9525 Vassar Ave., Chatsworth, CA 91311  Ph. 818-718-2195  Fax 818-718-2212  email: integrity@SIEinc.com 

July 20, 2012

Structural Integrity Engineering 

9525 Vassar Ave., 

Chatsworth, CA 91311 

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: FAA Project ST14145LA-T 

Under the subject FAA project, Structural Integrity Engineering (SIE) has been appointed as the acting 

agent for the applicant, ORBIS International, to obtain a one time STC to reconfigure an MD-10-30F 

Freighter to transport Modular Hospitals loaded on Pallets. The Modular Hospitals will be deployed in 

support of ORBIS International's efforts to improve eye care throughout the developing world. In 

support of this project, SIE is requesting a partial grant of exemption from the requirements of certain 

14 CFR Part 25 regulations for this aircraft. 

As part of the STC application process, SIE has identified, and reviewed with the FAA, the Title 14, 

Code of Federal Regulations relevant to this effort. These are contained in the Project Specific 

Certification Plan (PSCP), SIE report SIE-400-101 (currently at Rev. B). 

The Flying Eye Hospital (FEH) is a teaching hospital that allows people in the forward cabin, the 

"classroom", to follow operations with the help of audio-visual equipment. The existing 9G restraint 

location will be placed further aft at approximately FS 758 to allow for the classroom to double as a 

supernumerary area. The total number of seats installed in the supernumerary area will be forty seven 

(47), which includes one (1) flight attendant station in the forward galley area and the remaining forty

six (46) seats will be passenger type seating in the classroom. These crew members will be in addition 

to the two (2) flight crew and two (2) observers located in the cockpit for a total of fifty-one (51) 

occupants on board. The supernumeraries will be ORBIS employees including volunteer faculty and 

sub contractors to: 1) Accompany the hospital on each mission to perform set-up/take-down duties and 

ensure safe and secure handling of medical equipment and materials in accordance with FAR 125.331; 

and 2) Support hospital operations including in-country screening and training. The supernumerary 
9525 Vassar Ave., Chatsworth, CA 91311  Ph. 818-718-2195  Fax 818-718-2212  email: integrity@SIEinc.com 

seats and equipment will be equivalent to a passenger interior except that egress is provided through 

just one door on each side (L1 and R1). The doors will be equipped with standard slides/rafts with a 

capacity of forty six (46) per side and an additional life raft for five (5) to meet the requirements of 

25.1415(b)(1) Amdmt 82 (latest). The existing Class E main deck cargo compartment will be retained 

aft of the new location of the 9G barrier at approximately FS 758. The main deck cargo compartment 

is not occupied during flight; however, it is an “accessible Class E cargo compartment” for the purpose

of fire fighting. 

This petition is presented for relief to the requirements of the following sections of the 14 CFR Part 25 

regulations for the MD-10-30F aircraft being reconfigured for the teaching hospital mission. 

1 - §25.857 amendment 25-93, Sub paragraph (e) and (e)(3). Sub paragraph (e) defines a class E cargo 

compartment as one used only for the carriage of cargo. Sub paragraph (e)(3) requires a means to shut 

off the ventilating airflow to, or within the compartment. 

2 - §25.807 amendment 114, Sub paragraph (f)(2), (g)(5) Sub paragraph (f) deals with the location of 

the exits. Sub paragraph (f)(2) requires that floor-level exits must be in the rearward part of the 

passenger compartment unless another location affords a more effective means of passenger 

evacuation. Sub paragraph (g) defines the type and number of doors required and (g)(5) requires two 

doors per side for cabins with 41 to 110 seats. 

Supporting Information - Section Requirements 

1 - §25.857 Cargo Compartment classification, amendment 25-93, Sub paragraph (e) and (e)(3)

Paragraph (e) defines a Class E cargo compartment as one on airplanes used only for the 

carriage of cargo. As stated earlier in the discussion on page one of this petition, the ORBIS teaching 

hospital requires forty seven (46) supernumeraries for its operation beyond the one flight attendant 

station, two flight crew, and two observers.

The DC-10 certification (see TCDS Page 38) includes Exemption Number 2453 issued 

September 26, 1977 an exemption from §25.807(c)(1) to “permit evacuation of passengers with one 

oversize Type I emergency exit meeting the conditions specified in Exemption No. 1573 on each side 

of the fuselage with a passenger seating capacity of 50.”

The FAA has previously granted Exemption 6652, issued June 26, 1997 to Federal Express. 

This Exemption allows for the carriage of up to 24 supernumeraries inside a Class E Cargo 

Compartment on DC-10 aircraft. In addition, Exemption 6873 is part of the MD-10 certification basis. 

This exemption allows the carriage of an additional four (4) supernumeraries in front of the 9G Barrier. 

The total supernumeraries allowed on the MD-10 aircraft is, therefore 28. In granting the Exemption 
9525 Vassar Ave., Chatsworth, CA 91311  Ph. 818-718-2195  Fax 818-718-2212  email: integrity@SIEinc.com 

6652, the FAA nonetheless expressed a concern about “a trend toward proposals for rather more 

ambitious accommodations.” This refers back to a lack of intent towards “large numbers of 

supernumeraries” in 121.583. The current proposal does indeed request a “large” number of 

supernumeraries. This large number is acceptable, in this case only, because it is limited to: 1) Part 125 

Operations instead of Part 121; and 2) Carriage of Mobile Hospitals. The first condition precludes the 

commercial use of the exemption and the second condition includes a very specific purpose. This 

purpose while obviously different in nature, is just as specific as the previously allowed horse carriage.

Paragraph 25.857(e)(3) requires the air supply to the Class E compartment to be shut off in case of fire. 

This feature remains active on the current aircraft. However, the means of fighting a fire per the 

Airplane Flight Manual will be changed from decompression procedures to crew fire fighting. We will 

request an equivalent level of safety finding for the specific crew firefighting procedure. The crew 

firefighting is preferred for this application, because: 1) The modular hospital cargo is, by its nature 

accessible (and will be required to be accessible in the operational manuals); and 2) Flare-up of a fire in 

descend when the decompression method is no longer available is eliminated as a risk factor. 

Furthermore, the crew will not be exposed to prolonged operation at low atmospheric pressure during a 

fire event.

2 - §25.807 Emergency exits, amendment 25-114, Sub paragraph (f)(2), (g)(5)

 This regulation defines the number, location, and type of emergency exits required for various 

passenger quantities. The aircraft has a single door per side where two would be required for passenger 

operation (g)(5). The doors are located at the front of the supernumerary area where (f)(2) expresses a 

strong preference for an aft location for passenger operation. 

The existing L1 and R1 doors, which have an opening of 32”X76”, meet the requirements of a 

Type B door. Type B doors are qualified for a maximum number of seventy five (75) passenger seats 

per pair (left/right). This number is more than 50% larger than the number of supernumeraries. 

FAA has previously addressed egress issues for combi airplanes with only one pair of exits for 

passenger egress in Policy Number PS-ANM100-1987-00033, dated 11/02/1987. This Policy identifies 

and approves a maximum capacity of fifty passengers for the oversize Type I (a Type B) door available 

on the aircraft. The Exemption 2453, part of the Certification Basis of the aircraft is consistent with 

this policy. The number allowed exceeds the requested number of supernumeraries.

Information to Support Grant of Exemption: 

Per the provisions of 14 CFR Part 125.331 (Carriage of persons without compliance with the 

passenger-carrying requirements of this part), a minimum of two supernumeraries will have 

special training in the use of emergency equipment, emergency egress, and flight operations 

associated with controlling a fire in an accessible Class E compartment.

The supernumerary seating will be provided using seating, emergency egress provisions and 
9525 Vassar Ave., Chatsworth, CA 91311  Ph. 818-718-2195  Fax 818-718-2212  email: integrity@SIEinc.com 

emergency oxygen systems from a decommissioned DC-10 passenger aircraft as part of the STC 

project. The supernumerary compartment will have been outfitted with liners, overhead bins and 

galleys prior to STC from the same decommissioned DC-10 aircraft. Therefore, this compartment 

will meet the flammability requirements per the DC-10 TCDS.

A placard indicating that the door in the 9g rigid barrier is to be closed at all times during flight, except 

to gain access in an emergency fire fighting condition, will be located in a conspicuous place on or next 

to the smoke barrier. The safety of the crew members entering the cargo hold for the fire-fighting role 

is ensured with protective clothing and a breathing apparatus. These crew members have helmet 

mounted lights to supplement the ambient lighting provided in the hold.

The historical deployment schedule of the Flying Eye Hospital calls for three-week deployments. The 

extended on-ground time for deployment causes the number of flights and flight hours to be much 

lower than a normal passenger or freighter operation. The expected number of flights over 20 years of 

operations is about equal to the number of flights per year during the aircraft's use as a FEDEX 

freighter.

Evaluation of Public Interest: 

The availability of an Airborne Hospital that can be rapidly deployed to any location in the world is in 

the public interest. The specific purpose of this particular Airborne Hospital is to cure blindness 

worldwide. This is also in the public interest.

Petition for Exemption: 

SIE requests authorization to carry 47 supernumeraries, in accordance with the provisions of 14 CFR 

Part 125.331 Carriage of persons without compliance with the passenger-carrying provisions of this 

part. In consideration of the foregoing discussion, SIE petitions for exemption from the following 14 

CFR Part 25 regulations for the ORBIS reconfigured MD-10-30F aircraft undergoing reconfiguration 

by FAA project ST14145LA-T.

1 - 25.857 amendment 25-93, Sub paragraph (e) and (e)(3), 

 (e) Forty seven (47) supernumeraries in addition to the two flight deck crew members and 

two observers may be carried.

 (e)(3) The air supply will be shut off, but the aircraft will not be decompressed for fire 

abatement.

2 - 25.807 Emergency exits, amendment 25-114, Sub paragraph (f)(2) and (g)(5)

 (f)(2) The single emergency exit doors 1L and 1R are located at the forward end of the 

supernumerary seating compartment.

 (g)(5) A single door per side (Type B Doors 1L and 1R) will be available for emergency egress 

for no more than fifty (50) supernumeraries. 
9525 Vassar Ave., Chatsworth, CA 91311  Ph. 818-718-2195  Fax 818-718-2212  email: integrity@SIEinc.com 

The applicant would like the public comment phase to be eliminated from the Exemption process, 

because there is no industry-wide effect from a grant of exemption for this unique purpose. 

Structural Integrity Engineering respectfully requests the FAA consideration of the foregoing petition. 

Additionally, we ask that the FAA Los Angeles ACO perform coordination necessary to obtain FAA 

concurrence and advisement for this petition.

Yours sincerely, 

Willem Kernkamp 

Structural Integrity Engineering 

9525 Vassar Ave., 

Chatsworth, CA 91311 

Tel: 818-718-2195 #106 

E-mail: wkernkamp@sieinc.com