March 22, 2010

Mr. Clint Jones or Mr. Phil Ford

Federal Aviation Administration

Transport Aircraft Directorate, ANM-1 00

1601 Lind Avenue, SW

Renton, WA 98057-3356

SA 1078NE Single AC Config

PETITION FOR EXEMPTION

The Leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder of

SA1078NE requests FAR compliance relief and submits this Petition for Exemption (PIE) to FAA

rulemaking established under 14 CFR Sect. 26.47(c) & (e)(2).

LEG petitions the US Government for engineering task relief on a Single Configuration of

SA1078NE for (1) 8737-200 aircraft, SN 22600 with LEG/pats Auxiliary Fuel System (AFS) in VIP

LOPA Configuration.

8737-200 (Reg. HZ-MIS) is operated in private VIP service by Arabasco_

1. This SN contains a VIP stateroom and is configured for HOS service.

2. This SN operates exclusively in private service.

3. This SN is listed only on "HZ" foreign registry.

4. This SN will require extensive engineering changes for a deck plan (LOPA) to be

suitable for EASA or US commercial revenue service under FAR 121 (125 or 135).

5. Responsive engineering resources of the FAA can be conserved and financial relief to

the US Govt. can be realized on behalf of the DAH; upon timely approval of this PIE.

6. Air safety will not be adversely impacted given the Operators attention to FAR

compliance with a limited VIP flight operation.

In the event this SN is transferred to a third party and an interior reconfiguration (LOPA) is

completed, a current airframe survey to include #4 changes can be reviewed and specific

airframe load and inspection analysis (DTE I DTI) due FAA under the Aging Aircraft Safety Rule

for the AFS (and the attach points) can be completed in accordance with FAR 26.47(c) and (e)(2)_

Sincerely, n

THJ!LING IE GROUP,LLC

Capt. K~ n g, Managing Director

AirSpe..... ----~

CotporqteOffice 3425 Gmf/on Point- Kitk/lm4 0/Qs!lingtvl} 98033 Main (425) 576-4030
FAA-lO(O - 03q.q

ASE 100325-16 FRPE

PUBUC COMMENT

www.airspeed.us.com

March 25, 2010

Federal Register Petition for Exemption submittal for public comment:

The Leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder

of SA1078NE requests FAR compliance relief and submits this Petition for Exemption

(P/E) to FAA rule making established under 14 CFR Sect. 26.47(c) & (e)(2).

LEG petitions for US Govt engineering task relief on a single tank Configuration of

SA107SNE for B737-200 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP

passenger cabin (LOPA) deck plans.

Boeing SNs 22600:

1. This SN contains a VIP stateroom and is configured for HOS service.

2. This SN operates exclusively in private or Head of State (HOS) service.

3. This SN is listed on foreign Registry.

4. This SN will require extensive engineering changes for a deck plan (LOPA) to

be suitable for EASA or US commercial revenue service under FAR 12l.

5. Responsive engineering resources of the FAA can be conserved and financial

relief can be realized on behalf of the DAH and US Government; upon timely

approval of this PIE.

6. The Operator nor STC holder are not able to determine if modifications to the

AFS loading points on this airframe have been altered, AFS brackets removed or,

if the AFS attach points have been adapted for other purposes; requiring in

themselves new ICAs.

7. Operator disclosure and DAH-onboard AFS survey of the aircraft is required to

submit useful engineering to FAA that is relevant to SN existing condition.

S. It is the position of the STC holder that air safety will not be adversely

impacted given this SN has limited private use and with over 3D-years of

airframe age, will likely never return to commercial FAA/EASA air carrier service.

In the event this SN is transferred to a third party and an interior reconfiguration (LOPA)

is completed, a current airframe survey to include #6 changes can be reviewed and

specific airframe load and inspection analysis (DTE / D11) due FAA under the 8glog

Aircraft Safety Rule for the AFS (and the attach points) can be completed in accordance

with FAR 26.47(c) and (e)(2).

Thank you.

Karl Seuring, Managing Director

The Leading Edge Group, LLC

Kirkland, WA 9S033

Corporate Of1ice 3425 Carillon Point Kitkl.md washington 9BO;ri Main (425) 576-4030