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RECEIVED 

APR 2 e Z01Q Jl V ^ ASW-150 

«iW^99mL f*irp\tm Gerffl cation 

April 23. 2010 

Ms. Monica Merritt 

DOT/FAA ASW-150 

2601 Meacham Boulevard 

Fort Worth, TX 76137-0150 

Dear Ms. Kerritt; 

Enclosed is a copy of our petition, to delete or modify certain 

requirenifsnts of FAR 23.1001 "Fuel Jettisoning System". The 

Petition is dated February 8, 2010 and we have not heard from 

the FAA on this request. 

We have recently received an overseas order for 10 AT-802s to 

be used in the Patrolling configuration. The first of these 

planes is already i n our production line, and delivery is promised 

in this coming June. There are substantial penalties that must 

be paid if we are late with our delivery promise. 

It is in the public interest, to grant this petition for these 

reasons: 

1, This order brings more jobs to American workers producing 

raw materials, propellers, inslruments, hardware, and many other 

components that go into the manufacture of an airplane. 

2, This lO-plane order helps our trade imbalance with other 

countries -

3, This order will help a nation friendly to America to maintain 

border security. 

The country ordering the AT~802Us requires the fuselage fuel 

tank because it allov/s flights of more than 10 hours. The Jettison feature is to be used only in an emergency such as engine 

failure, so that the airplane i.5 as light as possible. 

In agricultural operations, our flight manual calls for dumping 

hopper contents in case of engine failureWe would appreciat.6 it if you would help us gain approval for 

our petition, and the sooner the better. 1/^-^DT)^ ! 

I • i;.r),iru-Mi:>nf1'.TiC.>:. .^SW-Mif 

Sincerely, 1 .-vpiirovni • 

. - / „ / //••...i, 

^_.'' ' ." , • •"'••I ' I - I •' '•• < 

Lelan d Snow 

t iiri'Mt-rn. vr r,.iir~ti 

l-:!iDiniXf'!''>l<M li>i«tc 
tm/^t5/'^uj.a it:j i oioj^nticj o 3«u rHtat uj/a t 

A I R TRACTO R INC . • P. O. flOXJieS • OINET, TEXAS 7437^ 

9J10-564-5616 • 9.1€-S6<-S61I (FAX) 

February 8, 2010 

Federal Aviation Administration 

Department of Transportation, ASW-150 

2601 Meacham Boulevard 

Fort Worth, TX 76137-0150 

Attention: Ms, Monica Merritt 

Gentlemen: 

This letter is Air Tractor's petition to make certain modifications 

or deletions from the requirements of FAR 23.1001 "Fuel Jettisoning 

System". These requirements are the result of incorporating a 

fuel tank in the AT-B02/802A fuselage to allow extended periods 

of loiter when the airworthiness certificate has been issued for 

the special purposes of Aerial Surveying and Patrolling. The 

fuselage fuel tank is also necessary for transAtlantic delivery 

flights to customers. 

The FARs that we are petitioning to modify for the above aircraft 

are 2 3.1001(b) where it says "must be demonstrated at maximum 

weight"-

Air Tractor petitions to demonstrate fuel jettison nt a gross 

weight of 13,000 lbs or more since the absen.'se of hoppers removes 

space to add the 3,000 povinfls 0£ liallaFil- rpqni rr-fd i^o bring tho 

AT-802 test aircraft up to its certificated weight of 16,000 pounds. 

Tlie FARs that we are petitioning to delete are 23.1001(c)(2) and 

33,1001 (c) (3). We also petition to use water with dye for tests. 

Reasons for deletion of the.'SG 2 FARs: 

The wing angle of incidence and the higlily camberojd airfoil caiifie 

the AT-802/F102A to fly in a tail-high position, which provides 

good visibility for the pilot. Rut tail-high flight results in 

B low pressure area under the fuselage. The enclo;>ed phoLo of 

an AT-802 releacjing fire retardant show;.;; that while most of the 

retardii,nt drops clcrir of the aircraft, tlv.;!re are. some wisp.? that 

impinge on the aft p<u't of the belly. 

It is posj-ibJe tliat small clropIetiK of fuel vjould enter tlie f:ui;alnq< 

tlirougli the Kitial]. openings for rudder control cables nr the 

openingr around the fuselage structure for corrosion prevention. 
Page 2 

February B, 2010 

The cockpits in the Ar-J502/G02A aircraft are sealed off from the 

rest of the fuselage but it is possible for the crew to detect 

the smell of fuel in case small amounts of fuel enter the fuselageFor environmental reasons as well as conservation of our resources. 

Air Tractor petitions to use water with a red dye instead of Jet 

fuel. The test aircraft is painted gray, so that the red dye will 

be visible to trace the path of the water during jettisoning. 

Reasons why Air Tractor's petition should be granted; 

1. The AT-802 is a 2-seat restricted category aircraft with no 

passenger carrying authority. It is for the special purposes 

listed in FAR 21.25 to include 21-25{b)(3) and 21.25(b) (4). For 

these purposes the aircraft must have .long loiter time foi' border 

patrol or other surveillance activities. It's basic configuration 

cannot be altered to meet FAKs for which we are seeking relief. 

2. The ,fire risk from fuel impingement on the fuselage is negligible due to there being more than ten feet of distance between 

the exhaust stacks and the discharge' port of the fuel jettison 

system. 

3. The F.AA approved airplane flight manual lists several instructions to dump the hopper contents in the Emergency Procedures 

section. It also lists dumping the ferry fuel in the hopper in 

the ditching procedures. These AFW pages are enclosed. 

AM The hopper jettison feature provides more- safety for flight 

over mountainous terrain where sxiitable landing sites are not 

available, A lowered landing speed resulting from jettisoning 

the hopper fuel lowers the.airplane stall speed, improving the 

odds of surviving a crash. 

5. We believe that the fuel jettisoning requirements were aimed 

at large,transport, airplanes with an emergency landing requirement 

and not for smaller restricted category airplanes not carrying 

passengers for hire. 

6, The trans Atlantic delivery flight to overseas customers is 

ffiade more safe because in case of engine failure over water, the 

•fuselage fuel can be jettisoned and the jetti..^on valve closed 

?.o that the tank can be used to create .more bouyancy and. help 

prevent the aircraft, from sinking. 

'.Details of the fvjol jettisoning system are shown on the enclosed 

drav;ing 52940, \^c hope the FA/\ will give consideration to our 

viewpointsSincerely, .,-. 

Lelan d .<3now 

rresident , Air Tractor , Inc . 

Hnc.l.oBures: I)rr.iwing 52940, A'r-802 ;vFM page s