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Tavaero Jet Charter Corp. 7930 Airport Blvd. Houston, TX 77061 Phone: 713 - 643 - 5387 Fax: 713 - 640 - 2623 Email: maintenance@tavaero.com Docket Management Facility US Department of Transportation 1200 New Jersey

Avenue, West Building Ground Floor W12 - 140 Washington, DC 20590 Subject: Tavaero Jet Charter Corp. Request for Exemption to Part 135 Appendix F - FDR

Normal Acceleration parameters requirement for Challenger CL - 600 - 2B16 (CL 604 variant) aircraft N456HK S/N 5568. Dear Sir or Madam: Tavaero Jet C harter request a time

–limited exemption to Part 135 Appendix F - Airplane Flight Data Recorder (FDR) - Normal Acceleration parameter (#5) processing and recording requirements, on behalf of certain CL - 6002B16 N456HK S/N 5568.

Executive Summary Upon lear ning of a potential issue with one of the sampling parameters for the CL - 604 aircraft operated under Part 135, Bombardier conducted an internal review which revealed non compliance with a single sampling rate under Part 135, Appendix F. Specifically, it wa s discovered that the normal acceleration sampling rate is recorded b y the FDR at the required rate of 0.125 seconds (8 times per second): however the source data is provided to the FDR at a rate of 0.2 seconds per sampling (5 times per second). As discuss ed below, the data can be correlated to match the sampling requirements without compromising the information recorded and all 87 other parameters are being recorded at the range, accuracy , and sampling rates specified in Appendix F. Upon completing its inv estigation, Bombardier immediatel y began working on a comprehensive solution with its partners, Rockwell Collins, which is further described below.Page **2** of **3**

BA is full y aware that Part 135 applies to aircraft operators, not manufactures and that the FAA does not ty

picall y grant exemptions to manufactures for operational requirements. However much like Airbus, BA delivers aircraft to its US customers with the understanding that they can be under Part 135, if so desired b y the customer. BA is committing to provide a comprehensive solution to close this issue for its US customers, which includes publication of a Service Bulletin to operators to replace the Data Concentrator Unit (DCU) in order to meet the sampling requirements. Request for Exemption Specifics Section and Extent of Relief Requested In accordance with 14 CFR Part 11, Tavaero Jet Charter Corp. request an exemption from the Normal Accelerations parameter in Appendix F of Part 135.152 to permit sampling 5 times(0.2 seconds per sampling interval) per second unit the DCU is updated to provide 8 times per second (0.125 seconds per sampling interval). BA had reviewed its records and determined that CL - 604 N456HK S/N 5568 aircraft is affected by this request. An exemption will have no adverse impacts on s afe operations of aircraft. The FDR, and its recording parameters, are not required for operations of the aircraft. The FDR’s primary purpose is to support investigations in case of incidents. The Normal Acceleration is provided thru the DCU - 4002. The base line Challenger 604 aircraft has 2 such units. Given that the information can be effectivel y correlated with no substantive degradation in information, we respectfully submit that that this compliance issue does not affect safe operation of the aircraft or hinder potential investigation requiring the FDR data. Bombardier and its Supplier, Rockwell Collins is committed to develop an in - service solution involving a re - design of the DCU on or before September 2014. Additionally , BA proposes a subsequent fleet retrofit period to account for parts availability and operator downtime requirements, for a completed retrofit within two years of the granted exemption. The exemption is in the public interest The technical solution to address the current situation is unv iable for this group of aircraft at this time. Granting the Exemption will allow the operator to carry the number of passengers per their approval configuration, as opposed to restricting the number of allowed passengers to 9 or fewer.Page **3** of **3**

Condition and Implementation As was the case with Exemption 10611 and 10611A, Tavaero Jet Charter Corp request that the FAA allow continued operations of the aircraft subject to conditions specified in the exemption, which Tavaero Jet Charter Corp. respectfull y suggest woul d include the following conditions similar to those contained in the above referenced DFDR exemptions for Airbus and its operators.
 Requirements for each Affected US Operator desiring an exemption to submit to the FAA a request to use the exemption for af fected aircraft (i ncluding supporting information such as a list of aircraft and acknowledgment of conditions in the exemption and basis for continued operations) within a specific period of time on not less than 90 day o f the issuance of the exemption.
 Provisions to allow the exemption to transfer to subsequent transfer of the aircraft, with the written approval of the FAA, which shall not be unreasonabl y withheld and shall be subject to compliance with the conditions of the exemption.
 Copies of the exemption to be retained b y the operator, and requirements that a cop y be sent to the NTSB and FAA in connection with any accident or incident involving the FDR: and
 Within 90 days of receipt of the BA Service Bulletin, the operator must provide its principle av ionics inspector a scheduled for completion of the new installation within the time period of the exemption. Publication in the Federal Register Tavaero J et Charter Corp. request that the FAA waive publication of this exemption request in the Federal Regis ter. First, the exemption applies only to a limited number of BA manufactured aircraft and the request is not precedent setting, if granted. Second, any delay in acting on the petition would unnecessarily delay implementation of the solutions for Affected US Operators. Contact information Should the FAA require any additional information, please do not hesitate to contact: Isaac Kirkpatrick Tavaero Jet Charter Corp. 7930 Airport Blvd Houston, TX 77061 maintenance@tavaero.com Thank you for your consideration of Tavaero Jet Charter Corp’s request. Best Regards, Isaac Kirkpatrick Chief Inspector Tavaero jet Charter Corp.