### AIR TRANSPORTINTERNATIONAL
May9,2013
U.S. Department ofTransportation Federal Aviation Administration Docket Operations**WestB~ilding** Ground floor, Room Wl2-140 1200 New Jersey Avenue, SE Washington, DC 20590
Attention:

Subject:
References: Transport Airplane Directorate

cc: Mr. Deke Abbott, Manager Air Transportation Division, AFS-220 Ms. Jackie Clow, AFS 220 Mr. Mark Lopez, AFS-330
Withdrawal- Request for Exemption from FARS 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 Whom It may Concern:
This letter is to notifY your office that Air Transport International, Inc. (ATn is withdrawing its letter dated October 23, 2012, subject, Request for Exemption from §121.313{f)ofTitle 14, Code ofFederal Regulations (See Attachment 1) for our B757-200 combi operations.
In lieu ofan exemption, A TI has submitted 

### a request for an Equivalent Level ofSafety, dated April 25, 2013, to comply with the requirements of§121313(j),(l),(ii) ofTitle**14~** Code ofFederal Regulations (See Attachment 2) for our B757-200 combi operations.
The following is additional information to supportA Tl's request for Equivalent Level ofSafety to meet the requirements of§121.313(j),(l),{ii):
1. Cockpit Security for the B757-200 Combi Aircraft with the P:EMCO 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 1). 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 eompletely 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 assigned to the cockpit/supernumerary compartment, there will be an additional flight crew member and a flight mechanic in the cockpit. The additional flight crew member, assisted by the flight mechanic, is trained and qualified to perform the following duties: ·

a. Conducting emergency equipment checks. ' ' l {;i ,j·- ' ,, I

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1. /1 ,,b. Arming and disarming exits Ll and Rl.

c. Conducting required briefing of**superrtum~raries.** d. Conducting fire-fighting procedures.

e. Opening ofL1 and Rl exits in normal and emergency situations.
f. Assisting passengers post evacuation.
g. Verifying dodr between cargo compartment and supernumerary compartment remains closed.
h. Monitoring the cargo. 'i. In a medical emergency, the flight mechanic will assist the additional flight crew member and can administer first aid, ifrequired, in the supernumerary compartment and flight deck. All flight mechanics have received 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 ofthe additional flight crew member will be to remove the incapacitated flight crew member from his/her crew duty station and assume those duties/responsibilities required'for safe operation ofthe flight. The flight mechanic, ifrequired, will administer first aid to the incapacitated flight crew member. j. Provide communication to the cockpit in the event ofa failed intercom. In the event the additional flight crew member assumes flight crew duties due to an incapacitated flight crew member, the flight mechanic will assist the flight crew in communications between the cockpit, the supernumerary compartmentand the cabin.
NOTE: Crew Duty limitations apply only to the additional flight crew member. The role ofthe flight mechanic is to assist the additional flight crew member as required.
With this additional information, A TI is confident that its proposal utilizing the "additionalflight crew member and flight mechanic team" as described, meets and exceeds the requirements of 14 CFR §121.3130),(1 },(ii). A TI respectfully and urgently request timely approval ofthis request for an equivalent level ofsafety to'comply with the requirements ofthis regulation.
Should you require further information or clarification, you can either contact me at (407) 257-1788, e-mail dennis.manibusan@airlransport.ee orJohn Vestal, Vice President Flight Operations, at (407) 341-2018, emailjohn.w:sfal@airfransport.cc.

Dennis Manibusan President

cc: J. Vestal/ ATI J. Sullivan/ ATI K. Sullivan/ A

TI D. Bucher/ AT! J. Weidner/FAA D. Forsberg/FAA D. Back/FAA B. Morrow/ FAA



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### AIR TRANSPORT INTE.RNATIONAL

October 23, 2012

U.S. Department ofTransportation 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 from FARs for Combi 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(£) oftitle 14, Code ofFederal Regulations, to allow operation of757 aircraft configured for combined cargo and passenger carriage (commonly known as "combi" aircraft) where the pilot compartment and the passenger compartment are not contiguous but separated by a class C cargo compartment.


### The petitioner requests relief from the following regulations: §121.313(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(£) is necessary because the passenger compartment and the pilot compartment are widely separated by a class C cargo compartment on 757 combi aircraft. No door is possible directly between the pilot compartment and the passenger compartment. In addition no personnel entry is allowed into the class C compartment inflight, by aircraft type cetiificate limitations.

### ·-

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# I Related regulations: §121.313(j)(1)(i) Amendment 121-353, requires that flightdeck doors meet the rquirements of §25.795(a)(l) 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 ofpersons without compliance with the passenger-carrying requirements ofthis 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 offlightcrew 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 ofBoeing 757-200 aircraft to a combi configuration have a class C main deck cargo compartment separating the pilot compartment and the passenger compartment. Because the class C compartment is over 70 feet in length, tightly packed with containers or palletized cargo, and not enterable inflight by AFM limitation, no door between the passenger compartment and the pilot compartment is possible. With regard to this petition, ATI wishes to operate 757-200 aircraft convetied to combi configuration in support ofUS Department ofDefense worldwide operations. The interest ofthe petitioner is in providing a level ofsafety and security for the crew, passengers and cargo that·.



### will allow operation ofconverted 757 combi aircraft to meet the needs ofATI's operations and clientele. To meet the security requirements implicit in §121.313(f), § 121.3130), and §25.795(a) each combi aircraft operated by ATI will have multiple barriers between the pilot compartment and the passenger compartment at least one ofwhich will be certified to the requirements of §25.79S(a)(l) and §25.795(a)(2).
The flight attendant assistance requirements of § 121.3130)(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 oftwo required flight crew and one or more personnel allowed under §121.583. The cockpit or adjacent compartment will be equipped with emergency medical equipment in accordance with § 121.803 and at all times during revenue operations with passengers, at least one ofthe nonflightcrew personnel will be trained in the use ofthe emergency medical equipment per the requirements of §121.805. § 121.582 compliance will be 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 ofthe smoke batTier between the class C compartment and the passenger compartment. Normal traffic is then not possible. However one ofthe two configurations available to 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 25.795 barrier will 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 batTier must be closed inflight, and has no provisions for opening from the passenger side, so neither§l21.587 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 effect. 

### Request for Waiver ofPublic Comment

### ATI requests waiver ofthe normal public comment process since this request is limited 

### in scope and intent and because the granting ofthis petition will not create new precedent.
Evaluation ofPublic Interest


### The use ofmodem, fuel efficient 757 combi aircraft in support ofthe worldwide operations ofthe United States Department ofDefense is directly in the public interest. Continued operation ofolder, less reliable, and much less fuel efficient DC8 combi 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 information provided, Air Transport International, Inc., hereby petitions for exemption from the following portions of 14 CPR Part 121 for 757-200 passenger airplanes converted to combi configuration:

• §121.313(f), Amendment 121-353
Air Transport International, Inc. respectfully requests favorable FAA consideration ofthis Petition. I can be contacted at (407) 812-1691.

Regards,

Ed Shockley Director ofTechnical Services

### l

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### AIR TRANSPORTINTERNATIONAL
April25, 2013
U.S Department ofTransportation Federal Aviation Administration Docket Operations West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE, Washington, DC 20590
Attention: Transport Airplane Directorate Mr. Deke Abbott, Manager, Air Transportation Division, AFS-220
cc: Leslie H. Smith, AFS-220 Subject: ATI Request for Equivalent Level ofSafety to comply with 14 CFR 

### §121.3130), (1), (ii)
Reference: FAA -2007-0001-0001
Dear Mr. Abbott:
In lieu ofour original referenced request for exemption, Air Transport International Inc. (ATI) is revising its request to seek an equivalent level ofsafety to comply with the requirements of §121.JBG), (l),(ii) ofTitle 14, Code ofFederal Regulations. ATI would like to expand the terminology of"Flight Attendant" to include an additional flight crew member and allow operation of our Boeing 757-200 aircraft configured for combined cargo and passenger carriage (commonly known as "combi" aircraft) where the pilot compartment and the passenger compartment are not contiguous but physically separated by a class C cargo compartment. Background:
The 'Denial ofExemption' to Alaska Airlines, October 2, 2007, letter from the FAA has several key points:
1. 

### § 121.313 covers two key issues with regard to cockpit safety; 

### (f) and 

### G), (1), (ii)
a. Cockpit security- mitigated by ballistic door b. Safety ofFlight in the event ofan incapacitated crew member
2. Infrequency ofpilot incapacitation is sufficient reason to have a Flight Attendant with the ability to gain access to the Flight Deck

One Cantrell Center • 2800 Cantrell Road • Little Rock, Arkansas 72202 USA Phone: 501-615-3500 • www.airtransport.cc3. The FAA in its denial to Alaska Airlines agreed that a Flight Attendant would be able to perform the following from the supernumerary area:
a. Conducting emergency equipment checks b. Arming and disarming exits Ll/Rl
c. Conducting required briefmg ofsupernumeraries d. Combating fires
e. Opening ofLl/Rl exists in normal and emergency situations f. Assisting passengers post-evacuation g. Verifying door between cargo compartment and vestibule remains closed h. Monitoring the cargo 1. Providing First Aid J. Provide communication to the cockpit in the event ofa failed intercom
The key is to show that an equivalent level ofsafety 

### in the tasks listed in item 3 can be demonstrated using an additional flight crew member. The primary difference in the ATI application and the Alaska denial is that ATI proposes to utilize an additional flight crew member in the areas outlined above rather than a flight attendant. 14 CFR 121.313(j}, (1}, 

### (ii) states: "(ii) Each operator must establish methods to enable a flight attendant to enter the pilot compartment in the event that a flight crew member becomes incapacitated. Any associated signal or confirmation system must be operable by each flight crew member from that flight crew member's duty station." Due to the physical separation ofthe passenger compartment from the flight deck by a Class C cargo compartment, it is not possible for the flight attendant in the passenger compartment to provide assistance in accordance with the requirements of §121.313(j), 

### (1), (ii). ATI will maintain an equivalent level ofsafety 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 ofthe two required flight crew plus one additional flight crew member. In addition, the cockpit or adjacent compartment will be equipped with emergency medical equipment in accordance with 

### §121.803. Based on the information provided, ATI respectfully and urgently requests approval for an equivalent level ofsafety to comply with 14 CFR §121.313(j), (1), (ii). These aircraft are required to provide logistical support to our military at remote sites in the Arctic, South Atlantic, Pacific and the Indian Ocean through our contract with the U.S. Transportation Command. Ifyou require further information, I can be contaCted at (407) 257-1788. Sincerely,

# ~~ Dennis Manibusan President

cc: J. Vestal/ ATI D. Bucher/ ATI J. Sullivan/ ATI K. Sullivan/ ATI E. Wilson/ ATI T. Erickson/ ATI B. Dufour/ ATI E. Lippincott/ A TI J. Weidner/ FAA D. Forsberg! FAA D. Back/ FAA J. Bassler, Jr./ FAA

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