**ST Aerospace Mobile**  **, Inc** 2100 9th Street, Brookley Complex Mobile, Alabama 36615, USA Tel : (251) 438 8888 Fax : (251) 438 8892

Page 1 of 10 FAA Atlanta 0 9 th May 2014 Subject: Petition for Exemption Reference: FAA Project Number ST14446AT-T Dear Mr. Avella , ST Aerospace Mobile (STA Mobile) is the applicant for a mu ltiple airplane Supplem ental Type Certificate for conversion of Boe ing 757-200 passenger airplanes to a 15- Unit Load Device (ULD) position (15- P) freighter configuration under FAA Project Number ST14446AT-T

. STA Mobile expects issuance of STC by October 15, 2014

. The purpose of this letter is to petition for an exemption from the requirements of certain sections of Title 14, Code of Federal Regulations (14 CFR), Part 25, to allow carriage of non -crewmembers, or ‘supernumerary’ personnel, in a compartment within the reconfigured flight deck on the converted airplanes. Supe rnumeraries will be restricted to those persons complying with § 121.583 (a)(1) through (a)(8). STA Mobile requests that the publication and comment procedures be waived in accordance with § 11.29 and § 11 .87 for the following reasons: i. Sim ilar exempti ons have been issued by the FAA for STC ST03562AT (STA Mobile 757- 200SF) , Boeing 757 -200PF & STC ST01529SE (Precision Conversions ’ 757-200PCF) ii. Granting this petition would not set a precedence **DESCRIPTION OF CONVERSION** The main features of the intended conversion from the passenger aircraft configuration include: (a) Installation of a side-opening ma in deck cargo door (MDCD) and its surround structure. The MDCD design is based on that used in the STA Mobile 757-200 Combi Freighter (STC ST03952AT) construction

. (b) I nstallation of a 9g rigid cargo barrier (RCB) at approximately STA 335, identical to that in the Boeing 757-200PF “package freighter (“PF”)” design, providing separation between the flight deck and the ma in deck cargo compartment.Page 2 of 10

(c) Installation of a vendor-developed ma in deck cargo loading sy stem (CLS) to accommodate 15 industry -standard 88 X 125 contoured ULDs, such as the International Air Transport Association (IATA) SAA container, on the ma in deck, using a floor track sy stem based on, and modified from, the incoming passenger aircraft ma in deck seat track installation, similar to the Boeing 757-200PF “package freighter” design. (d) Accommodation for six in the flight deck, with two pilots and two observers being accommodated within the original flight deck layo ut of the incoming passenger configuration aircraft (with observers on bulkhead - mo unted seats), and two supernumerary personnel located just forward of the RCB, identical to the Boeing 757-200PF package freighter configuration. (e) Installation of a new crew entry d oor (CED), identical to that of the Boeing 757-200PF, centered at approximately

STA 311 on the left- hand side of the fuselage forward of the RCB, in place of the forward passenger and service doors existing on the incoming passenger configuration aircraft. (f) Structural modifications related to the installation of the MDCD, CED, RCB, and CLS, including, but not necessarily

lim ited to, the floor and fuselage monocoque (skinframe- stringer) structures. (g) Sy

stems modifications related to the air conditioni ng, communications, electrical power, fire protection, flight controls, hydraulics, indicating and recording, lighting, pitot-static (navigation), oxy gen, as well as water and waste handling, based on the 14- P special freighter design, to enable the ma in d eck cargo compartment to meet the Class E cargo compartment classification requirements, with a one- mi nute smoke detection sy stem. (h) Interior modifications and installations related to side-wall and ceiling liners, new flight deck lavatory and emergency

equi pm ent. (i) Retention of all certificated flight performance as well as weight and balance lim itations (maximum taxi weight, maximum take-off weight, maximum zero fuel weight, maximum landing weight and centre of gravity

range) of the incoming passenger configu ration aircraft. (j) Damage tolerance based structural ma intenance inspections featuring a mi nim umof 20,000 cycles since modification for initial threshold for new structures, and no less than 3,000 cycles between inspections using detail visual inspection as basis, for modified, new and affected structures, to be listed as Airworthiness Lim itation Items in the Maintenance Planning Data document and its supplement.Page 3 of 10 Figure 1

– Overview of Post- Conversion STA Mobile 757 -200 15- P Freighter

Figure 2

– Post-conversion Flight Deck Layout **Legends** 1. Existing Pilot’s Seat 2. New Observer’s Seat 3. New Double Attendant Seat (Added)Page 4 of 10 This petition seeks relief from the requirements of the following sections of 14 CFR , for the 15P conversion :  § 25.785(j ), Amendment 25- 88,Seats, berths, safety belts, and harnesses  § 25.807(g)(1)(i)(1), Amendment 25- 114, Em ergency Exits  § 25.812(e), Amendment 25- 128, Em ergency Lighting  § 25.813( b)(1)(6) , Am endm ent 25- 128, Em ergency Exit Access  § 25.1445(a)(2), Am endm ent 25- 0, Equipm ent Standards for the Oxygen Distributing System  § 25.1447(c)(1), Am endm ent 25- 116, Equipm ent Standards for Oxygen Dispensing Units **The following information is provided to support this petition** : To date, there have been ma ny passenger-to-freighter conversions being carried out by the industry and the reconfigured flight deck layout design has accumulated a considerable satisfactory service history

. In accordance with § 121.583 , all persons that may be carried on the flight deck will have special training, which includes proper methods for egress from the airplane and use of em ergency equipm ent. Lim itations will be imposed on the airplane operator to find that all occupants are physically able to use the escape means provided. Wh en supernumeraries are carried, they will be briefed prior to each flight as to the location and use of the em ergency egress equipm ent and the supplemental oxygen equipm ent. Supernumeraries are also prohibited from being in the cargo area during any flight operation. These lim itations will be included as part of the Airplane Flight Manual Supplement (AFMS) similar to that of STC ST03562AT. The RCB sliding door will be closed and locked prior to taxi and will not be opened again for access to the cargo area until the airplane has parked at its destination. Steps will also be taken to ensure that no one is in the cargo area prior to the locking of the sliding door before taxi. Occupancy

of the flight deck area of the 15P-configured airplane is lim ited to a total of six ( 6 ) persons, which will consist of supernumeraries as defined by § 121.583 (a)(1) through (a)(8), and pers onnel permitted on the flight deck as defined by § 121.547. This lim itation will be included in the AFMS similar to that of STC ST03562AT.Page 5 of 10 T he AFMS will include a requirement for the flight crew to brief supernumeraries on use of the escape provisions pri or to each flight. **§ 25.785(** 

**j )**  , Am endm ent 25-88 , “If the seat backs do not provide a firm handhold, there must be a handgrip or rail along each aisle to enable persons to steady themselves while using the aisles in moderately rough air.” **Justification:** H and holds are not available in the flight deck area due to the space constrain

. The configuration of the flight deck area with the supernumerary seats’ backs attached on the RCB as shown in Figure 2 does not permit using the seat back as the traditional ha ndhold. The lack of handhold is identical to that of STA Mobile 757-200SF supernumerary area configuration. A Petition for Exemption was submitted by STA Mobile in connection with the STA Mobile 757- 200SF with regards to the equivalent § 25.785(d) at Am e ndm ent 25- 32, and this resulted in FAA Grant of Exemption No. 9487. The flight crew area is lim ited to the use of operator assigned supernumeraries or flight crew (not public passenger) as described by § 121.583 (a)(1) through (a)(8) and/or § 121.547 who have higher level of training and knowledge of the flight deck area layout

. There will also be a recommendation to supernumeraries to remain seated with their seat belts fastened. Therefore , an acceptable level of safety is provided. **§ 25.807(g)(1)(i)(1),**  Am endm ent 25- 114, “25.807(g)(1): For a passenger seating configuration of 1 to 9 seats, there must be at least one Type IV or larger overwing exit in each side of the fuselage or, if overwing exits are not provided, at least one exit in each side that meets the minimum dimensions of a Type III exit. 25.807(i)(1): Ditching emergency exits for passengers. Whether or not ditching certification is requested, ditching emergency exits must be provided in accordance with the following requirements, unless the emergency exits required by paragraph (g) of this section already meet them: (1) For airplanes that have a passenger seating configuration of nine or fewer seats, excluding pilot seats, one exit above the waterline in each side of the airplane, meeting at least the dimensions of a Type IV exit.Page 6 of 10 **Justification:** Flight deck is equipped with a left hand crew entry d oor (22" x 56"), with a step- up inside the aircaft of 10 inches

. T his me ets the size requirement of a Type III door for the LH side of the aircraft. The RH side of the aircraft does not have a Type III door. However, the right hand flight deck window will be modified to be openable from the outside to serve as a flight crew emergency exit. B oth exits are above the waterline, and will be equipped with ropes to serve as escape means. Recommended evacuation procedures will be briefed to the supernumeraries prior to each flight. Since the supernumeraries have a higher level of training and knowledge of the airplane configuration than a typical passenger, an acceptable level of safety is provided. The same exemption was granted to the Boeing Package Freighter certified under TCDS A2NM, using Exemption No. 4808, and to Precision Conversions’ PCF ( STC ST01529SE) , using Exemption No. 8258 , using the sa mejustifications

. **§ 25.812(e)**  , Am endm ent 25- 12 8, “Floor proximity emergency escape path marking must provide emergency evacuation guidance for passengers when all sources of illumination more than 4 feet above the cabin aisle floor are totally obscured

. In the dark of the night, the floor proximity emergency escape path marking must enable each passenger to-- (1) After leaving the passenger seat, visually identify the emergency escape path along the cabin aisle floor to the first exits or pair of exits forward and aft of the seat; and (2) Readily identify each exit from the emergency escape path by reference only to markings and visual features not more than 4 feet above the cabin floor. ” **Justification :**  From Figure 2, the configuration of the converted Boeing M odel 757-200 in the flight deck area does not provide floor proximity emergency

lighting s , as required by § 25.8 12(e). The proximity

of the two supernumeraries to the em ergency exits, via the left hand Crew Entry Door and the right hand flight deck window , provides a level of safety that would not be enhanced by the installation of floor proximity e me rgency

l ightings. In addition, supernumeraries have a higher level of training and knowledge of the em ergency exit layout than the typical passenger . Hence, the configuration of the flight deck area provides a n acceptable level of safety for the supernumeraries.Page 7 of 10 The absence of floor proximity e me rgency

exit path ma rking is identical to the configuration of STA Mobile 757-200SF. A Petition for Exemption was su bm itted by STA Mobile for STA Mobile 757-200SF and resulted in FAA Partial Grant of Exemption (No. 9487). In Exemption No. 9487, The FAA had granted the exemption based on the same justifications described above. The same exemption was granted to Precision Conversions’ PCF (STC ST01529SE) , using Exemption No. 8258, based on the same justifications. **§ 25.813(b)**  , Am endm ent 25- 128 , “Adequate space to allow crewmember(s) to assist in the evacuation of passengers must be provided as follows: (1) Each assist space must be a rectangle on the floor, of sufficient size to enable a crewmember, standing erect, to effectively assist evacuees. The assist space must not reduce the unobstructed width of the passageway below that required for the exit. (6) There must be a handle, or handles, at each assist space, located to enable the crewmember to steady himself or herself: (i) While manually activating the assist means (where applicable) and, (ii) While assisting passengers during an evacuation. ” **Justification :**  The co nfiguration of the flight area does not provide an assist space adjacent to each exit , due to the space constrain within the flight deck

. However, since the supernumeraries will have a higher level of training than a typical passenger, they will have no ne ed for crew assistance. In addition, in the relatively

small confines of the flight deck area , the flight crew can easily provide instructions and some physical assistance to the supernumeraries , if needed. The absence of an assist space adjacent to each exit is identical to the configuration of STA Mobile 757-200SF. A Petition for Exemption was submitted by STA Mobile for STA Mobile 757- 200SF and resulted in FAA Partial Grant of Exemption ( No. 9487 )

. In Exemption No. 9487, The FAA had granted the exempti on based on the same justifications described above. The same exemption was granted to the Boeing Package Freighter certified under TCDS A2NM, using Exemption No. 4808, and to Precision Conversions’ PCF (STC ST01529SE) , using Exemption No. 8258.Page 8 of 10 **§ 25.1445**  **(a)(2)** , Am endm ent 25- 0, “When oxygen is supplied to both crew and passengers, the distribution system must be designed for either -- (1) A source of supply for the flight crew on duty and a separate source for the passengers and other crewmembers; or (2) A common source of supply with means to separately reserve the minimum supply required by the flight crew on duty.” **Justification :**  There is no means to separate the means of oxygen to reserve the mi nim um s upply required by the flight crew as the supernumera ries occupy the same flight deck area as the flight crew. Since the two supernumeraries are co- located within the enlarged cockpit , they can communicate directly a nd receive instructions from the flight crew. Moreover, the common oxygen cylinder is able to supply

s ufficient supplemental em ergency oxygen for up to six occupants for an ETOPS duration of up to 120 minutes. The absence of the ability to separate the oxygen supply for the flight crew use is identical to that on the Boeing 757-200 Package Freigh ter certified under TCDS A2NM and the Precision Conversions’ PCF (STC ST01529SE)

. In Exemption No. 8258, The FAA had granted the exemption based on the same justifications described above. **§ 25.1447(c)(1)**  , Am endm ent 25- 116, “There must be an oxygen dispensing unit connected to oxygen supply terminals immediately available to each occupant wherever seated, and at least two oxygen dispensing units connected to oxygen terminals in each lavatory. The total number of dispensing units and outlets in the cabin must exceed the number of seats by at least 10 percent. The extra units must be as uniformly distributed throughout the cabin as practicable. If certification for operation above 30,000 feet is requested, the dispensing units providing the required oxygen flow must be automatically presented to the occupants before the cabin pressure altitude exceeds 15,000 feet. The crew must be provided with a manual means of making the dispensing units immediately available in the event of failure of the automatic system.” **Justification :**  The two supernume raries will have two quick-donning type masks similar to the flight crew that are not automatically

p resented. However, the high level of training of the supernumeraries and the aural warning system will allow the flight c rew to command the supernumeraries to don thePage 9 of 10 masks, providing an adequate level of safety to all occupants. The lavatory will also be outfitted with a portable walka round oxygen bottle equipped with a n oxygen mask. This area will not be utilized for takeoff and landing. The absence of the automatic presentation of the dispensing units for oxygen use is identical to the configuration of STA Mobile 757-200SF. A Petition for Exemption was submitted by STA Mobile for STA Mobile 757-200SF and resulted in FAA Partial Grant of Exemption (No. 9487). In Exemption No. 9487, The FAA had granted the exemption based on the same justifications described above. The same exemption was granted Precision Conversions’ PCF (STC ST01529SE) , using Exemption No. 8258, based on the same justifications. **Evaluation of Public Interest:** The presence of trained personnel on board the airplane when cargo is carried will enhance flight safety, which is in the public interest. Granting this exemption will enhance the utility of the airplane for the operator by e nsuring that needed cargo ma nagem ent personnel will be available at each flight destination. This will reduce shipping costs and transit time , which is in the public interest As Boeing 757-200 passenger airplanes are converted into 15P-configured airplanes, airlines will replace them with new passenger airplanes which me et newer 14 CFR Part 25 Am endm ents. Over tim e, this will have the effect of raising the safety l evel of the passenger airline fleets , which is in the public in terest. **P etition for Exemption**  Based on the information provided, STA Mobile , hereby petitions for exemption from the following sections of 14 CFR Part 25 for Boeing 757-200 passenger airplanes converted to a 15P configuration under FAA STC Project ST14446AT-T to allow the carriage of supernumeraries in the flight deck area :

 § 25.785(j), Amendment 25- 88,Seats, berths, safety belts, and harnesses  § 25.807(g)(1)(i)(1), Amendment 25- 114, Em ergency Exits  § 25.812(e), Amendment 25- 128, Em ergency LightingPage 10 of 10  § 25.813(b)(1)(6), Amendment 25- 128, Em ergency Exit Access  § 25.1445(a)(2), Amendment 25- 0, Equipm ent Standards for the Oxygen Distributing System  § 25.1447(c)(1), Amendment 25- 116, Equipm ent Standards for Oxygen Dispensing Units STA Mobile respectfully req uests favorable FAA consideration of this petition. Sincerely,

**Kumar esan**  **SUBRA MA** **NIA M**  **Engineering Director ST A** **erospace Mobile, Inc. Office:**  (251)436 - 0186 **E -** **mail:** Kum aresan_SUBRAMANIAM@stmae.com