ST Aerospace Mobile, Inc 

2100 9th Street, Brookley Complex 

Mobile, Alabama 36615, USA 

Tel : (251) 438 8888 

Fax : (251) 438 8892 

Singapore Technologies 

Engineering 

Page 1 of 3

FAA Atlanta 22nd January, 2012 

Subject: Petition for Revision to Exemption No. 10418 

Reference: FAA Project Number ST13005AT-T 

Dear Mr. Avella, 

ST Aerospace Mobile, Inc (STA Mobile) respectfully submits this letter to petition for a revision to 

Exemption Number 10418 (Attached to this letter as Appendix A). The exemption allowed the STA Mobile 

757-200 Combi configuration aircraft (Combi Aircraft) to be used for NATO operations and for private use 

operations and did not allow the use of the aircraft for hire or for common carriage. STA Mobile is 

requesting for a revision to the exemption so that it can be restricted to apply to only one airplane 

MSN25622, and at the same time expanded so that this one aircraft can be used for hire or common 

carriage, for the following reasons set out in the letter below. 

BACKGROUND: 

STA Mobile is the applicant for a multiple aircraft Supplemental Type Certificate (STC) for 

conversion of Boeing 757-200 passenger aircraft into an “8 pallet/80-passenger” Combi configuration 

under FAA Project Number ST13005AT-T. During the FAA evaluation of this project it was determined 

that the Main Deck Cargo Door (MDCD) design was non-compliant with some of the latest requirements 

applicable to doors (14 CFR 25.783 Amendment 25-114) but that it meets earlier requirements of 14 CFR 

25.783 Amendment 25-88. 

Under Exemption Number 10418 granted by the FAA on 23 December 2011, STA Mobile was 

granted a time-limited exemption from 14 CFR 25.783(c) and 25.783(d)(3)(i) with certain limitations to 

allow its current MDCD to be used on the Combi Aircraft. It is pertinent to note that the current MDCD, 

part number 65-25326-90710, was earlier approved under STC ST03562AT for use on the STA Mobile 

757-200SF conversion. 
Singapore Technologies 

Engineering 

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GROUNDS FOR REVISION TO EXEMPTION NUMBER 10418: 

i. The operator intends to use the 757 Combi Aircraft MSN25622 in the following roles: 

a. To be deployed on their logistical contract to transport freight and passengers for NATO 

operations (both cargo and passenger only), 

b. To move freight (cargo only) on the TNT express service air network, 

c. Charter flights (passenger only) for tour operators when one of the TNT BAE146 QC 

aircraft is not available due to a technical problem. 

ii. Limitation of aircraft usage to only NATO operations and private use operations would cause 

undue burden on the operator when utilization of the aircraft by NATO is low. 

iii. Boeing installs these MDCDs on their 757-200 Production and Special freighters and combi; 

the identical MDCDs are approved in STC ST03562AT for the STA Mobile 757-200 

freighters. The 757-200 fleet with this MDCD have accumulated service history of more than 

2,813,162 flight hours and 1,913,483 flight cycles without any significant service difficulties. 

The present fleet is being operated by UPS, DHL, FedEx and many others. See Appendix B 

for details on the MDCD service history. 

iv. This will be the only 757-200 Combi Aircraft that will be converted by STA Mobile with the 

non-compliant (to the latest requirements) MDCD. 

v. Exemption Number 10418 is time-limited, and STA Mobile must implement design changes 

to meet the requirements of § 25.783 Amendment 25-114 within two years of issuance of the 

exemption (i.e. by 22 December 2013). STA Mobile has already started the redesign 

process to implement the required changes and is confident it will meet the stipulated 

timeframe 

Furthermore, STA Mobile requests that the publication and comment procedures be waived in 

accordance with § 11.29 and § 11.87 for the following reasons: 

i. The FAA had approved the MDCD for STC ST03562AT (STA Mobile 757-200SF). 

ii. The FAA clarified the requirements of § 25.783(c) and § 25.783(d)(3)(i) late in the STC 

certification program. 

iii. The current usage limitation precludes the operator’s ability to conduct revenue flights, which 

while limited, will cause financial harm to the operator if the limitation is not removed soon 

after the STC is issued by the end of January 2012.