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AIR TRANSPORT INTERNATIONAL 

May2~,2013 

U.S. Department of Transportation 

Federal Aviation Administration 

Docket .Operations 

West Building Ground floor, Room WI2-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Attention: Transport Airplane Directorate 

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cc: Mr. Deke Abbott, Manager Air Transportation Division, AFS-220 

Ms. Jackie Clow, AFS 220 

Subject: 

References: 

Mr. Mark Lopez, AFS-330 

Ms. Andrea Copeland/FAA HQ 

Request for Exemption from F ARS for Combi Aircraft, dated October 23, 2012 

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Attachment 1: A TI Request for Exemption Letter dated October 23, 2012 

Attachment 2: ATI Request for Equivalent Level of Safety dated April25, 2013 

Attachment 3: B757-200 Combi layout , · · 

To Wh~m It may Concern: 

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This letter is to provide your office with additional information to clarify and support its letter dated October 23, · 1! : ! ! 

2012, subject; Request for Exemption from §121.313(f) of Title 14, Code ofFederal Regulations (See Attachment 1) 'i 

for our B757-200 combi operations. 

As part of our request for exemption, A TI previously submitted a letter to support its request based on an Equivalent 

Level of Safety, dated April25, 2013,to comply with the requirements of §l2l.313G),(l),(ii) of Title 14, Code of 

Federal Regulations (See Attachment 2) for our B757-200 combi operations. 

The following is additional information to support ATI's request based on an Equivalent Level of Safety to meet the 

requirements of§ 12 L313G),(l ),(ii): 

l. Cockpit Security for the B757-200 Combi Aircraft with the PEMCO STC consists of a hardened flight 

deck door as required by§§ 25.795 and 121.313 which separates the flight deck from the supernumerary 

compartment located immediately behind the flight deck (See attachment 1, Note l). Only authorized and 

approved personnel are allowed in the Supernumerary compartment during flight. No passengers are 

allowed in the Supernumerary compartment. 

2. There is no physical access for a person to go from the passenger compartment forward to the Class C 

cargo compartment, supernumerary compartment and flight deck, or vice versa. The bulkhead separating 

the passenger compartment from the Class C Cargo compartment is completely sealed off and inaccessible 

both in flight and on the ground (See attachment 2, Note 2). 

3. For all flights with passengers on board, if a flight attendant is not assigned to the cockpit/supernumerary 

compartment, there will be an additional flight crew member in the cockpit. The additional flight crew 

member, another pilot, will be trained and qualified to perform the following duties: 

a. Conducting emergency equipment checks. 

One Cantrell Center • 2800 Cantrell Road • Little Rock, Arkansas 72202 USA 

Phone: 501--615-3500 • www.airtransport.cc 

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b. Arming and disanning exits L 1 and R 1. 

c. Conducting required briefing of supernumeraries. 

d. Conducting frre-fighting procedures. 

e. Opening ofLl and Rl exits in nonnal and emergency situations. 

f. Assisting passengers post evacuation. 

g. Verifying door between cargo compartment and supernumerary compartment remains closed. 

h. Monitoring the cargo. 

i. In a medical emergency, the additional flight crew member will be able to administer first aid, if . 

required, in the supernumerary compartment and flight deck. All B757 Combi pilots will receive 

the Adult First Aid/ AED Training conducted by the American Red Cross and required to receive 

re-current training every 2 years. This is the same training required for a flight attendant. In the 

event that a flight crew member becomes incapacitated, the role of the additional flight crew 

member will be to remove the incapacitated flight crew member from his/her crew duty station, 

administer first aid, if required, and assume those duties/responsibilities required for safe 

operation ofthe flight. 

j. Provide communication to the cockpit in the event of a failed intercom. 

NOTE: Crew Duty limitation regulations and Fatigue Risk Management Program (FRMP) 

requirements will apply to the additional flight crew member. 

With this additional infonnation, A TI is confident that its proposal utilizing th.e additional flight crew 

member, as described, meets and exceeds the requirements of 14 CFR § 121.3 1 3G),(l ),(ii). A TI respectfully 

and urgently request timely approval of our request for an exemption based on the additional infonnation 

provided which provides an equivalent level of safety to comply with the requirements of this regulation. 

Should you require further infonnation or clarification, you can either contact me at ( 407) 257-1788, e~mail 

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dennis.manibusan@airtransport.cc or John Vestal, Vice President Flight Operations, at (407) 341~2018, e~ ·. 1 .. 

mail john.vestal@airtransport.cc. · 

Sincerely, 

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Dennis Manibusan 

President 

cc: J. VestaV ATI 

J. Sullivan/ ATI 

K. Sullivan/ATI 

D. Bucher/ATI 

LEricksoril A TI 

J. Weidner/FAA 

D. Forsberg/F AA 

D. Back/FAA 

B. Morrow/FAA 

A. Copeland/FAA 

One Cantrell Center • 2800 Cantrell Road • Little Rock, Arkansas 72202 USA 

Phone: 501-615-3500 • www.airtransport.cc 

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