C. 1655(c).

Issued In Washington, DC., on October 5,1971.

J. H.Shaffer, Administrator.Page 5 

### The reason given for the change, “ In the absence of operating experience to indicate otherwise, we

believe that occupancy of a pilot seat by a passenger may be unsafe with respect to newer and more

sophisticated aircraft.” 

### , seems somewhat contrived, as it w ould appear more likely that the

originally proposed operating rule change would now have been in conflict with Amendment 23-

10.

Subsequent to Amendment 23-10, th e FAA attempted to prohibit the use of small aircraft with

ten or more passenger seat s in Part 135 operations:

On August 29, 1977, the FAA issued Notice No. 77

‐ 17, (42 FR 43490) Part 135 Regulatory Review

Program, proposing, in part, to prohibit the operation, after certain dates, of reciprocating

engine or turbopropeller

‐ powered small airplanes not certificated in the transport category and

having a passenger seating configuration of ten or more seats. Before the closing date for

comments on November 28, 1977, the FAA withdrew this part of the proposal in Notice No. 77

‐

17. The more significant reasons given for the withdrawal are (1) Comments on this proposal

showed its effect would virtually destroy the commuter airline industry and deprive the general

public of needed transportation; (2) the proposal had already disastrously effected the industry;

(3) airplane sales had been canceled and operators had serious difficulty with financing; and (4)

the cost of complying with the proposal would exceed 300 million dollars for an industry whose

total profits did not exceed 50 million dollars a year.



### The withdrawal of this proposal showed recogniti on on the part of the FAA of the need, in the

public interest, for means to provide certain ty pes of air transportati on using aircraft not

certificated in the transport category. It also exposed the error of earlier thinking that “ In any

event, the recent rapid increase in the number of small airplanes carrying 10 or more passengers

emphasizes the need for a single level of airworthiness for airplanes carrying 10 or more passengers.”.



### As a result, through SFAR 41, and later with th e addition of the commuter category, the FAA

adopted airworthiness standards for aircraft up to 19 passenger seats under FAR 23 at

Amendment 34. Unfortunately, single engine aircraft were intent ionally excluded from

certification in the commuter category, as stated in the final rule a nd disposition of comments:

Another commenter recommends that Sec. 23.3(d) be changed to add single

‐ engine,

turbopropeller

‐ powered airplanes to the commuter category. The FAA does not agree with the

inclusion of single

‐ engine, turbopropeller

‐ powered airplanes within the commuter category.

While the commenter contends that turbopropeller engines have a record of increased

reliability over reciprocating engines, the prospect of a single

‐ engine failure does not provide

the level of safety expected from the airworthiness standards for commuter category airplanes

which must have the ability for continued safe flight and landing after probable failures,

including the failure of an engine. [Federal Register: January 15, 1987 (Volume 52, Number

10)][Page

‐ 1806]



### As such, a single engine, turbopr opeller aircraft cannot be type certificated in the commuter

category, it cannot be type certificated in the transport category, nor can it be type certificated in

the normal category with allowance for a passenger seating configuration greater than nine.

There is, however, precedent for allowing the operat ion of aircraft type ce rtificated prior to FARPage 6 

### 23 Amendment 10 with more than nine passengers , specifically the DHC-3 Otter, which was

type certificated under CAR 3 fo r up to 16 occupants, including crew. From the final rule

addressing ‘Commuter Operations and General Certification a nd Operations Requirements’:

Alaskan Comments:

A part of the proposal that would have affected several Alaskan certificate holders is the

proposal that single engine airplanes with 10 passenger seats now operating scheduled

flights under part 135 would in effect have to remove a seat in order to continue

operating in

scheduled service under part 135. Single

‐ engine airplanes are ineligible for operation

under part 121. The only 10

‐ seat single

‐ engine airplane model involved is the single

‐

engine deHaviland DHC–3 Otter (not to be confused with the twin

‐ engine de Haviland

DHC–6 Twin Otter mentioned 65840 Federal Register / Vol. 60, No. 244 / Wednesday,

December 20, 1995 / Rules and Regulations elsewhere in this notice). According to

AACA and other commenters, there is no possible safety benefit in taking a seat out of

an airplane, but the cost to certificate holders who want to continue to use these

airplanes in scheduled operations will be significant. NATA comments that no accident

involving the Otter would have been prevented by limiting the seating to 9 passengers.

Furthermore, according to the commenter, the FAA cost on this issue is another

example of gross underestimation; actual costs will be 15 times higher (almost $22,000

per aircraft). The City and Bureau of Juneau opposes the proposal to remove a seat from

the 10

‐ seat airplanes so that they can operate under part 135. This commenter notes

that there will be additional flights, additional noise, and additional congestion on the

water and in the air. It notes that it is incomprehensible how the reduction of one seat

from the Otter will provide an additional level of safety. Wings of Alaska comments that

the most cost efficient floatplane used in southeast Alaska is the single

‐ engine DHC–3

Otter. Because there is no cost

‐ effective replacement aircraft available for float

operations that offers the same capacity as the Otter, replacing them is not an option.

Wings states that it operates the Otter about 6 months a year. Four communities that

do not have runways receive daily service. Wings purchased five 10

‐ seat Otters in ’92–

93 to improve service to a wilderness sports facility, substantially reducing noise by

reducing the number of flights by 50%. Wings estimates that the removal of one seat

would have cost them $85,000 in 1994. Wings asks that the Cessna Caravan and the

Cessna Grand Caravan also be allowed to operate with 10 seats. (emphasis added)

AACA comments that Ketchikan Air Service, Taquan Air Service, and Wings of Alaska

together operate 12 Otters in southeastern Alaska.

............

In response to the single

‐ engine airplane issue, the FAA has decided to allow an

exception to continue. Currently, several part 135 certificate holders conduct scheduled

passenger carrying operations in single

‐ engine airplanes type certificated with two pilot

seats in the ‘‘cockpit’’ and 9 passenger seats in the ‘‘cabin.’’ Some certificate holders are

authorized to conduct scheduled operations in that airplane, the DHC–3 Otter, under

daytime VFR, and carry a tenth passenger in the right

‐ hand pilot seat. In Notice 95–5,

the FAA proposed to limit all scheduled operations of single engine airplanes to the

carriage of nine passengers, under all conditions. (60 FR 16235, 16273) The FAA has

decided to allow the current practice to continue for operators who currently conduct

single

‐ engine operations under daytime VFR with a tenth passenger.Page 7 ...........

5. Part 119

Single

‐ Engine Airplanes. Several commenters state that the NPRM cost estimates for not

allowing a passenger to sit in the co

‐ pilot seat on a single

‐ engine Otter are understated.

One commenter states that the data the FAA used was based on national averages while

all of the airplanes in question are located in Alaska. The commenters also state that the

load factors and operating costs in Alaska are much higher than the rest of the country.

FAA Response: The FAA agrees with the commenters and will not prohibit qualified (as

prescribed by § 135.113) single

‐ engine airplanes, namely single engine Otters, from carrying a

revenue passenger in the copilot seat.

(65832 Federal Register / Vol. 60, No. 244 / Wednesday, December 20, 1995)



### These statements support the FAA’s concurrence th at operations of single engine aircraft with

accommodations for more than nine passenger se ats are economically necessary, in the public

interest, and provide an acceptable level of safety. When §135.113 (previously 135.53 and

135.101) was created, the stated purpose was increased safety, and yet only aircraft certified

to earlier airworthiness rules are allowed to operate with a tenth passenger seat,

thus encouraging the continued operation of high time aircraft in lieu of newer, low

time aircraft certified to modern rules. The current rule effectively already provides a

§135.113 exemption identical to Wipaire’s petition w ith the exception that it only provides this

exemption to older aircraft certified to earlier rules.

Exemption is in the Public Interest

Granting this exemption would benef it the public in a number of ways:

 Increased utility - Because of th e utility nature of the aircra ft, it has served international

relief and humanitarian efforts throughout th e world. With the Wipaire seaplane or

amphibian float installation th e utility of the aircraft is greatly expanded, serving many

communities otherwise inaccessible by air tr ansportation. The Wipaire amphibian

configured aircraft provides additional remote access in support of humanitarian relief,

water rescue, and emergency medical evacuation. Allowance for additional passenger

seats further enhances this utility, encourages operators to upgrade to newer equipment,

and in some cases provides for economic viabili ty of remote routes that would otherwise

not receive service.

 Positive Environmental Impact – As stated by commenters ( including The City and

Bureau of Juneau ) 

### responding to Notice 95-5, additional passengers amounts to an

increase in capacity and associated potential reduction in number of flights, resulting in

less noise and less fuel consumed. Also, as compared to the Turbine DHC-3 Otter, the

Caravan and Grand Caravan provi de approximately 35% greate r cruise speeds on similar

fuel flow, further reducing fuel consumption and noise footprint.

 Increased safety – Operators upgrading from the DHC-3 or adding the Caravan/Grand

Caravan to existing DHC-3 fleets will be operatin g an aircraft that is not only newer andPage 8 

### lower time, but certified to safer, more mode rn regulations. Rule changes specific to

passenger safety include shoulder harnesses, fl ame resistant materials, and larger exit

door requirements, as well as in creased seat crashworthiness.

 Positive Economic Impact – While difficult to substantiate in specific numbers,

comments submitted to the referenced rulemaking actions indicate that existing operators

have specific interest in operating Wipaire modi fied Caravans in addition to, or in lieu of,

DHC-3 aircraft. As Wipaire, a ‘Made in US A’ manufacturer, is the exclusive worldwide

manufacturer of float modifications for the Caravan/Grand Caravan, any sales would

have a positive impact on the United States economy and international sales would have

an additional positive impact on balance of trade. Additiona lly, any associated sales of

Cessna Caravan series aircraft would ha ve a similar positive economic impact.

Appendix A provides a letter from a current 208 Caravan floatplane operator in support of this

petition and the benefits to the public as stated above.

No Adverse Effect on Safety

Safety is not adversely affected because the aircraft is already approved, on the Type Certificate

Data Sheet (TCDS), for the specific seating co nfiguration being requested in this petition.

Additionally, the 10 th 

### passenger seat, described as the ri ght front seat in the FAA Approved

Airplane Flight Manual (AFM), is already approv ed for passenger use. The passenger seating

configuration required by §§23.1524 and 23.1583(j) for the 11-place/10 passenger seat

configuration is already include d in the AFM, as is the loading information required by

§23.1589(b). The only alteration necessary to the a pproved data is relief from the limitation on

occupation of only eight seats aft wh en the right front seat is occ upied by a passenger. Copies of

the TCDS and applicable pages from the AF M, along with a copy of Wipaire STC SA1311GL,

are attached as Appendi x B of this petition.

For the 11 to 14 seat (including crew) additional configuration, applicable to the Cessna 208B

models, an optional seating conf iguration is already available from Cessna and is currently

approved for use in New Zealand, Australia, So uth Africa, Norway, Sweden, Kenya, Israel,

Columbia, and is approved on the EASA issued Caravan TCDS for use by the 31 EASA

Member States for up to 14 seats. As a bove, an approved AFM supplement, providing

compliance with the passenger seating c onfiguration required by §§23.1524 and 23.1583(j), and

the loading information required by §23.1589(b), is available for the requested configuration as

Cessna P/N 108BPHBUS-S16-02. Similar to the a bove, the only alterations necessary to the

approved data are relief from th e limitation on occupation of only ei ght seats aft when the right

front seat is occupied by a pa ssenger, and FAA approval of the S16 AFM supplement for up to

14 seats (including pilot). Add itionally, the 208B meets the comm uter category emergency exit

requirements of 23.807, and Wipaire is willing to provide an evacuation demonstration in

compliance with the commuter cat egory requirements of 23.803(a) . Copies of EASA TCDS

IM.A.226, Issue 5, and Internati onal AFMS Cessna P/N 108BPHBU S-S16-02 for fourteen place

seating, along with applicable pages from the Cessna Grand Caravan optional equipment

selection guide, are attached as Appendix C of this petition.Page 9 

### Summary

The current part 23 rules provide for increased levels of certitude based on weight and passenger

seat limits. Early part 23 rulemaking implies that these limits were expected to be in close

proximity to one another, i.e. an aircraft that could carry 10 or more passengers would likely be

multiengine and in excess of 12,500 lbs. and theref ore subject to transpor t category rules. The

FAA has subsequently acknowledged that techno logy has altered these assumptions, and also

acknowledged that some of these current generation aircraft need not be subject to the full level

of certitude offered by the transpor t category in order to provide acc eptable levels of safety, most

notably with the advent of the commuter category.

The Wipaire modified Cessna Cara van has fallen into a void in the current certification and

operations rules, being single en gine, significantly less than 12,500 lbs., and capable of ten place

(or more) passenger seating configurations. Past rulemaking has discussed safety of turbine

powered aircraft in relation to ‘high and fast’ performance, and this same performance and

complexity model is the basis for current part 23 rulemaking efforts. The Wipaire modified

Cessna Caravan is not a complex, ‘high and fast’ ai rcraft, it is a utility aircraft capable of

providing humanitarian service and service to remote areas that w ould not otherwise be served.

The aircraft is already FAA TC Approved for a seating configuration supporting ten passenger

seats, and TC approved by EASA and other intern ational airworthiness authorities for a seating

configuration supporting eleven (or more) passenger seats.

There is significant benefit to the United States and no detriment to safety by the granting of this

petition.

Federal Register Summary

To comply with FAR 11.81(f) the following information provides a summary for Federal

Register publication.

Petitioner: Wipaire, Inc.

Sections of 14 CFR Aff ected: 14 CFR 23.3(a), 135.113.

Description of Relief Sought: Wipaire is petitioning for exemption from §§ 23.3(a) and

135.113 of 14 CFR with respect to the limitation on seating configur ation, less pilot seats, of

nine or less. The exemption would permit an increase in the maximum number of passenger

seats to ten, while maintaining the TC approved maximum seats, including crew, of eleven, for

Wipaire modified Cessna Caravan and Grand Carava n aircraft. For Grand Caravan aircraft, an

additional approved configuration would permit an increase in the number of passenger seats to

eleven or more (up to thirteen) based on current international approvals. The exemption is in the

public interest because it expands the utility capabilities of the aircraft, which include

international humanitarian relief efforts, water rescue, emergency medical evacuation,

transportation services to remote areas not otherwise accessible, and Government operated public

service missions. Safety is not adversely affected because the aircraft is already approved, on the

Type Certificate Data Sheet (TCDS), for the spec ific ten passenger sea ting configuration beingPage 10 

### requested, and TC approved by EASA and others for a seating configuration supporting eleven

(or more) passenger seats.

Sincerely,

Richard S. Adler

Wipaire, Inc.

Certification Engineer

DER Flight Analyst/Acoustics

Cc: Mr. Greg Micha lik, FAA Chicago ACO

.Page 11 

### Appendix A – Seair Seaplanes Supporting LetterPage 12 

### Appendix B – Cessna Caravan TCDS and AFM InformationPage 13Page 14Page 15Page 16Page 17Page 18Page 19Page 20Page 21Page 22Page 23Page 24Page 25Page 26Page 27Page 28Page 29 

### Appendix C – Cessna Caravan EASA TCDS , International AFMS, and Optional

Equipment InformationPage 30Page 31Page 32Page 33Page 34Page 35Page 36Page 37Page 38Page 39Page 40Page 41Page 42Page 43Page 44Page 45Page 46Page 47Page 48Page 49Page 50Page 51Page 52Page 53Page 54Page 55Page 56Page 57Page 58Page 59Page 60Page 61Page 62Page 63Page 64Page 65Page 66Page 67Page 68Page 69Page 70Page 71Page 72Page 73