(B 

communications 

Integrated Systems 

10001 Jack Finney Blvd., Greenville, TX 75402 

P.O. Box 6056, Greenville, TX 75403-6056 

26 May 2010 

In Reply Refer To: 

8-81710C/10L-038 

U. S. Department of Transportation 

Docket Operations, West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

SUBJECT . Petition for Exemption Under 14 CFR 11.61(b), From Certain Parts of 14 CFR 26, Continued 

Airworthiness and Safety Improvements for Transport Category Airplanes 

To Whomever It May Concern: 

L-3 Cormnunications Integrated Systems, Mission Integration Division, Greenville, Texas submits this Petition 

for Exemption under 14 CFR 11.61(b), from certain parts of 14 CFR 26, Continued Airworthiness and Safety 

Improvements for Transport Category Airplanes. 

AIRPLANE MODEL: 

Exemption is requested for the Boeing 737-700, Type Certificate Data Sheet A16WE, when STC ST9214SC-D 

is installed. This STC installs a Self Protection System including a Large Aircraft Infi:ared Counter Measure 

(LAIRCM) System, a passive RADAR Warning Receiver (RWR) System and a Countermeasure Dispenser 

System (CMDS) for three foreign military-registered aircraft. 

REGULATORY RELIEF REQUESTED: Pelitioner requests exemption for the following regulations. 

14 CFR 26.11 - Electrical wiring interconnection systems (EWIS) maintenance program. (Final Rule Docket 

Number FAA-2004-18379) 

14 CFR 26.47 - Holders of and applicants for a supplemental type certificate - AlteraUons and repairs to 

alterations. (Final Rule Docket Number FAA-2005-21693) 

GENERAL BACKGROUND: 

STC ST9214SC-D has been installed on three Boeing 737-700 aircraft, serial numbers 36106, 36107, and 

36108. These aircraft are registered with the India military, and are used as Head of State aircraft. This 

foreign Head of State configuration includes a self-protection system, not found on air carriers. As a result of 

the Aging Aircraft Safety Final Rule (AASFR) the FAA issued regulations imder 14 CFR 26 Subparts B and E. 

The final rule is based on several fundamental principles, two of which are as follows. 

The first principle is that the regulations found in 14 CFR 26 are intended to apply to airplanes operated under 

14 CFR 121 or 14 CFR 129. The second principle is that a Design Approval older (DAH) may require 

compensation from an operator of these airplanes for work performed to provide the documentation required 

by the regulations. 
REQUESTED EXEMPTION: 

L-3 Communications requests that the aircraft identified above with STC ST9214SC-D installed be exempt 

from 14 CFR 26.11 and 26.47. Justification of this request is based on the fact that with the self-protection 

system installed by STC ST9214SC-D, these aircraft are not configured for operation under 14 CFR 121 or 14 

CFR 129. Also, the govermnent of India has indicated to L-3 Communications that these aircraft are registered 

with the military of India, and likely will never be operated under 14 CFR 121 or 14 CFR 129. Additionally, if 

the data required under 14 CFR 26 were to be generated, that data would not be used by any aircraft operators. 

With that rationale, the petitioner requests the following be applied in lieu of the existing rule. This limitation 

shall be added to STC ST9214SC-D for flie aiicraft identified in the GENERAL BACKGROUND section 

above. 

When installed, the airplanes with this STC are hmited to operations excluding those of an Air Carrier. 

Specifically, no operations under 14 CFR 121, 14 CFR 129 or any foreign Air Carrier are permitted. 

JUSTIFICATION AND SAFETY CONSIDERATIONS: This Petition for Exemption is consistent witii tiie 

stated safety goals of Final Rule Docket Numbers FAA-2004-18379 and FAA-2005-21693. Specifically, the 

intent of the Final Rules was to invoke the regulations of 14 CFR 26 on Design Approval Holders for airplanes 

used by Part 121 and 129 operators. The FAA criteria for granting exemptions to 14 CFR 26.11 and 26.47 are 

based on the operational usage of the airplane. Therefore, granting this exemption on the basis of airplane 

serial number meets the criteria without adveniely affecting Public Safety. Similar criteria were used when the 

FAA granted Exemptions 9838 and 9935. 

PUBLIC INTEREST: This Petition for Exemption is consistent witii the stated public interest goals of Final 

Rule Docket Numbers FAA-2004-18379 and FAA-2005-21693. In addition, this Exemption would eliminate 

unnecessary costs by avoiding the creation of data that will never be used by the operator. 

Sincerely, 

Dr. Michael E. Hoppey L/ 

FAA ODA Administrator 

ODA-750173-SW 

/jh