JET SOLUTIONS, L.L.C. 

3400 WATERVIEW PARKWAY 

SUITE 102 

RICHARDSON, TEXAS 75080 

214.570.4108 VOICE 

214.570.4122 FAX 

Jet Solutions, LLC 

3400 Waterview PKWY Suite 102 

Richardson, TX 75080 

May 18, 2012 

US Department of Transportation 

1200 New Jersey Ave. SE 

West Building Ground Floor, Room W12-140 

Washington, DC 20590 

Submitted via: www.regulations.gov

Dear Sir or Madam, 

Jet Solutions LLC Air Carrier Certificate Number J7SA150H is requesting exemption 

from the requirements of 14 CFR 43.3(g) and 135.443 (b) (3) to allow it’s properly 

trained pilots (under an approved training program) to accomplish updates of 

navigational software databases of installed flight management systems and 

properly record the update. This applies to all aircraft used in operations under 14 

CFR 135. The primary contacts in this matter are: 

Fred Turner Christopher Page 

Director of Operations Director of Maintenance 

fturner@jetsolutions.com capage@jetsolutions.com

(214) 570-4101 (214) 570-4108 

PETITION FOR EXEMPTION

This petition for exemption (“Petition”) is submitted in accordance with 14 CFR 11 

and seeks permanent relief from certain rules issued by the Federal Aviation 

Administration governing persons authorized to perform preventive maintenance, in 

the form of updating Air Traffic Control (ATC) navigational software databases, on 

an aircraft used in operations under 14 CFR 135. In addition, this petition is based 

upon the grant of exemption detailed in Regulatory Docket No FAA-2010-1018 and 

its own merits. 

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SCOPE

This petition request applies to all Jet Solutions, LLC pilots who have completed 

instruction covered under the approved training program and who are authorized by 

the Director of Operations or his designee to accomplish updates of ATC 

navigational software databases in accordance with accepted procedures, on their 

assigned Jet Solutions, LLC aircraft used in operations under 14 CFR 135. 

SPECIFIC RELIEF REQUESTED

Jet solutions, LLC seeks an exemption to 14 CFR 43.3(g) and 135.443 (b) (3) to 

allow Jet Solutions, LLC pilots to update ATC navigational software databases of its 

aircraft, and properly record its completion for those Jet Solutions, LLC aircraft that 

are used in operations under 14 CFR 135. 

Jet Solutions, LLC also requests to use the exemption outside of the United States. 

Annually, Jet Solutions, LLC operates a considerable amount of flights outside the 

United States. In many cases the aircraft are outside the United States for an 

extended period. The public benefit and equivalent level of safety addressed below 

supporting this exemption request have equal applicability to Jet Solutions, LLC’s 

international flights. 

14 CFR 43.3(g) states, in pertinent part, that “Except for holders of a sport pilot 

certificate, the holder of a pilot certificate issued under part 61 may 

perform preventive maintenance on any aircraft owned or operated by 

that pilot which is not used under Part 121, 129 or 135 of this 

chapter.” 

14 CFR 135.443 (b) (3) states, in pertinent part, that “Be signed by an authorized 

certificated mechanic or repairman, except that a certificated 

repairman may sign the release or entry only for the work for which 

that person is employed and for which that person is certificated.” 

In 14 CFR 43.3(a) reference is made to Appendix A to Part 43 as containing the 

items that are considered to be preventative maintenance and thus subject to 

provisions in 14 CFR 43.3(g). Specifically, paragraph (c) (32) of Appendix A to Part 

43 identifies “updating self-contained ... ATC navigational software databases” as a 

preventive maintenance item. In essence, the current rules prevent a pilot who 

operates an aircraft used under 14 CFR 135 from accomplishing navigational 

database updates and requires those updates to be accomplished by authorized 

maintenance personnel and subsequently have a log book entry signed by a 

authorized certificated mechanic or repairman. 

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PUBLIC BENEFIT

Jet Solutions, LLC is a 14 CFR 135 Air Carrier certified in accordance with 14 CFR 

119. Jet Solutions, LLC operates 78 business jet aircraft serving more than 1000 

customers. 

Most of the airports to which Jet Solutions, LLC’s customers fly have limited or no 

scheduled air service. Each year access to more of these airports, especially during 

periods of low visibility is becoming entirely dependent on use of RNAV procedures. 

The same is also true for a number of major metropolitan airports where RNAV 

SID’s (Standard Instrument Departures) are the only “published” departure 

procedures normally available to any departing aircraft. In addition, RNAV based 

airways (US “Q” and “T” routes) have been installed in key areas of US airspace. 

The number of airports solely served by RNAV procedures is increasing and will 

continue to do so for the foreseeable future. Advanced RNAV capability is also a 

key enabler in the FAA’s Next Generation Air Transportation System (NextGen). 

The FAA has promoted RNAV as serving the general public interest because RNAV 

benefits the safety, access, capacity, predictability, and operational efficiency of the 

National Airspace System (NAS), and reduces environmental impacts of aviation1

. 

Specifically, RNAV procedures provide: 

• Reduced risk of controlled flight into terrain (CFIT) 

• Improved airport and airspace access in all weather conditions, and ability 

to meet environmental and obstacle clearance constraints. 

• Enhanced reliability and reduced delays by defining more precise terminal 

area procedures 

• Reduced workload and improved productivity or air traffic controllers 

Jet Solutions, LLC’s aircraft are appropriately equipped and authorized by the FAA to 

use RNAV routes and procedures. All terminal RNAV procedure authorizations as 

well as some RNAV route authorizations require the ATC navigational database be 

“current”. 

RNAV allows Jet Solutions, LLC to serve airports and routes that better satisfy its 

customer’s needs. However, these needs can sometimes lead to an aircraft being 

away from a location where authorized maintenance personnel would normally be 

available to update the navigational software database when the previous database 

expires. When the navigational database has “expired” operation of the aircraft is 

permitted by the FAA approved Minimum Equipment List (MEL), but only when 

RNAV routes and procedures (i.e. those requiring a current navigational database) 

are not used. 

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The interest of Jet Solutions, LLC customers and the general public are not served if 

an airport cannot be accessed or flight routes cannot be used because the 

navigational database is no longer current. 

• Unnecessary positioning flights to maintenance locations or transporting 

maintenance personnel to an aircraft solely for the purpose of updating an 

expired navigational database are in direct conflict with public benefits of 

using RNAV procedures and routes (as outlined above). 

• Such maintenance positioning flights can needlessly lead to increased 

flight delays, increased airspace congestion, and do increase carbon 

emissions and pollution. 

• Additional cost accruing from use of alternative airports or routes that do 

not require a current navigational database are ultimately borne by Jet 

Solutions, LLC customers; having to use alternative airports or routes in 

this circumstance is a major economic burden to Jet Solutions, LLC 

customers and the public. 

EQUIVALENT LEVEL OF SAFETY

It is Jet Solutions, LLC’s position that by allowing its trained and authorized pilots to 

update the FMS navigational databases, and properly record the update in the 

aircraft records for aircraft which they have received training, provides an 

equivalent level of safety equal to, if not greater than having the FMS updates solely 

completed by an authorized mechanic. 

Jet Solutions, LLC pilots have been trained in the use of each FMS to which aircraft 

they are assigned. They are experts on their FMS in all normal and abnormal 

procedures. Additional points of equivalent level of safety: 

 The FMS database update process is simple and is usually performed 

by inserting a USB memory stick into a FMS USB port and selecting 

update on the FMS screen. 

 In Jet Solutions, LLC aircraft where USB update isn’t available, a floppy 

disk drive is utilized with the same ease and procedures as the USB 

update system. 

 No tools or disassembly is required for FMS systems installed on Jet 

Solutions, LLC aircraft. 

 If during the update an anomaly is encountered, Jet Solutions, LLC 

pilots are trained to follow FAA approved MEL deferral procedures. 

 Each FMS update has detailed instructions which are located in the 

aircraft manual system to update the FMS database. 

Procedures and/or Restrictions for FMS Database Updates

 All Jet Solutions, LLC pilots will be trained on updating their particular 

FMS database. 

 This training will be aircraft and FMS specific and will not carry over to 

other aircraft or FMS systems without specific training. 

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 Only after the training is completed and documented will the pilot be 

authorized to perform the update. 

 Pilots will only be authorized to update the FMS database, not the 

system operating software. The director of maintenance is responsible 

to ensure the software being uploaded does not contain operating 

system software. 

 Once the FMS database is successfully updated, the pilot will complete 

a maintenance log entry. 

o The maintenance log entry will include the name of the person 

performing the upload, the date of the upload, the database 

revision number, if applicable, and the aircraft location at the 

time of the upload. 

 The update will be tracked by Jet Solutions, LLC maintenance control 

located at our company headquarters in Richardson, Texas 

 Written procedures will be in place detailing the process to follow for 

the FMS database updates including performance and evaluation of 

successful completion and properly documenting the update. 

FEDERAL REIGISTER SUMMARY AND PUBLICATION

Jet Solutions, LLC, Air Carrier Certificate number J7SA150H, is requesting 

exemption from the requirements of 14 CFR 43.3 (g) and 135.443 (b) (3)to 

allow its properly trained pilots (under an approved training program) to 

accomplish updates of its aircrafts’ flight management systems (FMS) 

navigational software databases, and properly document its completion. This 

applies to all aircraft used in operations under 14 CFR 135. Jet Solutions, LLC 

also requests to utilize the exemption outside the United States. 

It is the position of Jet Solutions, LLC, that allowing it’s trained and 

authorized pilots to update the FMS navigational databases, and properly 

record its completion in the aircraft type in which they have received the 

training, provides an equivalent level of safety, if not greater than having the 

FMS updates solely completed by an authorized mechanic. This exemption 

will benefit the public as a whole by increasing safety since Jet Solutions, LLC 

will be able to take advantage of the full spectrum of advanced navigation 

features in the national airspace system without needlessly increasing costs, 

which ultimately would have to be borne by the traveling public that utilizes 

our services. 

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