Record of Telecon

Subject: BaySys Technologies, LLC, petition for exemption for the carriage of 19 

persons on the upper deck of a Boeing 747-400F with inflight access into the main deck 

Class E cargo compartment by a maximum of 15 persons.

Attendees: Nick Olmsted BaySys Technologies

Robert Roytas BaySys Technologies

Steve Walton BaySys Technologies

Jayson Claar FAA Cabin Safety ANM-115

Ian Won FAA ANM-115 Acting Manager

Steve Happenny FAA ANM-112 Smoke detection and penetration

Date: August 29, 2012

Docket Number: FAA-2012-0361

References: 1) BaySys Technologies petition for exemption dated April 26, 2012

2) FAA letter to Nick Olmsted, BaySys Technologies dated May 17, 2012

3) FAA letter to Nick Olmsted, BaySys Technologies dated July 10, 2012

BaySys Technologies has petition for exemption, reference 1), that if granted would 

allow the carriage of 19 persons including flight crew on the upper deck of a Boeing 747-

400F, and would allow inflight access to the main deck Class E cargo compartment by a 

maximum of 15 persons when the operations is associated with the carriage of live 

animals on the main deck that required care and inspection during flight. The upper deck 

of the Boeing 747-400F airplane is limited by the exit confirmation to maximum of 8 

persons due to the size of the overhead hatch on the left side of the airplane. BaySys 

Technologies is proposing to use another exit located on the main deck of the airplane 

which is within the Class E cargo compartment for additional evacuation capability for 

the left side of the airplane. The FAA has raised concerns with project and requested 

additional information with the reference letter 2) and 3). BaySys Technologies has 

responded to these letters by providing additional information and proposed tests for 

developing data to support the petition for exemption. 

This telecom was requested by the FAA to discuss the proposed evacuation 

demonstration of the 19 persons from the upper deck of the airplane, down the stairway

to the main deck and out the main deck emergency exit under heavy smoke conditions. 

The FAA is concerned for the safety of the test subject to used in this demonstration

considering the heavy smoke and the proposed evacuation route. Also, the FAA is 

concerned with the level of experience the BaySys Technologies has for conducting this 

type of test in the aircraft environment.

BaySys Technologies has proposed three types of operations for the subject airplane. 

One type of operation is associated with the carriage of live animals on the main deck 

that required care and inspection during flight with 19 persons on the upper deck and 
inflight access to the Class E cargo compartment is requested for 15 persons. The other 

two types of operations did not request inflight access to the Class E cargo compartment 

and have a maximum of 8 and 19 persons respectfully on the upper deck. 

The FAA questioned the need for the operation with the 19 persons with cargo on the 

main deck. BaySys Technologies identified that this is customer request and the believe 

this was requested to cover a flight either before or after the transport of the live animals 

to return the airplane and supernumeraries either to the home base or to transport live 

animals on the next flight. The FAA made a proposal that if we could allow that first 

additional type of operation with no cargo except for what is needed to transport the live 

animals; eliminate the second (19 persons on upper deck for general cargo); and maintain 

the third all other operations of the airplane be limited to a maximum of 8 persons on the 

upper deck with no inflight access to the Class E cargo compartment the FAA would not 

require the evacuation demonstration of the 19 persons from the upper deck of the 

airplane, down the stairway to the main deck and out the main deck emergency exit under 

heavy smoke conditions. This is based on the limitation of live animals and associated 

cargo only. Also, the associated cargo is additional limited to no HAZMAT, no ignition 

sources and lithium batteries are permitted on the main deck cargo compartment during 

the first type of operation.

BaySys Technologies took the action item to contact the owner/operator of the airplane to 

determine if this limitation would be acceptable and to respond in writing with a revision 

to the proposed operations listed in their petition for exemption. All parties involved 

agree that this was a very good proposal.