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## AIR TRANSPORTINTERNATIONAL**May2~,2013** U.S. Department ofTransportation Federal Aviation Administration Docket.Operations West Building Ground floor, Room WI2-140 1200 New Jersey Avenue, SE Washington, DC 20590 Attention: TransportAirplane Directorate i; i**~ .~**  .l. d**~ ~~** 

cc: Mr. Deke Abbott, ManagerAirTransportation 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 ' Attachment 1: A TI Request for Exemption Letter dated October 23, 2012 Attachment 2: ATI Request for Equivalent Level ofSafety dated April25, 2013 Attachment 3: B757-200 Combi layout , · · To**Wh~m** It may Concern: 

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# II 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) ofTitle 14, Code ofFederal Regulations (See Attachment 1) 'i for ourB757-200 combi operations. As part ofour request for exemption, A 

## TI previously submitted a letterto support its request based on an Equivalent Level ofSafety, dated April25, 2013,to comply with the requirements of§l2l.313G),(l),(ii) ofTitle 14, Code of Federal Regulations (See Attachment 2) for ourB757-200 combi operations. The following is additional information to supportATI's requestbased on an Equivalent Level ofSafety to meetthe requirements of§12L313G),(l),(ii): l. Cockpit Security for the B757-200 Combi Aircraft with the PEMCO STC consists ofa 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 compartmentand flight deck, or vice versa. The bulkhead separating the passenger compartment from the Class C Cargo compartment is completely sealed offand inaccessible both in flight and on the ground (See attachment 2, Note 2). 3. For all flights with passengers on board, ifa flight attendant is not assignedto 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 equipmentchecks.
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 1and R1.
c. Conducting required briefing ofsupernumeraries. 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 memberwill 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. Inthe eventthat a flight crew memberbecomes incapacitated, the role ofthe additional flight crew member will be to remove the incapacitated flight crew member from his/her crew duty station, administer first aid, ifrequired, and assume those duties/responsibilities required for safe operation ofthe flight. j. Provide communication to the cockpit in the event ofa failed intercom. NOTE: Crew Duty limitation regulations and Fatigue Risk ManagementProgram (FRMP) requirements will apply to the additional flight crew member. With this additional infonnation, A TI is confidentthat its proposal utilizing th.e additional flight crew member, as described, meets and exceeds the requirements of14 CFR §121.3 1 3G),(l),(ii). A TI respectfully and urgently request timely approval ofourrequest for an exemption based on the additional infonnation provided which provides an equivalent level ofsafety to comply with the requirements ofthis regulation. Should you require further infonnation or clarification, you 

### can either contactme at (407) 257-1788,**e~mail** 

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dennis.manibusan@airtransport.cc orJohn Vestal, Vice PresidentFlight Operations, at (407)**341~2018, e~**  ·. 1 .. mail john.vestal@airtransport.cc. · Sincerely,

# ·~~ Dennis Manibusan President
cc: J. VestaV ATI J. Sullivan/ ATI K. Sullivan/ATI D. Bucher/ATI LEricksorilATI 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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