Km 9 1/2 Carretera Panamericana, La Libertad, El Salvador PBX (503) 2254-2300 vecaairlines.com

February 16, 2015

U.S. Department of Transportation

Docket Operations

1200 New Jersey Avenue

S.E. West Building, Ground floor

RM W12-140, Washington D.C. 20590

ATT ́N: TO WHOM IT MAY CONCERN:

The intent of this letter is to kindly request for an exemption to comply with 14 CFR Part 129.117 

paragraph (e)(1). The exemption we are requesting is to comply with the 50% requirement on April 

2016.

FAR 129.117(e)(1) require operators of transport category airplanes with U.S. registered transport 

category, turbine – powered airplanes with a type certificate issued after January 1, 1958 to install a 

Flammability Reduction Means (FRM) in 50% of each operator fleet no later than December 26, 2014, 

and 100% of each operator fleet no later than December 26, 2017.

At this moment, VECA ́s fleet is one (1) aircraft, an AIRBUS A319-132 MSN 2718 – (N1235V), and 

we want to add a new A/C (A319-132, MSN 2383 – N1821V) no later by Feb 2015. We will present 

by Feb 20 the Maintenance Program and Minimum Equipment List to Dallas IFO for approval, in order 

to include this new A/C in our Ops-Specs.

The request for the exemption is base in the following facts:

 We must comply with the 50% requirement of Part 129.117(e)(1) when we add the second A/C 

to the Ops-Specs. 

 According to AIRBUS the development of the modification instructions will be completed by 

February 2015. After received the information we will need to issue an Engineering Order and all 

the relate document in order to perform the modification to the A/C. The applicable SB ́s will be: 

31-1314, 47-1034, 47-1033, 47-1035.

 The availability of the required parts (FTIS MOD KIT) will be on April 2015.

 In accordance with AIRBUS Solution for Flammability Reduction – (Fuel Tank Inerting System) –

(FTIS) the modification take around 650 Man Hours with elapsed time of 7-10 days.

 The following scheduled heavy check is by April 2016 – (MSN2383 – N1821V).

We request the aforementioned exemption because we plan to incorporate the FTIS modification on 

MSN 2383 during the heavy check inspection in order to avoid additional down time. We have learned 

that other carriers have been granted this request by the FAA (Docket ID: FAA-2013-0605 Agency: 

Federal Aviation Administration, Parent Agency: Department of Transportation, Summary: 14 CFR, 

Part 129.117)
Km 9 1/2 Carretera Panamericana, La Libertad, El Salvador PBX (503) 2254-2300 vecaairlines.com

If the exemption is granted, would be in public interest because VECA will increase the frequency and 

routes in Central America. Also of the small size of VECA fleet, increasing the airplane on ground time 

for this installation without an extension, would put VECA in a disadvantaged position as compared 

to competitors that will not incorporate the modification, as well as to competitors that operate much 

larger fleets and can manage multiple airplanes on ground without major impact to their operation.

The following table sow the schedule for FTIS installation, considering the exemption:

No. REG. NUMBER 2015 2016 2017

01 N1235V Oct-2015 – PO 

for MOD KIT Nov-2017

02 N1821V Apr-2016

% Compliance 50% 100%

If VECA will add a new aircraft during this period (2015 – 2017), the A/C will be incorporated with the 

FTIS modification embodied.

The FTIS MOD KIT for the N1235V will be ordered by October of 2015 in order to comply with the 

date from the table above (Nov-2017). This Modification will be incorporated in the next heavy check 

from this A/C.

As part of the plans and arrangements to retrofit the A/C, VECA will perform the following:

 Prepared the incorporation calendar of this modification, as indicated in the table above

 Plase the purchase orders for the FTIS MOD KIT for N1235V

 Contact an MRO that is performing the modification 

 Prepare all the material in order to facilitate its use during the FTIS installation.

The summary that can be published in the Federal Register regarding VECA exemption request is 

the following: “VECA Airlines is seeking for exemption to comply with the 14 CFR Part 129.117, 

paragraph (e)(1) by April 30, 2016, due to the Modification Kit from AIRBUS will be available 

by April 2015, high aircraft downtime for this modification and the next heavy check by April 

2016, add a new A/C to the fleet.”
Km 9 1/2 Carretera Panamericana, La Libertad, El Salvador PBX (503) 2254-2300 vecaairlines.com

If you require additional information regarding this application, please do not hesitate to contact me 

at the following:

Jose Miguel Alejandro Calderón Escobar

VECA Airlines, S.A. de C.V.

Km 9 1⁄2 Carretera Panamericana, Santa Tecla

La Libertad, El Salvador

Phone number (503) 7850-1889

e-mail address: mcalderon@vecaairlines.com

Sincerely,

Miguel Calderon

Quality Assurance Manager

Enclosures,

CC Mark R. Sawyer FAA

Principal Maintenance Inspector

Jim H. Speight FAA

Principal Operations Inspector

John A. Love FAA

Principal Avionics Inspector