ST Aerospace Mobile, Inc 2100 9th Street, Brookley Complex Mobile, Alabama 36615, USA Tel : (251) 438 8888 Fax : (251) 438 8892

Singapore Technologies Engineering Page 1 of 8 FAA Atlanta 15 th July, 2011
Subject: Petition for Exemption
Reference: FAA Project Number ST13005AT-T

Dear Mr. Avella,

ST Aerospace Mobile (STA Mobile) is the app licant for a multiple airplane Supplemental Type
Certificate for conversion of B oeing 757-200 passenger airplanes into an “8 pallet/80-passenger” Combi configuration under FAA Project Number ST13005AT- T. STA Mobile expects issuance of STC by November 30, 2011.

The purpose of this letter is to petition for an exem ption from the requirement s of certain sections of Title 14, Code of Federal Regulations (14 CFR), Part 25, to allow carriage of non-crewmembers, or ‘supernumerary’ personnel, in a compartment aft of the flight deck on the converted airplanes. Supernumeraries will be restricted to those persons complying with § 121.583 (a)(1) through (a)(8).

STA Mobile requests that the publication and co mment procedures be waived in accordance with § 11.29 and § 11.87 for the following reasons:
i. Similar exemptions have been issued by the FAA for STC ST03562AT (STA Mobile 757- 200SF)
ii. Granting this petition would not set a precedent

DESCRIPTION OF CONVERSION
The main deck of the Combi configuration consists of the flight deck, supernumerary area, main deck cargo compartment (MDCC) and a passenger cabi n. The flight deck and supernumerary area is separated from the MDCC by a 9g Rigid Cargo Barrier (RCB) installed per STC ST02115LA at approximately STA 379. The passenger cabin is s eparated from the MDCC by a Smoke Barrier at approximately STA 1115.

The supernumerary area will accommodate up to two supernumeraries as defined by § 121.583 (a)(1) through (a)(8). The MDCC aft of the RCB is converted into a Class C cargo compartment, equipped with a Halon 1301 fire suppression system. The MDCC will be able to hold eight 88 x 125 or 88 x 108Singapore Technologies Engineering Page 2 of 8 sized pallets. The passenger cabin will be able to accommodate up to 80 passengers and 4 flight attendants. (See Figure 1).

Figure 1: Main Deck Layout

The Combi configuration retains Type I doors 1L and 1R, complete with escape slides or sliderafts. A rigid 9G barrier is installed just aft of door 1L, permitting both doors 1L and 1R to be used in an emergency evacuation. There is a sliding door on the left side of the RCB to provide access to the main deck cargo compartment. Two business class supernumer ary seats are installed immediately forward of the RCB (See Figure 2).Singapore Technologies Engineering Page 3 of 8 Figure 2: Cabin Layout Diagram (Not to scale)

The RCB is sealed to prevent smoke penetrati on. The two supernumerary seats are provided with supplemental oxygen through a salvaged passenger service unit with chemical oxygen generators and drop-down masks. Two-way communication is provi ded from the flight deck to each supernumerary seat through the relocation of an original flight attendant handset to the forward face of the RCB.

This petition seeks relief from the requirements of the following sections of 14 CFR, for the Combi
conversion:

 § 25.785(j), Amendment 25-88,Seats, berths, safety belts, and harnesses

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

 § 25.813(a) and (b), Amendment 25-128, Emergency Exit Access

The following information is provided to support this petition : To date, STA Mobile has re-delivered forty ( 40) STA Mobile 757-200SF configured airplanes to Federal Express since the issuance of STC ST03562AT on April 2, 2008 and the supernumerary area layout design has accumulated a consider able satisfactory service history.

In accordance with § 121.583, all persons that may be carried on the flight deck and supernumerary area will have special training, whic h includes proper methods for egress from the airplane and use of emergency equipments. Limitations will be imposed on the airplane operator to findSingapore Technologies Engineering Page 4 of 8 that all occupants of the supernumerary area are physically able to use the escape means provided. When supernumeraries are carried, they will be briefed pr ior to each flight as to the location and use of the emergency egress equipment, the supplement al oxygen equipment and the communication equipment. Supernumeraries are also prohibited from bei ng in the cargo area during any flight operation. These limitations will be included as part of the Airpl ane Flight Manual Supplement (AFMS) similar to that
of STC ST03562AT.

The RCB sliding door will be closed and locked prior to taxi and will not be opened again for access to the cargo area until the airplane has parked at its destination. Steps will also be taken to ensure that no one is in the cargo area prior to the lo cking of the sliding door before taxi. Admission to the flight deck of the Combi-configured airplane will be lim ited to those people that m eet the requirements of § 121.547, "Admission to the flight deck."

Occupancy of the flight deck and supernumerary ar ea of the Combi-configured airplane is limited to a total of six (6) persons, wh ich will consist of supernumeraries as defined by § 121.583 (a)(1) through (a)(8), and personnel permitted on the flight deck as defined by § 121.547. This limitation will be included
in the AFMS similar to that of STC ST03562AT. The modification will include provisions to carry personnel as defined by § 121.547 in the supernumerary area in compliance with § 25.722(c).

The Flight Crew Operations Manual Supplement (FCOMS) will provide instructions on the recommended evacuation procedures using doors 1L or 1R and the AFMS will include a requirement for the flight crew to brief supernumeraries on use of the escape provisions and communication equipments prior to each flight.

§ 25.785(j) , Amendment 25-88, “If the 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 using the aisles in moderately rough air.”

Justification: Hand holds are not available in the supernumerar y area. The configuration of the supernumerary area with the seats’ backs positioned along the perim eter of the RCB as shown in Figure 2 does not permit using the seat back as the traditi onal handhold. The lack of handhold is identical to that of STA Mobile 757-200SF super numerary area configuration.Singapore Technologies Engineering Page 5 of 8 A Petition for Exemption was submitted by STA Mobile in connection with the STA Mobile 757- 200SF with regards to the equivalent § 25.785(d) at Amendment 25-32, and this resulted in FAA Grant of Exemption No. 9487.

The supernumerary area is limited to the use of operator assigned supernumeraries or flight crew (not public passenger) as described by § 121. 583 (a)(1) through (a)(8) and/or § 121.547 whom have higher level of training and knowledge of t he supernumerary area layout. There will also be a recommendation to supernumeraries to remain seat ed with their seat belts fastened. Therefore, an acceptable level of safety is provided.

§ 25.812(e) , Amendment 25-128, “Floor proximity emergency escape path marking must provide emergency evacuation guidance for passengers when a ll sources of illumination more than 4 feet above the cabin aisle floor are totally obscured.”

Justification: From Figure 2, the configuration of the c onverted Boeing Model 757-200 in the supernumerary area does not provide floor proximity emergency lightings, as required by § 25.812(e).

The proximity of the two supernumeraries to the doors 1L and 1R, provides a level of safety that would not be enhanced by the installation of floor proximity emergency lightings. In addition, supernumeraries have a higher level of training and knowledge of the emer gency exit layout than the typical passenger. Hence, the configurat ion of the supernumerary area provides an acceptable level of safety for the supernumeraries.

§ 25.813(a) , Amendment 25-128, “Passageways between individual passenger areas and those leading to Type I, Type II, or Type C emergency exits must be unobstructed and at least 20
inches wide.”

Justification: There are two Type I emergency exits located at t he supernumerary area. However, the widths of the passageways between supernumerary seats and t he Type I emergency exits fall short of the required minimum 20 inches at certain points. The point of the shorte st passageway width, approximately 10.9 inches, is from the super numerary seat to the edge of Lavatory A.Singapore Technologies Engineering Page 6 of 8 STA Mobile seeks to “de-rate” the two Type I emergency exits into Type III emergency exits. As such, the minimum 20 inches requirements in accordance with § 25.813(a) will no longer be applicable. Since the supernumerary area and the passenger cabin compartment are completely isolated from each other, STA Mobile affirms t hat the passenger seating configuration of the supernumerary area is inaccessible from the pa ssenger cabin compartment aft of the smoke barrier. As such, there are only 6 occupants (inc luding the flight crew) who will have access to
Door 1L and 1R.

The applicable regulation, § 25.813(c)(2)(ii) at Am endment 25-128 states that “For airplanes that have a passenger seating configuration of 19 or fewer, there may be minor obstructions in this region, if there are compensating factors to main tain the effectiveness of the exit.” The smaller passageway may be considered as a minor obstr uction and the compensating factor would be the small number of supernumeraries and flight crew whom have a higher level of training and knowledge of the emergency exit la yout than the typical passenger. Given that there are only two supernumeraries, there would not be any congesti on in the passageways to the emergency exits during egress. In addition, the supernumeraries are in close proximity of the two Type I emergency exits. This is coupled with the fa ct that the supernumeraries are equipped with a higher level of knowledge of the airplane configuration than the typical passenger. Therefore, an acceptable level of safety is obtainable when t he Type I emergency exits are “de-rated” as Type III emergency exits.

§ 25.813(b) , Amendment 25-128, “Adequate space to allow crewmember(s) to assist in the evacuation of passengers must be provided.”

Justification: The configuration of the supernumerary area does not provide an assist space adjacent to each exit. However, since the supernumeraries will have a higher level of training than a typical passenger, they will have no need for crew assistance. In addition, in the relatively small confines of the supernumerary area, the flight crew c an easily provide instructions and some physical assistance to the supernumeraries, if needed.

The absence of an assist space adjacent to each ex it is identical to the configuration of STA Mobile 757-200SF. A Petition for Exemption was submitted by STA Mobile for STA Mobile 757-Singapore Technologies Engineering Page 7 of 8 200SF and resulted in FAA Partial Grant of Exem ption (No. 9487). In Exemption No. 9487, The FAA had granted the exemption based on the same justifications described above.

Evaluation of Public Interest:

The presence of trained personnel on board the ai rplane when live or hazardous cargo is carried will enhance flight safety, which is in the public interest.

Granting this exemption will enhance the utility of the airplane for the operat or by ensuring that needed cargo management personnel will be available at eac h flight destination. This will reduce shipping costs, which is in the public interest

As Boeing 757-200 passenger airplanes are convert ed into Combi-configured airplanes, airlines will replace them with new passenger airplanes wh ich meet newer 14 CFR Part 25 Amendments. Over time, this will have the effect of raising the safety level of the passenger airline fleets, which is in the public interest.

The usage of Combi-configured airplanes will optim ize the space usage in flights in cases where there is a low demand in passenger flights and a hi gh demand in cargo transportation. This will help reduce the number of flights and in turn lead to a reducti on of air pollution, which is in the public interest.

# ~:: ST Aerospace

A COnlp l n'f at ST En9jl'l'- l flring

Petition for Exemption

Based on the information provided
, STA Mobile, hereby petitions for exemption from the follow i ng
sect i ons of 14 CFR Part 25 for Boeing 757-200 passenger airplanes converted to a Combi configuration
under FAA STC Pro j ec t ST 1 3005A T -T to allow t he ca rr iage of supernu m era r ies i n t he supernumerary
area af t of the fl i ght deck :

• § 25

. 7850)
, Amendment 25

- 88
• § 25.812(e), Amendment 25-128

• § 25

. 813(a) and (b), Amendmen t 25

- 128

STA Mobile r espectfully requests favorable FAA consideration of this petition

.

Sincerely
, 

# fA

Terence Tan En g in ee rin g D i rector ST A eros p ace M obi l e, I n c. Offi ce: (251) 4 36-0 1 81 E -mail : Te r ence_TAN@s t mae

. com

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