October 24, 2012 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590 

Attention Transport Airplane Directorate 

RE: Request for Exemption from FARs for Combi Aircraft 

To Whom It May Concern,

Air Transport International Inc. (ATI) seeks exemption from certain Federal Aviation 

Regulations (FAR’s) pursuant to 14 CFR Part 11. Specifically, ATI seeks an exemption 

from §121.313(f) of title 14, Code of Federal Regulations, to allow operation of 757 aircraft 

configured for combined cargo and passenger carriage (commonly known as “combi” 

aircraft) where the pilot compartment and the passenger compartment are not contiguous but 

separated by a class C cargo compartment. 

The petitioner requests relief from the following regulations: 

§121.313(f) Amendment 121-353, requires there to be “a door between the passenger and 

pilot compartments (i.e., flightdeck door), with a locking means to prevent passengers from 

opening it without the pilot's permission”. The exemption from §121.313(f) is necessary 

because the passenger compartment and the pilot compartment are widely separated by a 

class C cargo compartment on 757 combi aircraft. No door is possible directly between the 

pilot compartment and the passenger compartment. In addition no personnel entry is 

allowed into the class C compartment inflight, by aircraft type certificate limitations. 

Related regulations: 

§121.313(j)(1)(i) Amendment 121-353, requires that flightdeck doors meet the rquirements 

of §25.795(a)(1) and §25.795(a)(2). 

§121.582 Amendment 121-353, requires a “Means to discreetly notify a flightcrew.” 
§121.583 Amendment 121-96, concerns “Carriage of persons without compliance with the 

passenger-carrying requirements of this part.” 

§121.584 Amendment 121-334, outlines “Requirement to view the area outside the 

flightdeck door.” 

§121.587 No amendment Number, to ensure “Closing and locking of flightcrew 

compartment door.” 

§25.795(a)(1) Amendment 25-127, requires that the “boundary separating the flightcrew 

compartment from occupied areas” must meet certain minimum forcible intrusion 

requirements.

§25.795(a)(2) Amendment 25-127, requires that the “boundary separating the flightcrew 

compartment from any occupied areas” must meet certain minimum “tensile load” 

requirements on “accessible handholds”. 

The petitioner supports its request with the following information: 

Supplemental Type Certificates for modification of Boeing 757-200 aircraft to a combi 

configuration have a class C main deck cargo compartment separating the pilot compartment 

and the passenger compartment. Because the class C compartment is over 70 feet in length, 

tightly packed with containers or palletized cargo, and not enterable inflight by AFM 

limitation, no door between the passenger compartment and the pilot compartment is 

possible. With regard to this petition, ATI wishes to operate 757-200 aircraft converted to 

combi configuration in support of US Department of Defense worldwide operations. The 

interest of the petitioner is in providing a level of safety and security for the crew, 

passengers and cargo that will allow operation of converted 757 combi aircraft to meet the 

needs of ATI’s operations and clientele. 

To meet the security requirements implicit in §121.313(f), §121.313(j), and §25.795(a) each 

combi aircraft operated by ATI will have multiple barriers between the pilot compartment 

and the passenger compartment at least one of which will be certified to the requirements of 

§25.795(a)(1) and §25.795(a)(2). 

§121.582 compliance will be maintained procedurally using multiple redundant 

communication systems between the passenger compartment and the pilot compartment. 

This is the same method used on passenger aircraft. 

§121.587 compliance is either not applicable or will be maintained. No currently available 

combi has a door that can be opened from the passenger side of the smoke barrier between 

the class C compartment and the passenger compartment. Normal traffic is then not 
possible. However one of the two configurations available to ATI has the 25.795 barrier at 

the pilot compartment bulkhead as in a passenger aircraft. In that configuration the smoke 

barrier between the passenger compartment and the cargo compartment has no door but is 

not secure. On those aircraft the existing 25.795 barrier will be locked inflight. §121.584 

compliance will be provided and maintained. The other configuration has a 25.795 barrier 

between the passenger compartment and the class C cargo compartment. The door in that 

barrier must be closed inflight, and has no provisions for opening from the passenger side, 

so neither§121.587 or§121.584 is applicable. 

All other aircraft and operating requirements except those specifically dependent on the 

§121.313(f) requirement for a cockpit door will remain in effect. 

Request for Waiver of Public Comment 

ATI requests waiver of the normal public comment process since this request is limited in 

scope and intent and because the granting of this petition will not create new precedent.

Evaluation of Public Interest 

The use of modern, fuel efficient 757 combi aircraft in support of the worldwide operations 

of the United States Department of Defense is directly in the public interest. Continued 

operation of older, less reliable, and much less fuel efficient DC8 combi aircraft currently 

supporting those operations compromises ATI’s ability to provide the level of service 

deserved by the customer, wastes non-renewable energy resources, and increases greenhouse 

gas emissions. 

Petition for Exemption 

Based on the information provided, Air Transport International, Inc., hereby petitions for 

exemption from the following portions of 14 CFR Part 121 for 757-200 passenger airplanes 

converted to combi configuration: 

 §121.313(f), Amendment 121-353 

Air Transport International, Inc. respectfully requests favorable FAA consideration of this 

Petition. I can be contacted at 

Regards, 

Timothy V. Erickson 

Director of Quality Control 

Air Transport International, Inc. 

Ph: (501) 615-3500 x1266 

Fax: 501-603-2094 

timothy.erickson@airtransport.cc