^-,::::' T 

• - - f . • ^ 

Federal Aviation 

Administration 

Menfiorandum 

Date: May 17,2011 

To: U.S. Department of Transportation, Docket Operations, West Building 

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

Washington, DC 20590 

From: ^ z Joseph A Kain, Manager, AEA-FSDO-17 

Prepared by: Robert W. Fus, Principal Avionics Inspector, AEA-FSDO-17 

Subject: Petition for Exemption, 14 CFR Part 125.226(b)(2), Surdex Geospatial 

Systems Integration, LLC 

The Philadelphia Flight Standards District Office (FSDO) is providing this petition for 

exemption on behalf of Surdex Geospatial Systems Integration, LLC (SGSI), a 14 CFR 

Part 125 operator that is authorized to conduct operations in accordance with a Letter of 

Deviation Authority (LODA A125). SGSI is submitting a petition for exemption to 14 

CFR Part 125.226(b)(2) that currently authorizes a Deviation Authority in accordance 

with 14 CFR Part 125.3(a) under Letter of Authorization paragraph A005. Surdex 

operates three Aerospatiale/ATR-42-320 aircraft with Flight Data Acquisition Units 

(FDAU) that do not record three of the required operational parameters currently listed 

under 14 CFR Part 125.226(a) as identified below: 

• (12) Pitch control input 

• (13) Lateral control input 

• (14) Rudder control input 

The Philadelphia FSDO has reviewed the petition and recommends an exemption based 

on the following facts: 

• The FDAUs presently installed in their aircraft are no longer in production, 

have limited OEM support, and cannot be modified prior to the February 2, 

2012. 

• The aircraft's primary flight control systems are mechanical (there are no 

hydraulic or electronic controls). The flight control surface positions (14 
CFR Part 125.226(a)(15)(16)(17)) are currently, and will continue to be, 

monitored and recorded. 

• The three non-recorded parameters (14 CFR Part 125.226(a)(l2)(13)(14)) 

are flight control inputs for data collection only which would not 

compromise the required level of safety. 

We have attached SCSI's petition letter dated May 10, 2011 that includes the required 

information and content in accordance with 14 CFR Part 11.81. We have also included 

SGSFs Letter of Authorization paragraphs A005, A125, and D085, and ATR Service 

Letter No. ATR42-31-5011 pages 12,13, 34, and 35 that show the parameters that 

SGSI's current FDAU records. If you require additional information, please contact this 

office at the above listed number. 

^m 
^ 

Surdex Geospatial Systems Integration, LLC 

203 Airport Drive, Hangar 6 > ^^^^ K 

Westminster, MD 21157 ^^^^r*^**" l 

tel 800-847-6459 ^^^ ^ SGS I 

fax 410-391-1767 ^ ^ A SUROEX DivisroN 

www.surdexsgsi.com ^ 

Chuck King 

Director of Maintenance 

chuckk@surdexgsi.com 

Federal Aviation Administration 

AEA-FSDO-17 

Attn: Joseph Kain 

2 Internatloiud Plaza Philadelphia, PA 19113 

May 10,2011 

Dear Mr. Kain, 

Surdex Geospatial Systems Integration requests an exemption as defined by 14 CFR 125.3(a), 

from 14 CFR 125.226(b)(2) for three ATR-42-320 aircraft. The aircraft have been operated 

under a full 125 deviation from 1991 until October 1, 2008 and we currently have an approved 

deviation to the regulation as listed on Letter of Authorization paragraph A005. Our operation is 

to provide aerial geological survey services and involves carrying a crew of six persons only. 

There are no passengers carried during any of the operations. 

The change to a Part 125 operation identified a discrepancy in the FDR parameters list. The 

aircraft currently meet the "18" parameter list as defined by 14 CFR 125.226 before a rule 

change in 1997 (reference Federal Register Vol. 62, No. 137, dated July 17, 1997). It was this 

rule change that created a requirement for additional parameters. Operators were given until 

August 18, 2001 (4 years) to meet this requirement. Having a full 125 deviation until recently, 

we were not required to perform any upgrade since the rule change. 

The current FDR records 39 parameters including many engine parameters and airframe system 

discretes that are not mandatory, but are listed in Appendix E of the regulation. The system does 

not record mandatory parameters (a) 12, 13, and 14. These are the flight control "inputs". The 

current system records the flight control surface positions (A) 15, 16 and 17. It should be noted 

that the primary flight control systems are all mechanical. There are no hydraulic or electric 

controls. Other than a break in the control circuit it would be impossible for the surface and the 

control to be in different positions. 

The Flight Data Acquisition Unit (FDAU) currently installed cannot be modified to add the new 

parameters as it is no longer in production and has limited support from the OEM. This FDAU is 

also utilized for other ftjnctions as well as the FDR system. It is part of the engine power 

management system that positions the torque bug on the engine torque indicators. It also gathers 

and stores information for engine condition trend monitoring utilized to detect negative trends in 

engine operation and is part of the approved maintenance program. 
Q Surdex Geospatial Systems Integration, LLC 

203 Airport Drive, Hangar 6 •> ^^^^ ^ 

Westminster, MD 21157 ^^^^r-^-r- l 

tel 800-847-6459 ^^^ ^ SGS I 

fax4I0-39I-1767 ^ ^ AsuRDExDIVISION 

www.surdexsgsi.com ^ 

Chuck King 

Director of Maintenance 

chuckk@surdexg5i.e0m 

The OEM has not developed a service bulletin that addresses the requirement. We anticipate a 

very lengthy schedule and potentially a cost prohibitive process for ATR to engineer and develop 

a modification program for our fleet of three aircraft. 

By not installing the extra parameters for the FDR, airworthiness and safety will not be 

compromised since the primary flight control systems are mechanical and flight control surface 

positions are currently and will continue to be monitored and recorded. The lack of parameters 

(a) 12, 13, and 14 are for data collection only and will not enhance safety or performance 

handling qualities in any way. 

Please consider the following information; SGSI has been operating with only two aircraft out of 

three, typically, and one of the ATR-42 aircraft has been involved in an extensive modification 

and certification project for over five years. Due to 1/3 of our fleet currently down for 

modifications, SGSI could not financially and feasibly begin FDAU modifications until 3^** 

quarter of 2012. In this case if an exemption is denied, SGSI would resort to a request for an 

extension to the LODA expiration date of February 2, 2012, to February 2013 in order to get all 

three aircraft modified to meet the required FDR parameters. In addition, Delta Engineering, a 

company with Organizational Designation Authorization (ODA) authority, is currently working 

on a prototype STC to upgrade the FDAU to incorporate an aircraft performance monitoring 

(APM) ftanction. It will replace the current FDAU, which is out of production, with a new 

production unit. Delta does not forecast approval for this FDAU until late in 2011. By 

extending the LODA expiration to February 2013 at a minimum, this would allow SGSI to 

adequately plan for upgrading the FDAU as well as the FDR and allows additional time for the 

aircraft OEM to develop a service bulletin that could possibly become a better option than 

installing the Delta Engineering STC. 
^ 

Surdex Geospatial Systems Integration, LLC 

203 Airport Drive, Hangar 6 > ^^^^f t 

Westminster, MD 21157 ^^^ ^ #«,^ - r" • 

tel 800-847-6459 ^^^ ^ SGS I 

fax410-39I-J767 ^ ^ A SURDEX DIVISION 

www.surdexsgsi.com ^ 

Chuck King 

Director of Maintenance 

chuckk@surdexgsi.com 

In closing, this request is not intended to disregard the Federal Aviation Regulation, but to 

continue to operate with an equivalent level of safety. As stated above, the FDR system records 

39 parameters, but does not record required flight control inputs. However the system records the 

required flight control surface positions. Since the flight control systems are mechanical and 

there are no hydraulic or electronic controls, it would impossible for the surface and control to be 

in different positions other than a break in the control circuit. We feel this allows for an 

equivalent level of safety. In addition, it is noted that our operation provides aerial survey 

services and only carries crewmembers, never passengers. Please contact me if you have any 

questions. 

Sincerely, 

ingDirector of Maintenance 

Enclosure; 

List of parameters monitored by the FDR 
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U.S. Department 

of Transportation 

Federal Aviation 

Administration 

14 CFR Part 125M Operations 

Letter of Authorization 

Exemptions an d Deviations 

1. The Operator/Company, authorized to conduct operations in accordance with the Letter of Deviation 

Authority (LODA A125), is authorized to conduct operations in accordance with the provisions, conditions, 

and/or limitations set forth in the following exemptions and deviations issued in accordance with Title 14 of 

the Code of Federal Regulations (CFR). The Operator is not authorized and shall not conduct any 

operations under the provisions of any other exemptions and/or deviations issued under Title 14 of the CFR. 

2. Exemptions. 

Table 1. - Exemptions Authorized 

(Enter N/A if no exemptions are authorized) 

Exemption Number 

N/A 

Date of Expiration 

N/A 

Remarics and/or References 

N/A 

3. Deviations. 

Deviation 

Authority 

125.3(a) 

125.3(a) 

125.3(a) 

125.71(a) 

Table 2 - Deviations Auttkorized 

(Enter N/A if no deviations are authorized) 

Deviation From 

125.226(b)(2) 

125.383(a)(8) 

125.5(a) and 

119.23(a) 

125.73 

Description 

Authorizes a deviation for flight 

data recorder parameters of 14 

CFR Part 125.226(a) 12, 13, & 14. 

Authorizes a deviation from the 

load manifest requirement to list 

the names of the passengers and to 

show only the number of 

passengers on board 

Authorizes a deviation from the 

requirement to hold a 14 CFR Part 

125 operating certificate and 

operations specifications. (A125) 

Authorizes a deviation from the 

contents of the General Operations 

Manual because of the limited size 

and scope of the operation. The 

specific sections of Section 125.73 

to be deviated from must be 

identified with justification in this 

table. A full deviation from all the 

manual requirements is not allowed 

to be authorized. 

Conditions and 

Limitations 

Applies to aircraft serial 

numbers: 016, 247 and 

252. 

N/A 

N/A 

125.73(c)-copies of the 

certificate holder's 

operations specifications 

or appropriate extracted 

infoimation, including 

area of operations 

authorized, category and 

class of airplane 

authorized, crew 

complements, and type of 

operations authorizations 

will not be contained in 

the GOM (COM) since 

the operator will not be 

required to hold 14 CFR 

Part 125 operations 

specifications. 

Print Date: 9/25/2008 A005-1 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC 

ID No.: XY7M125M 
e 

U.S. Department .. - *.-i ^ P* ^ ^«.—* . 

of Transportation 14 CFR Part 125M Operations 

Federal Aviation 

Administration 

HQControi: 08/14/06 HQ Revision: 000 

This Autliorization is Issued by the Federal Aviation Administration and approved by direction of 

the Administrator. 

V^p^(^ Jeffrey L. Principal Operations Inspector EA17 

^"Bate Approvalis effective: 10/1/08 Amendment Number: 0 

I hereby accept and receive this Authorization. 

Kin Kingo rhnrl f ^"" ^ 

, Chuck ^" ^ Director of Maintenance Date: 9/25/08 

Print Date: 9/25/2008 A005-2 ID No.; XY7MI25M 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC 
Q 

U.S. Department 

of Transportation 14 CFR Part 125l\/l Operations 

Federal Aviation 

Administration 

Letter of Deviation Authority (LODA) 

1. Letter of Deviation Authority. The operator/company listed at the bottom of this document is hereby 

issued a Letter of Deviation Authority (LODA) from the requirements of 14 CFR Section 125.5 to hold a 

Part 125 operating certificate and operafions specifications, as provided by 14 CFR Section 119.23(a), 

Section 125.3(a) and as authorized in A005, Letter of Authorization, Exemptions and Deviations. 

2. The LODA authorizes the company/operator to transport its personnel, property, and guests. Guests 

may only travel on flights for which the company/operator has a business purpose. 

3. This LODA is issued for the purpose of conducting noncommercial operations. Noncommercial 

operations are operations in which persons or cargo are transported without compensation or hire, or 

operations that do not involve the transportation of persons or cargo. It is also issued when the 

operator/company conducts compensation oi>erations not involving common carriage as long as such 

compensation operations are only in accordance with the following: 

a. Kinds of Operations. 

(1) Ferry or training flights; 

(2) Aerial work operations such as aerial photography or survey, or pipeline patrol, but not 

including fire fighting operations; 

(3) Flights for the demonstration of an airplane to prospective customers when no charge is made 

except for those specified in subparagraph 3.c. below; 

(4) Flights conducted by the operator of an airplane for his personal transportation, or the 

transportation of his guests when no charge, assessment, or fee is made for the transportation; 

(5) Carriage of officials, employees, guests, and property of a company on an airplane operated 

by that company, or the parent or a subsidiary of the company or a subsidiary of the parent, when the 

carriage is within the scope of, and incidental to, the business of the company (other than transportation by 

air) and no charge, assessment or fee is made for the carriage in excess of the cost of owning, operating, and 

maintaining the airplane, except that no charge of any kind may be made for the carriage of a guest of a 

company, when the carriage is not within the scope of, and incidental to, the business of that company; 

(6) The carriage of company officials, employees, and guests of the company on an airplane 

operated under a time sharing, interchange, or joint ownership agreement as defined in subparagraph 3.c. 

below; 

(7) The carriage of property (other than mail) on an airplane operated by a person in the 

furtherance of a business or employment (other than transportation by air) wlien the carriage is within the 

scope of, and incidental to, that business or employment and no charge, assessment, or fee is made for the 

carriage other than those specified in subparagraph 3.c. below; 

(8) The carriage on an airplane of an athletic team, sports group, choral group, or similar group 

having a common purpose or objective when there is no charge, assessment, or fee of any kind made by any 

person for that carriage; and 

Print Date: 9/25/2008 A125-I ID No.: XY7M125M 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC 
e 

U.S. Department ^ , -. -. -, 

of Transportation 14 CFR Part 125M Operations 

Federal Aviation 

Administration 

(9) The carriage of persons on an airplane operated by a person in the furtherance of a business 

other than transportation by air for the purpose of selling them land, goods, or property^ including franchises 

or distributorships, when the carriage is within the scope of, and incidental to, that business and no charge, 

assessment, or fee is made for that carriage. 

b. Definitions. 

(1) A time sharing agreement means an arrangement whereby a person leases his airplane with 

flightcrew to another person, and no charge is made for the flights conducted imder that arrangement other 

than those specified in subparagraph 3.c. below; 

(2) An interchange agreement means an arrangement whereby a person leases his airplane to 

another person in exchange for equal time, when needed, on the other person's airplane, and no charge, 

assessment, or fee is made, except that a charge may be made not to exceed the difference between the cost 

of owning, operating, and maintaining the two airplanes; 

(3) A joint ownership agreement means an arrangement whereby one of the registered joint 

owners of an airplane employs and furnishes the flight crew for that airplane and each of the registered joint 

owners pays a share of the charge specified in the agreement. 

c. Expenses That Mav be Charged. The following may be charged, as expenses of a specific flight, 

for transportation; 

(1) Fuel, oil, lubricants, and other additives. 

(2) Travel expenses of the crew, including food, lodging, and ground transportation. 

(3) Hangar and tie-down costs away from \he airplane's base of operation. 

(4) Insurance obtained for the specific flight. 

(5) Landing fees, airport taxes, and similar assessments. 

(6) Customs, foreign permit, and similar fees directly related to the flight. 

(7) In flight food and beverages. 

(8) Passenger groimd transportation. 

(9) Flight planning and weather contract services. 

(lO)An additional charge equal to 100 percent of the expenses listed above in subparagraph 3c(l) 

of this subparagraph. 

4. Any operations, other than those authorized by this LODA, will result in the termination of this 

deviation authority. This LODA must be sunendered upon the request of the Adminisfrator or an 

authorized representative. A copy of this LODA must be carried in the airplane(s) as required by 14 CFR 

§ 125.7 and presented for inspection upon the request of the Administrator or an authorized representative. 

5. This LODA is issued with the understanding that the company/operator shall: 

Print Date: 9/25/2008 A125-2 ID No.: XY7M125M 

SURDEX GEOSPATL\L SYSTEMS INTEGRATION LLC 
e 

U.S. Department --*«- * 

of Transportation 14 CFR Part 125M Operations 

Federai Aviation 

Administration 

a. Operate its airplane (make/model and registration number) authorized in A003, Airplane 

Au±orization, in compliance with 14 CFR Sections 125.91 and 125.93 notwithstanding specific deviations 

as authorized in A005. Letter of Authorization, Exemptions and Deviations. 

b. Conduct operations in accordance with 14 CFR Sections 125.25, 125.37, 125,39, 125.45, 125.47 

(AGO 1, Issuance and Applicability), 125.49, 125.51, and 125.53, of Subpart B, notwithstanding specific 

deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. A007, Letter of 

Authorization, Designated Persons, must be issued to show compliance or equivalent level of safety to CFR 

section 125.25. 

c. Comply with the Manual Requirements of 14 CFR 125 Subpart C, notwithstanding specific 

deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. 

d. Comply with the Airplane Requirements of 14 CFR Part 125 Subpart D, notwithstanding specific 

deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. 

e. Comply with the Special Airworthiness Requirements of 14 CFR Part 125 Subpart E, 

notwitltetanding specific deviations authorized in A005, Letter of Authorization, Exemptions and 

Deviations. 

f Comply with the Instrument and Equipment Requirements of 14 CFR Part 125 Subpart F, 

notwithstanding specific deviations authorized in A005, Letter of Authorization, Exemptions and 

Deviations. 

g. Comply with the Maintenance Requirements of 14 CFR Part 125 Subpart G, notwithstanding 

specific deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. 

h. Comply with the airmen and flight crewmember requirements of 14 CFR Part 125, Subparts H 

and I, and provide initial and/or recurrent training for flightcrew and flight attendant emergency training as 

authorized in A031, Letter of Authorization, flight Crewmember Requirements, notwithstanding specific 

deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. 

i. Conduct flight operations in accordance with 14 CFR Part 125, Subparts J, K and L, 

notwithstanding specific deviations authorized in A005, Letter of Authorization, Exemptions and 

Deviations. These operafions shall be described in A008, Letter of Authorization, Flight Release Authority. 

j . Comply with the requirements of 14 CFR Part 125 Appendices A, B, C, D, and E, notwithstanding 

specific deviations authorized in A005, Letter of Authorization, Exemptions and Deviations. 

k. Comply with the Special Area of Authorization requirements contained in, but not limited to, 

LOAs B034, B036, B039, B046, B050, and D098, as applicable, if issued. 

1. Comply with the requirements of 14 CFR Section 125.201 by the issuance of a Letter of 

Authorization for an MEL (LOA D095). 

m. Notify the manager of the Flight Standard District Office of any material change in the facts stated 

in your letter of compliance for this LODA and/or any changes in the original authorizations and deviations 

herein. 

6. This LODA will remain in effect unfil superseded, withdrawn, or rescinded. 

Print Date: 9/25/2008 A125-3 ID No.: XY7M125M 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC 
e 

U.S. Department . ^ -,- _ — 

of Transportation 14 CFR Part 125M Operations 

Federal Aviation 

Administration 

HQ Control: I2/21//06 HQ Revision: 010 

This Autborizatioii is Issued by tiie Federal Aviation Administration and approved by direction of 

tlie Adminij 

Principal Operations Inspector EAl 7 

ate Approval is elective: 10/1/08 Amendment Number: 0 

I hereby accept and receive ttiis Authorization. 

—jeing. Chuck ^^- — Director of Maintenance Date: 9/25/08 

Print Date: 9/25/2008 A125-4 ID No.: XY7M125M 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC 
® 

U.S. Department 

of Transportation 

Federal Aviation 

Administration 

14 CFR Part 125M Operations 

Letter of Authorization 

Airplane Listing 

The Operator/Company, authorized to conduct operations in accordance with the Letter of Deviation 

Authority (LODA A125), is authorized to conduct operations using the airplane(s) listed in Table 1 below. 

Registration No. 

N212AZ 

N315CR 

N470JF 

Table 1 - Airplane Listing 

Serial No. 

016 

252 

247 

Airplane M/M/S 

ATR-42-320 

ATR-42-320 

ATR-42-320 

HQControi: 08/14/06 HQ Revision: 000 

This Authorization is Issued by the Federal Aviation Administration and approved by direction of 

the Adjninistrator. 

^^Cv.x^ f 

Blauth, Frederick H. ' Principal Maintenance Inspector EA17 

Date Approval is effective: 10/1/08 Amendment Number: 0 

I hpr^ y accept and receive this Authorization. 

i.irig, Chuck Director of Maintenance Date: 9/25/08 

Print Date: 9/25/2008 D085-1 ID No.: XY7M125M 

SURDEX GEOSPATIAL SYSTEMS INTEGRATION LLC