David M. McDonald

VP, General Counsel

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 August 22, 2014

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 Rs For CRJ-200 Freighter Aircraft

To Whom It May Concern,

Aeronautical Engineers, Inc. (AEI) seeks exem ption from certain Federal Aviation Regulations (FAR) pursuant to 14 CFR Part 11. Specificall y, AEI seeks an exemption from §§ 25.785(j), 25.812(e), 25.855(a), 25.857(e), 25.1447(c)(1), and 25.1449 of Title 14, Code of Federal Regulations, to allow the carriage of up to thr ee (3) non-crewmembers (commonly referred to as supernumeraries) that meet the requirements of §121.583 in an area af t of the cockpit and forward of the 9G bulkhead ("Supernumerary Ar ea") on Bombardier CRJ200 freighters to attend to special cargo. This request is substantially si milar to the requests gran ted to other freighter conversion STC holders, see e.g. Exemption 9487.

The petitioner requests relief from the following regulations:

§25.785(j), Amendment 25-88, requires th ere to be a firm handgrip or rail for persons using the aisles during moderately rough flight. The exempt ion from §25.785(j) is ne cessary as hand holds

are not available in this area.

§25.812(e), Amendment 25-116, requires floor proxi mity emergency escape path lighting. The exemption from §25.812(e) will allow trained supernumeraries to occupy the Supernumerary Area during taxi, ta keoff, flight, and landing. This area is in the immediate proximity of the forward emergency exits. Si nce the supernumerarie s will be trained on emergency procedures, including emergency egress, and will be located immediately adjacent to the exits, the lack of additional light ing will not adversely affect safety.

§25.855(a), Amendment 25-116, requires that cargo co mpartments must meet one of the class requirements of § 25.857. AEI's conversion results in the main deck being classified as a Class E cargo compartment. Exemption from 14 CFR 25.855( a) is requested as this FAR requires any cargo compartment to comply with a designate d classification of 25.857 which would exclude the carriage of supernum eraries in the area forward of the 9G bulkhead. The 9G bulkhead also

functions as a smoke barrier between the main cargo compartment and the Supernumerary Area and cockpit.David M. McDonald

VP, General Counsel

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 §25.857(e), Amendment 25-93, defines the attribut es of a Class E cargo compartment, and mandates that a Class E cargo compartment may not be on any airplane othe r than one utilized exclusively for the carriag e of cargo. The exemption from 25.857( e) will allow for up to three (3) supernumeraries on the aircraft who are otherwis e prohibited from being present on an aircraft with a Class E cargo compartment.

§25.1447(c)(1), Amendment 25-116, requires, in pert inent part, that oxyg en masks must be immediately available to each seated occupant , be automatically deployed with manual backup, and exceed in number the quantity of seats by ten percent, with the extra units distributed evenly throughout the cabin. The exemption from 25.1447(c )(1) will mandate an equivalent level of safety for supernumeraries in the Supernumerar y Area by requiring portable oxygen bottles that will be mounted within reach of the supernumerarie s while in their seats. These bottles will meet the requirements of 25.1447(c)(1), excluding the re quirement that the number of oxygen units must exceed the number of seats by at least ten percent. Since the supernumeraries will be trained in emergency procedures and will be within reach of a portable oxygen bottle at all times, an equivalent level of safety is maintained without having an additional 10% supply cushion. All features of the Class E cargo compartmen t required by §25.855 and §25.857 will be retained and all safety requirements of part 25 as defined by the certification basis of the airplane in Type Certificate Data Sheet (TCDS) A16WE will be complied with.

§25.1449 requires the pilots be able to determin e there is oxygen bei ng delivered to the dispensing unit. To the extent that §25.1449 require s the crew to be able to determine if oxygen is being provided to the portabl e bottles being utilized by the s upernumeraries, AEI also seeks exemption from compliance with this FAR as it is technically and commercially infeasible to comply with the requirements of §25.1449

Related regulations:

Section 121.285 provides requirements pertaining to the carriage of cargo in passenger

compartments.

Section 121.310 requires, in pertinent part, emergency escape means in accordance with §25.809(f)(1), emergency exit markings and sign s, emergency lighting in accordance with §25.812, and passageways and accesses to emergency exits.

Section 121.317 provides requirements for “No Sm oking” and “Fasten Seat Belts” signs in accordance with § 25.791 and “No Smoking” placards in accordance with § 25.1541.

Section 121.583(a) contains a list ing of categories of the people who may be carried aboard an airplane in part 121 service without complying with all th e passenger-carrying airplane requirements of part 121.David M. McDonald

VP, General Counsel

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 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 has applied for a Supplemental Type certificate for the reconfiguration of the Bombardier CRJ200 from passenger configuration to cargo configuration, including the installatio n of a large cargo door and a Class E main deck cargo compartment. Over 200 aircraft have been converted by AEI to freighters. Some opera tors of AEI freighters need to be able to carry supernumeraries to assist with special cargo such a valuable cargo requiring security and/or perishable, fragile, or li ve cargo requiring special attention to ensure its safe delivery. The interest of the petitioner is in providing a level of safety for the crew, supernumeraries, cargo and aircraft that will allow operators of AEI converted CRJ200 freighters

to meet the needs of their clientele.

The FAA approved Aircraft Flight Manual (AFM) will contain a supplement with the operating limitation restricting the carri age of occupants accommodate d to those defined by §121.583 who have been trained for such duties. In addition, an FAA approved training plan will be initiated to instruct the supernumeraries in the prohibition against smoking, a nd procedures in equipment use relating to fire suppression, ditc hing, and emergency evacuation.

The Supernumerary Area will meet the following safety requirements: An automatically activated decompression si gnal immediately recogni zable throughout the supernumerary area will be provided to automa tically notify supernumeraries when to don oxygen. Flight crew activated, lighted, “Fasten Seat Belt” signs will be provided and located so as to be visible to the supernumeraries while seat ed. In addition, flight cr ew activated ‘Return to Seat’ signage will be provided in the Supernumer ary Area. A standard aircraft intercom/public address (PA) system will be retained and the PA system will be audible within the Supernumerary Area. Two-way communication from th e supernumerary seating area to the flight deck will be provided by means of a flight phone installed within reach of at least one of the supernumerary seats. Finally, th e following placards will be provided: 1. No Smoking Signs; 2. Door Operating Instructions; a nd, 3. External Door Exit Marking.

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 public 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 exemp tions will enhance the u tility of the aircraft, thereby helping to reduce shipping costs, which will in turn be in th e public interest.David M. McDonald

VP, General Counsel

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 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.

Best Regards.

Sincerely,

David M. McDonald VP, General Counsel