UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION RENTON, WASHINGTON 98057-3356

In the matter ofthe petition of ST Aerospace Mobile, Inc Exemption No.11060

for an exemption from§§ 25.7850), 25.807(g)(l), 25.807(i)(l), 25.810(a)(l), 25.812(e), 25.813(b)(l), 25.813(b)(6), 25.1445(a)(2), and 25.1447(c)(l) ofTitle 14, Code ofFederal Regulations Regulatory Docket No. FAA-2014-0351

PARTIAL GRANT OF EXEMPTION By letter dated May 9, 2014, Mr. Kumaresan Subramaniam, Engineering Director, ST Aerospace Mobile, Inc., 2100 9th Street, Brookley Complex, Mobile, Alabama, 36615, petitionedthe Federal Aviation Administration (FAA) for exemption from the requirements of§§ 25.785G), 25.807(g)(l) and (i)(l), 25.812(e), 25.813(b)(l) and (6), 25.1445(a)(2), and 25.1447(c)(l) of Title 14, Code ofFederal Regulations (14 CFR). Itwas confirmed viatelephone conversation on August 15,2014, that the petitioner also intended to request relieffrom the requirements of § 25.810(a)(l). The requested exemption, ifgranted, wouldpermitrelieffrom the requirements ofthese regulations to allow carriage ofnon-crewmembers (commonly referred to as supernumeraries) within the flight deck area on Boeing Model 757-200 airplanes whichhave been converted from a passenger to freighter configuration. The petitioner requests relieffrom the following regulations: Section 25.7850), at Amendment 25-88, requires, in pertinentpart, handholds to enable passengers to steady themselves when moving about the cabin, in the event the airplane encounters moderately rough air. Section 25.807(g)(l), at Amendment 25-114, requires that, ifoverwing exits are not provided, airplanes having a passenger seating configuration of 1to 9 seats mustbe fitted with an emergency exit having at least the dimensions ofa Type III exit in each side of the fuselage. Section 25.807(i)(l), at Amendment 25-114, requires that airplanes having a passenger seating configuration ofnine or fewer seats, excludingpilot seats, must have at least one exit above the waterline in each side ofthe airplane, meeting at least the dimensions ofa Type IV exit.Section 25.810( a)(1), atAmendment 25-114, requires, inpertinentpart, that each nonoverwing emergency exit more than 6 feet from the ground have an approved means to assist occupants in descending to the ground. Forpassenger exits, this must be a selfsupporting, automatically deployed and erected slide at each applicable exit. Section 25.812(e), at Amendment 25-128, requires, inpertinentpart, that floor proxiruity emergency escape-path markings mustprovide emergency evacuation guidance for passengers when all sources ofillumination more than 4 feet above the cabin aisle floor are totally obscured. Section 25.813(b)(1), at Amendment 25-128, requires, in pertinentpart, that each passenger emergency floor-level exit, equipped with an assist means, have an assist space next to that exit. Section 25.813(b)( 6), at Amendment 25-128, requires a handle at each assist space to enable crewmembers to steadythemselves when assisting in an evacuation. Section 25.1445(a)(2), atAmendment 25-00, requires that when crew and passengers share a common oxygen supply source, the distribution system must have a means to separately reserve the minimum supply required bythe flightcrew on duty. Section 25.1447(c)(1), at Amendment 25-116, requires, in pertinentpart, that oxygen dispensing units mustbe automatically presented to the occupants before the cabin altitude exceeds 15,000 feet. The total number ofdispensing units and outlets must exceed the number ofseats by at least 10 percent. The extraunits must be uniformly distributed throughout the cabin as practicable, and there mustbe two oxygen masks in each lavatory. Related sections of 14 CFR Section 121.583(a) contains, inpertinentpart, a listing ofcategories ofpersons who may be carried aboard an airplane inpart 121 service, without having to comply with all ofthe requirements ofpart 121 pertaining to carriage ofpassengers. Section 121.547 contains, in pertinentpart, a listing ofcategories ofpersons who may be admitted to the flight deck during operation. The petitioner supports its request with the following information: This section quotes the relevant information from the petitioner's request, withminor edits for clarity. The complete petition is available at the Department ofTransportation's Federal Docket Management System, onthe Internet athttp://regulations.gov, in DocketNo. FAA-2014-0351. ST Aerospace Mobile (STA Mobile) is the applicant for a multiple airplane Supplemental Type Certificate for conversion ofBoeing 757-200 passenger airplanes to a 15-Unit Load Device (ULD) position (15-P) freighter configurationunder FAA Project Number ST14446AT-T. STA Mobile expects issuance ofSTC by October 15,2014. The purpose ofthis letter is to petition for an exemption from the requirements ofcertain sections ofTitle 14, Code ofFederal Regulations (14 CFR), Part 25, to allow carriage of non-crewmembers, or 'supernumerary' personnel, in a compartment within the reconfigured flight deck onthe converted airplanes. Supernumeraries will be restricted to those persons complying with§ 121.583 (a)(l) through (a)(8).

2STA Mobile requests thatthe publication and commentprocedures be waived in accordance with § 11.29 and § 11.87 for the following reasons: i. Similar exemptions have been issued bythe 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 precedent DESCRIPTION OF CONVERSION The main features ofthe intended conversion from the passenger aircraft configuration include: a) Installation ofa side-opening main deck cargo door (MDCD) and its surround structure. The MDCD design is based on that used inthe STA Mobile 757-200 Combi Freighter (STC ST03952AT) construction. b) Installation ofa 9grigid cargo barrier (RCB) at approximately STA 335, identical to that in the Boeing 757-200PF "package freighter ('PF')" design, providing separationbetweenthe flight deck and the main deck cargo compartment. c) Installation ofa vendor-developed main deck cargo loading system (CLS) to accommodate 15 industry-standard 88 x 125 contoured ULDs, such as the International AirTransport Association (lATA) SAA container, on the main deck, using a floor track system based on, and modified from, the incoming passenger aircraft main deck seat track installation, similar to the Boeing 757-200PF "package freighter" design. d) Accommodationfor six inthe flight deck, withtwo pilots and two observers being accommodated withinthe original flight deck layout ofthe incoming passenger configuration aircraft (with observers onbulkhead-mounted seats), and two supernumerary personnel locatedjustforward ofthe RCB, identical to the Boeing 757-200PF package freighter configuration. e) Installation ofa new crew entry door (CED), identical to that ofthe Boeing 757- 200PF, centered at approximately STA 311 onthe left-hand side ofthe fuselage forward ofthe RCB, inplace ofthe forward passenger and service doors existing on the incoming passenger configuration aircraft. f) Structural modifications related to the installation ofthe MDCD, CED, RCB, and CLS, including, but notnecessarily limited to, the floor and fuselage monocoque (skinfi·ame-stringer) structures. g) Systems modifications related to the air conditioning, communications, electrical power, fire protection, flight controls, hydraulics, indicating and recording, lighting, pitot-static (navigation), oxygen, as well as water and waste handling, based onthe 14-P special freighter design, to enable the main deck cargo compartmentto meet the Class E cargo compartment classificationrequirements, with a one-minute smoke detection system.

3h) Interior modifications and installations related to side-wall and ceiling liners, new flight deck lavatory and emergency equipment. i) Retention ofall certificated flight performance as well as weight and balance limitations (maximum taxi weight, maximum take-offweight, maximum zero fuel weight, maximum landing weight and center ofgravity range) ofthe incoming passenger configuration aircraft. j) Damagetolerance based on structural maintenance inspections featuring a minimum of20,000 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 Limitation Items in the Maintenance Planning Data document and its supplement. This petition seeks relieffrom the requirements ofthe following sections of 14 CPR, for the 15P conversion:

• § 25.7850), Amendment 25-88, Seats, berths, safety belts, and harnesses

• § 25.807(g)(l) and (i)(l), Amendment 25-114, Emergency Exits

• § 25.812(e), Amendment 25-128, Emergency Lighting

• § 25.813(b)(1) and (6), Amendment 25-128, Emergency Exit Access

• § 25.1445(a)(2), Amendment 25-0, Equipment Standards for the Oxygen Distributing System

• § 25.1447(c)(1), Amendment 25-116, Equipment Standards for Oxygen Dispensing Units The following information is provided to support this petition: To date, there have been many passenger-to-freighter conversions being carried outby 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 onthe flight deck will have special training, which includes proper methods for egress from the airplane and use of emergency equipment. Limitations will be imposed on the airplane operatorto find that all occupants are physically able to use the escape means provided. When supernumeraries are carried, they will be briefedprior to each flight as to the location and use ofthe emergency egress equipment and the supplemental oxygen equipment. Supernumeraries are also prohibited from being inthe cargo area during any flight operation. These limitations will be included as part ofthe Airplane Flight Manual Supplement (AFMS) similar to that ofSTC ST03562AT. The RCB sliding door will be closed and locked prior to taxi and will notbe opened again for access to the cargo area until the airplane has parked at its destination. Steps will also be taken to ensure thatno one is in the cargo area prior to the locking ofthe sliding door before taxi.

4Occupancy ofthe flight deck area ofthe 15P-configured airplane is limitedto a total of six (6) persons, which will consist ofsupernumeraries as defined by§ 121.583 (a)(1) through (a)(8), and personnel permitted onthe flight deck as defined by§ 121.547. This limitation will be included inthe AFMS similarto that ofSTC ST03562AT. The AFMS will include a requirement for the flight crewto briefsupernumeraries onthe use ofthe escape provisions priorto each flight. 

### § 25.7850), Amendment 25-88, "Ifthe 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 usingthe aisles in moderately rough air." Justification: Handholds are not available inthe flight deck area due to the space constraint. The configuration ofthe flight deck area with the supernumerary seats' backs attached onthe RCB does not permitusingthe seat back as the traditional handhold. The lack of handhold is identical to that ofSTAMobile 757-200SF supernumerary area configuration. A Petition for Exemption was submitted by STA Mobile in connection withthe STA Mobile 757-200SF with regards to the equivalent§ 25.785(d) at Amendment 25-32, and this resulted inFAA Grant ofExemptionNo. 9487. The flight crew area is limited to the use ofoperator assigned supernumeraries or flight crew (notpublic passenger) as described by§ 121.583 (a)(1) through (a)(8) and/or § 121.547 whom have higher level oftraining and knowledge ofthe flight deck area layout. There will also be a recommendationto supernumeraries to remain seated with their seatbelts fastened. Therefore, an acceptable level ofsafety is provided. 

### § 25.807(g)(l) and (i)(l), Amendment 25-114, "25.807(g)(l): Fora passenger seating configuration ofI to 9 seats, there mustbe at least one Type IV or larger overwing exit in each side ofthe fuselage or, ifoverwing exits are notprovided, atleast one exit in each side thatmeets the minimum dimensions ofa Type III exit. 25.807(i)(1): Ditching emergency exits for passengers. Whether ornotditching certification is requested, ditching emergency exits mustbe provided in accordance with the following requirements, tmless the emergency exits required by paragraph (g) ofthis section already meet them: (1) For airplanes that have a passenger seating configuration ofnine or fewer seats, excluding pilot seats, one exit above the waterline in each side ofthe airplane, meeting at least the dimensions ofa Type IV exit." Justification: Flight deck is equipped with a left hand crew entry door (22" x 56"), with a step-up inside the aircraft ofI0 inches. This meets the size requirement ofa Type III door for the LH side ofthe aircraft. The RH side ofthe aircraft does not have a Type III door. However, the right hand flight deck windowwill be modified to be openable from the outsideto serve as a flight crew emergency exit. Both exits are above the waterline, and will be

5equipped with ropes to serve as escape means. Recommended evacuation procedures will be briefedto the supernumeraries prior to each flight. Since the supernumeraries have a higher level oftraining and lmowledge ofthe airplane configuration than a typical passenger, an acceptable level ofsafety is provided. The same exemptionwas granted to the Boeing Package Freighter certified under TCDS A2NM, using ExemptionNo. 4808, and to Precision Conversions' PCP (STC ST01529SE), using ExemptionNo. 8258, using the samejustifications. 

### § 25.812(e), Amendment25-128, "Floorproximity emergency escape pathmarking mustprovide emergency evacuation guidance for passengers when all sources of illumination more than4 feet above the cabin aisle floor are totally obscured. Inthe dark ofthe night, the floor proximity emergency escape pathmarking 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 ofexits forward and aft ofthe seat; and (2) Readily identify each exit from the emergency escape pathby reference only to markings and visual features not more than 4 feet above the cabin floor." Justification:

... the configuration ofthe converted Boeing Model 757-200 inthe flight deck area does notprovide floor proximity emergency lightings, as required by§ 25.812(e). The proximity ofthe two supernumeraries to the emergency exits, viathe left hand Crew Entry Door and the right hand flight deck window, provides a level ofsafety that would notbe enhanced by the installation offloor proximity emergency lightings. In addition, supernumeraries have a higher level oftraining and lmowledge ofthe emergency exit layout thanthe typical passenger. Hence, the configuration ofthe flight deck area provides an acceptable level ofsafety for the supernumeraries. The absence offloor proximity emergency exit path marking is identical to the configuration ofSTAMobile 757-200SF. A Petition for Exemption was submittedby STA Mobile for STA Mobile 757-200SF and resulted in FAA Partial Grant ofExemption (No. 9487). In ExemptionNo. 9487, the FAA had granted the exemption based onthe samejustifications described above. The same exemption was granted to Precision Conversions' PCP (STC ST01529SE), using ExemptionNo. 8258, based onthe same justifications. 

### § 25.813(b), Amendment25-128, "Adequate space to allow crewmember(s) to assist in the evacuation ofpassengers mustbe provided as follows: (1) Each assist space mustbe a rectangle onthe floor, ofsufficient size to enable a crewmember, standing erect, to effectively assist evacuees. The assist space mustnot reduce the unobstructed width ofthe passageway belowthat required for the exit. (6) There mustbe a handle, or handles, at each assist space, locatedto enable the crewmember to steadyhimselforherself: (i) While manually activating the assist means (where applicable) and,

6(ii) While assisting passengers during an evacuation." Justification: The configuration ofthe flight area does not provide an assist space adjacent to each exit, due to the space constraint withinthe flight deck. However, since the supernumeraries will have a higher level oftraining than a typical passenger, they will have no need for crew assistance. In addition, inthe relatively small confines ofthe flight deck area, the flight crew can easily provide instmctions and some physical assistance to the supernumeraries, ifneeded. The absence ofan assist space adjacent to each exitis identical to the configuration of STAMobile 757-200SF. A Petition for Exemption was submitted by STA Mobile for STA Mobile 757- 200SF and resulted inFAAPartial Grant ofExemption (No. 9487). In ExemptionNo. 9487, the FAA had granted the exemptionbased onthe same justifications described above. The same exemption was granted to the Boeing Package Freighter certified under TCDS A2NM, using ExemptionNo. 4808, and to Precision Conversions' PCP (STC ST01529SE), using ExemptionNo. 8258. 

### §25.1445(a)(2), Amendment 25-0, "When oxygen is suppliedto both crew and passengers, the distribution systemmustbe designed for either-- (1) A source ofsupply for the flight crew on duty and a separate source for the passengers and other crewmembers; or (2) A common source ofsupplywithmeans to separately reserve the minimum supply required by the flight crewon duty." Justification: There is no meansto separate the means ofoxygento reserve the minimum supply required bythe flight crew as the supernumeraries occupy the same flight deck area as the flight crew. Since the two supernumeraries are co-located withinthe enlarged cockpit, they can communicate directly and receive instructions from the flight crew. Moreover, the common oxygen cylinder is able to supply sufficient supplemental emergency oxygen for up to six occupants for anETOPS duration ofup to 120 minutes The absence ofthe ability to separatetl1e oxygen supply for the flight crewuse is identical to that onthe Boeing 757-200 Package Freighter certified underTCDS A2NM and the Precision Conversions' PCP (STC ST01529SE). InExemptionNo. 8258, the FAAhad granted the exemptionbased onthe samejustifications described above. 

### § 25.1447(c)(l), Amendment25-116, "There mustbe an oxygen dispensing unit connected to oxygen supplyterminals immediately available to each occupant wherever seated, and at least two oxygen dispensing units connectedto oxygenterminals in each lavatory. The total number ofdispensing units and outlets inthe cabinmust exceedthe number ofseats by at least 10 percent. The extraunits mustbe as uniformly distributed throughout the cabin as practicable. Ifcertification for operation above 30,000 feet is requested, the dispensing unitsproviding the required oxygen flow mustbe automatically presented to the occupants before the cabinpressure altitude exceeds 15,000 feet. The

7crewmust be provided with a manual means ofmaking the dispensing units immediately available inthe event offailure ofthe automatic system." Justification: The two supernumeraries will have two quick-donning type masks similarto the flight crewthat are not automatically presented. However, the high level oftraining ofthe supernumeraries and the aural warning system will allow the flight crewto commandthe supernumeraries to don the masks, providing an adequate level ofsafety to all occupants. The lavatory will also be outfitted with a portable walk around oxygenbottle equipped with an oxygen mask. This area will not be utilized for takeoffand landing. The absence ofthe automatic presentation ofthe dispensing units for oxygenuse is identical to the configuration ofSTA Mobile 757-200SF. A Petition for Exemption was submitted by STA Mobile for STA Mobile 757-200SF and resulted inFAA Partial Grant ofExemption (No. 9487). InExemptionNo. 9487, the FAA had granted the exemption based on the samejustifications described above. The same exemption was granted to Precision Conversions' PCF (STC ST01529SE), using ExemptionNo. 8258, based onthe samejustifications. Evaluation ofPublic Interest: Thepresence oftrained personnel on boardthe airplane when cargo is carried will enhance flight safety, which is inthe public interest. Granting this exemption will enhance the utility ofthe airplane for the operator by ensuring that needed cargo managementpersonnel will be available at each flight destination. This will reduce shipping costs and transit time, whichis inthe public interest. As Boeing 757-200 passenger airplanes are conve1ied into 15P-configured airplanes, airlines will replace them with newpassenger airplanes which meetnewer 14 CFRPart 25 Amendments. Over time, this will have the effect ofraising the safety level ofthe passenger airline fleets, which is in the public interest. Petition for Exemption: Based on the information provided, STA Mobile, hereby petitions for exemption from the following sections of 14 CFRPart 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:

• § 25.7850), Amendment 25-88, Seats, berths, safetybelts, and harnesses

• § 25.807(g)(1) and (i)(1), Amendment 25-114, Emergency Exits

• § 25.812(e), Amendment 25-128, Emergency Lighting

• § 25.813(b)(l) and (6), Amendment 25-128, Emergency Exit Access

• § 25.1445(a)(2), Amendment 25-0, Equipment Standards for the Oxygen Distributing System

8• § 25.1447(c)(1), Amendment 25-116, Equipment Standards for Oxygen Dispensing Units STA Mobile respectfully requests favorable FAA consideration ofthis petition. Federal Register publication The FAA has determined that good cause exists for waiving the requirement for Federal Register publication for public commentbecause the request is identical in all material respects to previously granted exemptions; the exemption, ifgranted, would not set a precedent; and any delay in acting onthis petition would be detrimental to ST Aerospace Mobile, Inc. The FAA's analysis The FAA considers the petitioner's proposal to be in the public interest for the following reasons: The FAAhas granted several exemptions for the carriage ofsupernumeraries on freighter airplanes. These supernumeraries are seen as a benefitto airplane safety and efficient operations ofair cargo and a significant dismption ofair commerce could occur ifthe petition were not granted.
The certificationregulations for transport-category airplanes address airplane occupants as being either "crew" or "passengers." Due to differences intraining, physical capabilities, and other factors (such as familiarity withthe airplane), the means required bypart 25 to address emergency evacuation and emergency equipment differ for passengers and crewmembers. Because supernumeraries are not crewmembers, they must be considered "passengers" by default, withrespect to part 25. However, supernumeraries do hold a special status because of their training and other factors. The FAA, therefore, has granted certain exemptions to allow the carriage ofsupernumeraries on freighter airplanes without compliance with all ofthe part 25 standards for passengers, provided that certain other conditions are met. Those conditions have varied, depending on the airplane design, the nature ofthe proposals under consideration, and the number and location ofpersons to be carried.
The handhold requirement of§ 25.785G), at Amendment 25-88, is to ensure that occupants have a means to steady themselves inmoderately rough air while traversing the main aisles oftypical passenger airplanes. The petitioner states that the lack-of-handhold issue is identical to that of the ST Aerospace Mobile, Inc., 757-200SF supernumerary-area configuration for which the FAA granted reliefviaExemptionNo. 9487. On the proposed airplane, the FAA requires the same limitation for a crew-operated visual/aural alerting system as stated in ExemptionNo. 9487. This alerting system enables the crew to indicate, at the onset ofturbulence, that supernumeraries mustreturn to their seats. The alert mustbe recognized in accessible areas inthe supernumerary compartment and lavatory and indicate, during turbulence, those persons mustreturn to their seats.
The emergency exitprovided on the right side ofthe airplane-the right flight deck windowdoes not meet the minimum size for a Type III exit as required by§ 25.807(g)(1). The Boeing Company has tested the usability ofsuch a right flight deck window. Results indicate that the

9window can be used for an exit-withthe evacuation means provided-for a maximum ofseven people inthe flight deck ofthe BoeingModel 757-200PF. Also, the four non-crewmembers of the airplane will have a higher level oftraining and be physically more capable ofevacuating the airplane by using the smaller exit opening provided onthe right side ofthe airplane than would typical passengers. The emergency exit provided onthe right side ofthe airplane-the right flight deck windowalso does not meet the minimum size for a Type IV exit as required by§ 25.807(i)(l) for a ditching exit. As discussed above, the utility ofthe right flight deck window and its usability withthe evacuation means provided has been demonstrated for a maximum occupancy ofseven persons on the flight deck ofthe Boeing Model 757-200PF. This demonstration would also apply to evacuating the airplane for ditching. Furthermore, the four non-crewmembers ofthe airplane will have a higher level oftraining and bephysically more capable ofevacuating the airplane by using the reduced exit opening on the right side ofthe airplane than would typical passengers. It should be noted that, iflife-rafts must be installed for flights over water, they must be ofa design that can be launched out ofthe right flight deck window.
As stated above, because oftheir training and physical capabilities, as well as other factors, flight crewmembers are different than typical passengers, and as such, the means required bypart 25 to enable flight crewmembers to reach the ground are different from those required for passengers. As an example, ropes are allowed as the sole means ofescape for flight crewmembers, but slides or equivalent means are required for passengers. Although supernumeraries mustbe considered "passengers" by default (because they are not crewmembers) under part 25, the FAArecognizes that supernumeraries normally have unique training to perform their roles on an airplane. As indicated above, the FAAhas previously granted exemptions to allow the carriage ofsupernumeraries on cargo airplanes without complying with all ofthe part 25 requirements applicable to passengers. The petitioner has proposedto not install an assist means at the crew entry door. We have reviewed figure 2 inthe information submitted by the petitioner, and confirmed with a phone call with the petitioner onAugust 15,2014, that the intent ofthe petitioner is to also request relief from the requirements of§ 25.810(a)(l). This section requires the passenger emergency exits to be equipped with a self-supporting slide or equivalent assist means. ST Aerospace Mobile, Inc. has proposed to install descent devices (commonly known as inertiareels) at the crew entry door emergency exit.
The issue ofwhether inertiareels withharnesses for trained supernumeraries provide an acceptable alternative to the escape slides required bypart 25 for passengers is discussed in some length inExemptions No. 4808 and 4808A. (The FAA granted those exemptions to the Boeing Commercial Airplane Group in 1987 and 1997, respectively.) This issue is also discussed in ExemptionNo. 5993A, which the FAA granted in 1995 to the Boeing Commercial Airplane Group for Boeing 767-300F airplanes.
The FAArecognizes that supernumeraries, as opposed to passengers, may be selected and trained appropriately inthe use ofescape ropes and inertia reels and harnesses. We consider that

10the petitioner's proposed installation ofinertiareels and harnesses at the emergency exit crew entry door and retention ofthe existing escape ropes installed for the flight deck window exits on the left and right side provides an adequate level ofsafety to supernumeraries for the petitioner's airplane configuration.
The petitioner requested an exemption from§ 25.812(e) that requires floor-proximity emergency escape-path markings in the passenger areas ofthe airplane. During the evaluation ofthis petition, the FAA determined that the original certificationbasis for the 757- 200 did not include Amendment 25-58, which codified the requirements for the floor-proximity emergency escapepath marking requirements. The petitionerhas volunteered to step up to this amendment level of § 25.812 and thenrequest an exemption from that requirement. The FAA has elected to revert the petitioner's certificationbasis to Amendment 25-32 for§ 25.812, which does not include the floor-proximity emergency escape-path marking requirements rather than grant an exemption from that requirement.
The petitioner's Boeing Model 757-200 airplanes have a crew entry door onthe left and the number 2 flight deck windows, left and right, available for evacuation. However, the configuration does not provide an assist space or an assist handle nextto the exitto allow a crew member to assist in the evacuation ofthe supernumeraries as required by§ 25.8l3(b). With respect to the lack ofan assist space and assist handle adjacent to the crewentry door on the left, the FAA has determined that the supernumeraries will have a higher level oftraining than a typical passenger, and will therefore have less need for crew assistance. Additionally, inthe relatively small confines ofthe flight deck and supernumerary area, the flightcrew can easily provide instructions and some physical assistance, ifneeded. The FAA considers that an assist space and assist handle are not necessary in this case due to the size ofthe exit and the inertial reel assist means provided withthe number ofoccupants, and to the higher level oftraining of the occupants.
The petitionerhas requested relieffrom the requirements of§ 25.1445(a)(2) which require that when a single source ofoxygen is provided for the flightcrew and passengers, a means must be provided to separately reserve the minimum supply required bythe flightcrew on duty. The petitioner has proposed a design ofthe systemthat is intended to provide oxygento four supernumeraries and the flightcrew, as ifthey were all required flight crewmembers. Supplying all six occupants as ifthey were all flightcrew on duty in the flight deck would comply with the regulations and thus, would not require an exemption. However, the amount ofoxygen mustbe sufficient for operational requirements for the airplane mission.
The FAA considers that the supernumeraries should have an oxygen systemthat is comparable to that ofpassengers. However, taking into account the extraknowledge and training that these persons will have, it is not necessary that an equivalent systembe installed. Section 25.1447(c)(l) requires automatic presentation ofthe oxygen dispensing units. For seated passengers intypical passenger airplanes, the automatic presentation ofmasks throughout the cabin indicates the need to don an oxygenmask. Supernumeraries onthe petitioner's Boeing Model 757 airplanes will nothave this indication. In order for an acceptable level ofsafety to be provided, an automatically activated aural/visual decompression signal mustbe immediately



### 11recognizable throughout the supernumerary seating area and the lavatory. Operation ofthis signal must be automatic with flightcrew manual action as a backup. Additionally, the petitionerproposed to provide supernumeraries with a portable walk-around oxygenbottle equipped with a supplementalpassenger oxygen mask when accessing the lavatory. To ensure adequate hypoxiaprotection during non-sedentary use, all ofthe oxygen units must meet the requirements for flightcrew oxygen equipment(§ 25.1443(a) or (b)), orthe equipment must be shownto protect the supernumerary from hypoxia at an activity level required to return to his orher seat following a rapid decompression to 25,000 feet cabin altitude. One acceptable means ofcompliance is the use ofa continuous-flow passenger oxygen mask that meets FAA Technical Standard Order TSO-C64a, or later revision, and is approved for use up to at least 40,000 feet cabin altitude, and is connected to an oxygen bottle that supplies a flow rate ofat least 4 liters per minute NTPD (Normal Temperature and Pressure Dry) at a cabin altitude of23,000 feet. Ifthe oxygen bottle regulator has more than one flow rate itmustbe set to 4 liters per minute NTPD.
The non-auto presenting oxygen dispensing units at the supernumeraries' seats and the portable oxygenunit must still meet § 25.1449, which states that there must be a means for the crewto determine whether oxygen is being delivered to the dispensing units. The FAA has determined that it would be an acceptable means ofcompliance to train the supernumeraries inmaking this determination and to provide oxygen flow indicationinthe oxygen equipment.
Section 25.1447(c)(1) also requires 10% extra oxygen masks. The intent is that these masks will be used by flight attendants and children sitting onpassengers' laps. Since neither will be onboard the airplane, installing 10% extra oxygen masks is not required. Supernumeraries must be trained regarding the location and use ofoxygen equipment and the alerts that indicate the need to don oxygen equipment. The oxygenunits must be sized adequately for continuous and uninterrupted use during worst-case flight duration following decompression. TheFAA's decision In consideration ofthe foregoing, I find that a partial grant ofexemption is inthe public interest. Therefore, pursuantto the authority contained in49 U.S.C. §§ 40113 and 44701, delegated to me by the Administrator, ST Aerospace Mobile, Inc., is hereby granted a partial exemption from 14 CFR §§ 25.785G), 25.807(g)(1) and (i)(l), 25.810(a)(1), 25.813(b)(1) and (6), 25.1445(a)(2) and 25.1447(c)(l) to the extent necessary to allow type certification ofBoeing Model 757-200 series airplanes withprovisions for the carriage ofsupernumeraries. The petitioner is not granted an exemption from§ 25.812(e), Amendment 25-128.
The following conditions apply and limitations numbers 1through 7, S.d, and the preflight briefings required by 7 and 9, below, mustbe documented in the limitations section ofthe airplane flight manual:
I. A maximum offour supernumeraries may occupy the area on the flight deck.

122. The supernumeraries are limited to the categories specified in§§ 121.583(a)(l) through 121.583(a)(8).
3. Supernumeraries are prohibited from being inthe cargo area during any flight operation. The pre-flight briefing must inform supernumeraries ofthis requirement.
4. Prior to each flight, a flightcrew member mustbriefeach supernumerary on the use ofthe exits, assist means, and emergency equipment.
5. The operator must determine that each supernumerary is physically able and trained to accomplish the necessary emergency procedures.
6. A flightcrew-operated aural or visual annunciation that would be recognized in the supernumerary seating area and lavatory must be installed to indicate, during turbulence, that persons must return to their seats. Appropriate procedures/limitations must be established to ensure that the flightcrew signals the supernumeraries to returnto their seats at the onset of turbulence and for landing.


### 7. DecompressionAlert:
An automatically activated aural decompression signal must be present and immediately recognizable inthe lavatory to notify supernumeraries when to don oxygen masks. The pre-flight briefing must include training inthe sound ofthe alert, the meaning ofthe alert, and the response to the alert, and coverprocedures for donning the masks and activating the flow ofoxygen. 8. Supernumeraries Fixed and Portable Oxygen:

a. There mustbe at least one fixed non-automatically presenting oxygen unit installed and located such that each occupant can don a mask and can simply activate the oxygen flow while seated. The oxygen masks mustbe within easy reach ofthe supernumeraries while seated. The unit mustprovide an indicationto the user that oxygen is flowing.
b. There mustbe at least one portable oxygen unit with a mask connected to it located in the lavatory. The unit mustprovide an indication to the user that oxygen is flowing.

c. The oxygen units must meet the performance requirements of§ 25.1443(a) or § 25.1443(b), or the equipment mustbe shown to protect the supernumerary from hypoxia at an activity level required to return to his or her seatfollowing a rapid decompression to 25,000 feet cabin altitude.
d. The supernumeraries must betrained inthe use ofthe fixed and portable oxygen units. The supernumeraries must also betrained inmalcing the determination whether oxygen is being delivered to the dispensing units.

13e. The fixed and portable oxygenunits mustbe sized adequately for continuous and uninterrupted use during worst-case flight duration following decompression, ormust be ofsufficient duration to allow the supernumeraries to return to their seats where additional oxygen is readily accessible for the remainder ofthe decompression.
9. Placards:
Placards are to be located outside ofthe cargo compartment, in a conspicuous location either on or adjacent to the smoke barrier doors. Theplacards must indicate the following:

a. Do not occupy the Class E cargo compartment during taxi, take-off, and landing and flight.
b. The smoke barrier mustbe secured (i.e., the doors mustbe closed) except when entering or leaving the cargo compartment.
The pre-flightbriefing must inform supernumeraries ofthese requirements.
10. Alerting Requirements:

a. Mustbe distinctive and effective. The alert forturbulence must be clearly distinguishable from the alerts for decompression/fire/smoke.
b. Visual alerts mustbe visible from all occupant locations and orientations, during all expected operational conditions including a rapid decompression where moisture in the air may condense.

c. Aural alerts mustbe loud enoughto be heard during all expected operational conditions including a rapid decompression where the ambient noise level will mcrease.
11. A standard airplane public address (PA) system must be installed. Itmustbe audible tln·oughout the supernumeraries' seating area.



### . Issued inRenton, Washington, on 

## SEP 232014

Dionne Palermo Acting Manager, Transport Airplane Directorate Aircraft Certification Service

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