Km 9 1/2 Carretera Panamericana, La Libertad, El Salvador PBX (503) 2254

- 2300 vecaairlines.com

February 1 6 , 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 ex emption to comply with 14 CFR Part 129.117 paragraph (e)(1)

. The ex emption 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% require ment of Part 129.117(e)(1) when we add the second A/C to the Ops

- Specs.

 According to AIRBUS t he development of the modification instructions will be complete d 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:

Feder al Aviation Administration, Parent Agency: De partment 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 grant ed , would be in p ublic 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 modifica tion , 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 2 015 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 retrofi t 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 A pril 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

Phon e 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 A vionics Inspector