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 Ai rplane Directorate

RE: Request for Exemption fro m FARs for Combi Aircraft

To Whom It May Concern,

Air Transport International Inc. (ATI) se eks 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 passeng er carriage (commonly known as “combi” aircraft) where the pilot comp artment 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), w ith 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 compartm ent 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 compartm ent. In addition no personnel entry is allowed into the class C comp artment inflight, by aircraft type certificate limitations.

Related regulations:

§121.313(j)(1)(i) Amendment 121-353, requires that fli ghtdeck 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 requirem ents of this part.”

§121.584 Amendment 121-334, outlines “Requireme nt 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 “b oundary separating the flightcrew compartment from occupied ar eas” must meet certain minimum forcible intrusion requirements.

§25.795(a)(2) Amendment 25-127, requires that the “b oundary separating the flightcrew compartment from any occupied areas” must meet certai n minimum “tensile load” requirements on “accessible handholds”.

The petitioner supports its request with the following information:

Supplemental Type Certificates for modificat ion of Boeing 757-200 aircraft to a combi configuration have a class C main deck car go compartment separating the pilot co mpartment and the passenger compartment. Because the cl ass 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 co mpartment and the p ilot compartment is possible. With regard to this petition, ATI wi shes 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 al low operation of conve rted 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 mu ltiple barriers between the pilot compartment and the passenger compartment at least one of wh ich 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 p ilot compartment.

This is the same method used on passenger aircraft.

§121.587 compliance is either not applicable or will be mainta ined. 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 th e passenger compartment. No rmal traffic is then notpossible. However one of the two configurations available to ATI has the 25.795 barrier at the pilot compartment bul khead as in a passenger aircraft. In that configuration the smoke barrier between the passenger compartment and the cargo comp artment 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 confi guration 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 specifical ly dependent on the §121.313(f) requirement for a coc kpit door will remain in effect.

Request for Waiver of Public Comment ATI requests waiver of the normal public comme nt 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 ai rcraft 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 co mpromises ATI’s ability to pr ovide the level of service deserved by the customer, wast es non-renewable energy resour ces, and increases greenhouse gas emissions.

Petition for Exemption Based on the information prov ided, Air Transport Internati onal, Inc., hereby petitions for exemption from the follo wing portions of 14 CFR Part 1 21 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