David M. McDonald
VP Operations

7765 Northwest 54 th Street Miami, Florida 33166 U.S.A. Phone 305.594.5802

Fax 305.594.5804 www.aeronautical-engineers.com dmm@aeronautical-engineers.com May 16, 2012

U.S. Department of Transportation Docket Management System

400 7 th Street SW

Room PL 401 Washington, DC 20591-0001

Attention Transport Airplane Directorate

RE: Request For Exemption From FA R §25.785(k) For Freighter Aircraft (STC # ST01827LA)

To Whom It May Concern,

Aeronautical Engineers, Inc. (AEI) has been gr anted an exemption from certain Federal Aviation Regulations (FAR) pursuant to 14 CFR Part 11, vi a Exemption No. 9722, allowing the carriage of up to 4 non-crewmembers (commonly referred to as supernumeraries). In addition to the exemptions requested and granted in Exemp tion 9722, AEI also seeks an exemption from the requirements of FAR §25.785(k)

The petitioner requests relief from the following regulations:

§25.785(k), Amendment 25-88, requires (k) Each projecting object that would injure persons seated or moving about the airplane in normal flight must be padded.

The petitioner supports its request with the following information:

AEI holds numerous Supplemental Type Certificates for modification of transport aircraft. With regard to this petition, AEI holds STC ST 01827LA which allows conversion of Boeing 737- 300/400 aircraft to a freighter with a Class E ma in deck cargo compartment. Over 200 Boeing aircraft have been converted by AEI to freighters. Some operators of AEI freighters need to be able to carry supernumeraries to assist with specia l cargo such a valuable cargo requiring security and/or perishable, fragile, or live cargo requiring special attention to ensure its safe delivery. The interest of the petitioner is in providing a level of safety for th e crew, supernumeraries, cargo and aircraft that will allow operator s of AEI converted 737 freighters to meet the needs of their

clientele.

In this case, the supernumeraries are limited to a maximum of 4 persons. There are far fewer supernumeraries on a freighter th an passengers on a passenger ai rcraft. The supernumeraries, unlike passengers, will be trained on emergenc y procedures, including emergency egress and safety during flight. The area available for the supernumeraries is very limited and theDavid M. McDonald
VP Operations

7765 Northwest 54 th Street Miami, Florida 33166 U.S.A. Phone 305.594.5802

Fax 305.594.5804 www.aeronautical-engineers.com dmm@aeronautical-engineers.com supernumeraries will normally be se ated in the flight attendant (F/A ) seats during flig ht, except to use the lavatory or galley. See in cluded photos and diagram below.

AEI B737-300/400 Freighter Supernumerary Area

The emergency equipment, the cargo door contro l panel and cargo door hydrau lic system panel are installed on the 9G barrier adjacen t to the F/A seats. These obj ects do not pose a hazard to the supernumeraries when seated and will not be a hazard during normal flight. As shown in the diagram above, this is a very small area and, when not in their seats, supe rnumeraries can easily steady themselves with the su rrounding aircraft structure.David M. McDonald
VP Operations

7765 Northwest 54 th Street Miami, Florida 33166 U.S.A. Phone 305.594.5802

Fax 305.594.5804 www.aeronautical-engineers.com dmm@aeronautical-engineers.com 9G Barrier and Forward F acing Supernumerary SeatDavid M. McDonald
VP Operations

7765 Northwest 54 th Street Miami, Florida 33166 U.S.A. Phone 305.594.5802

Fax 305.594.5804 www.aeronautical-engineers.com dmm@aeronautical-engineers.com Retained Original F/A Seat

Request for Waiver of Public Comment

AEI requests waiver of the normal public comment process since this request is substantially similar to those already granted to other freigh ter STC holders and because the granting of this petition will not create new precedent.

2. Public Interest

The carriage of an appropriate number of attendants aboard an aircraft to monitor and to attend to the special requirements of valuable, fragile, peri shable, or live animal cargo, serves the publicDavid M. McDonald
VP Operations

7765 Northwest 54 th Street Miami, Florida 33166 U.S.A. Phone 305.594.5802

Fax 305.594.5804 www.aeronautical-engineers.com dmm@aeronautical-engineers.com interest in raising the level of safety of the car go, the airplane, the flight crew, and consequently, the public in general. In addition, these exemptions will enhance the utility of the aircraft, thereby helping to reduce shipping costs, which w ill in turn be in th e public interest.

This exemption, therefore serves the public interest for safety reasons and also for increased airfreight utility, both domes tically and internationally and consistent commercial operations among all AEI freighter operators.

AEI respectfully requests that this petition be granted.

Sincerely,

David M. McDonald,

Vice President