October 23 , 2012

U.S. Department of Transportation Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

Attention Transport Airplane Directorate

RE: Request for Exemption f rom FARs f or Comb i Aircraft

To Whom It May Concern,

Air Transport International Inc. ( ATI ) seeks exemption from certain Federal Aviation Regulations (FAR ’s ) pursuant to 14 CFR Part 11. Specifically, ATI seeks an exemption from § 121.313(f) of t itle 14, Code of Federal Re gulations, to allow operation of 757 aircraft configured for combined cargo and passenger carriage (commonly known as “combi” aircraft) where the pilot compartment and the passenger compartment are not conti guous but separated by a class C cargo compartmen t

.

The petitioner requests relief from the following regulations:

§ 1 2 1

. 313 ( f ) Amendment 121

- 353 , requires there to be “ a door between the passenger and pilot compartments (i.e., flightdeck door), with a locking means to prevent passengers from opening it without the pilot's permission”

. The exemption from § 121

. 313 ( f ) is necessary because the passenger compartment and the pilot

compartment a re widely separated by a class C cargo compartment on 757 combi

aircraft

. No door is possible directly between th e pilot compartment and the passenger compartment. In addition n o personnel entry is allowed in to the class C

compartment inflight

, by aircraft type certificate limitations.Related regulations:

§121.313(j)(1)(i) Amendment 121

- 353, requires that flightd eck doors meet the rquirements of §25.795(a)(1) and §25.795(a)(2).

§121.313(j)(1)(ii) Amendment 121

- 353, Requires the operator to establish methods to enable a flight attendant to enter the pilot compartment in the event that a flightcrew member becomes incapacitated.

§121.582 Amendment 121

- 353, requires a “ Means to discreetly notify a flightcrew.”

§121.583 Amendment 121

- 96, concerns “ Carriage of persons without compliance with the passenger

- carrying requirements of this part. ”

§121.584 Amendment 121

- 334, outlines “ Requirement to view the area outside the flightdeck door.”

§121.587 No amendment Number, to ensure “Closing and locking of flightcrew compartment door.”

§25.795(a)(1) Amendment 25

- 127, requires that the “boundary separating the flightcrew compartment from occupied areas” must meet certain minimum forcible intrusion requirements.

§25.795(a)(2) Amendment 25

- 127, requires that the “boundary separating the flightcrew compartment from any occupied areas” must meet certain minimum

“tensile load” requirements on “accessible handholds”.

The petitioner supports its request with the following information:

Supplemental Type Certificates for modification of Boeing 75 7

- 200 aircraft to a combi configuration have a c lass C main deck cargo compartment se parating the pilot compartmen t and the passenger compartment

. Because t he class C compartment is over 7 0 feet in length, tightly packed with containers or palletized cargo, and not enterable inflight by AFM limitation, no door between the passenger

compar tment and the pilot compartment is possible. With regard to this petition,

ATI wishes to operate 7 5 7

- 200 aircraft converted to combi configuration in support of US Department of Defense worldwide operations. The interest of the petitioner is in providing a level of safety and security for the crew

, passengers and cargo t hatwill allow operation of converted 75 7 combi aircraft to meet the needs of ATI’s operations and clientele. To meet the security requirements implicit in §121.313(f), §121.313(j), and §2 5.795(a) each combi aircraft operated by ATI will have multiple barriers between the pilot compartment and the passenger compartment at least one of which will be certified to the requirements of §25.795(a)(1) and §25.795(a)(2).

The flight attendant assi stance requirements of §121.313(j)(1)(ii) are not possible in the Combi aircraft for which this exemption is requested. ATI will maintain equivalent safety by requiring that for all revenue operations where passengers are

carried

, there will be at least three ATI personnel in the cockpit or adjacent compartment. These personnel will consist of two required flight crew and one or more personnel allowed under §121.583. The cockpit or adjacent compartment will be equipped with emergency medical equipment i n accordance with § 121.803 and at all times during revenue operations with passengers

, at least one of the non

flightcrew personnel will be trained in the use of the emergency medical equipment per the requirements of §121.805.

§121.582 compliance will b e maintained procedurally using multiple redundant communication systems between the passenger compartment and the pilot

compartment. This is the same method used on passenger aircraft.

§121.587 compliance is either not applicable or will be maintained. No currently available combi has a door that can be opened from the passenger side of the smoke barrier between the class C compartment a nd the passenger compartment. N ormal

traffic is then not possible. However one of the two configurat ions available t o ATI

has the 25 .795 barrier at the pilot compartment bulkhead as in a passenger aircraft

. In that configuration the smoke barrier between the passenger compartment and the

cargo compartment has no door but is not secure. On those aircraft the existing

2 5 .795 barrier wil l be locked inflight. §121. 584 compliance will be provided and

maintained. The other configuration has a 25.795 barrier between the passenger compartment and the class C cargo compartment. The door in that barrier must be closed infligh t, and has no provisions for opening from the passenger side

, so neither §121.587 or§121.584 is applicable.

All other aircraft and operating requirements except those specifically dependent on the §121.313(f) requirement for a cockpit door will remain in e ffect.

Request for Waiver of Public CommentATI requests waiver of the normal public commen t process since this request is

limited in scope and intent and because the granting of this petition will not create new precedent.

Evaluation of Public Interest

The use of modern, fuel efficient 757 combi aircraft in support of the worldwide operations of the United States Department of Defense is directly in the public

interest. Continued operation of older, less reliable, and much less fuel efficient

DC8 comb i aircraft currently supporting those operations compromises ATI’s ability to provide the level of service deserved by the customer, wastes non

- renewable energy resources, and increases greenhouse gas emissions.

Petition for Exemption

Based on the inform ation provided, Air Transport International, Inc. , hereby petitions for exemption from the following p ortions of 14 CFR Part 1 2 1 for 75 7

- 200 passenger airplanes converted to combi configuration:

• § 121.313 ( f ), Amendment 1 2 1

- 353

Air Transport International, Inc. respectfully requests favorable FAA consideration

of this Petition

. I can be contacted at (407) 812

- 1691.

Regards

,

Ed Shockley

Director of Technical Services