AIR TRANSPORT INTERNATIONAL 

May9,2013 

U.S. Department of Transportation 

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 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 of Safety 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. (A Tn is withdrawing its letter dated October 

23, 2012, subject, Request for Exemption from § 121.313{f) of Title 14, Code of Federal Regulations (See 

Attachment 1) for our B757-200 combi operations. 

In lieu of an exemption, A TI has submitted a request for an Equivalent Level of Safety, dated April 25, 2013, to 

comply with the requirements of §121313(j),(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 A Tl's request for Equivalent Level of Safety 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 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 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 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 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. 

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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, if required, 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 of the 

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 of the 

flight. The flight mechanic, if required, will administer first aid to the incapacitated flight crew 

member. 

j. Provide communication to the cockpit in the event of a 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 of the 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 "additional flight 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 of this request for an equivalent 

level of safety to' comply with the requirements of this regulation. 

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

dennis.manibusan@airlransport.ee or John Vestal, Vice President Flight Operations, at ( 407) 341-2018, email john.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/F AA 

D. Back/FAA 

B. Morrow/ FAA 

One cantre1J Cenrer • 2800 Cantn,!IJ ~ •l.iflle Roek,..Ad:ansas 72202 USA 

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

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AIR TRANSPORT INTE.RNATIONAL 

October 23, 2012 

U.S. Department of Transportation 

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 F ARs 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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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 of persons without compliance 

with the passenger-carrying requirements of this 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 of Boeing 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 

of US Department ofDefense worldwide operations. The interest of the petitioner is 

in providing a level of safety and security for the crew, passengers and cargo that 
·. 

will allow operation of converted 757 combi aircraft to meet the needs of ATI'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 of which 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 of two 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 of the nonflightcrew personnel will be trained in the use of the 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 of the smoke 

batTier between the class C compartment and the passenger compartment. Normal 

traffic is then not possible. However one of the 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 of Public Comment 
ATI requests waiver of the normal public comment process since this request is 

limited in scope and intent and because the granting of this petition will not create 

new precedent. 

Evaluation of Public Interest 

The use of modem, fuel efficient 757 combi aircraft in support of the worldwide 

operations of the United States Department of Defense is directly in the public 

interest. Continued operation of older, 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 

of this Petition. I can be contacted at (407) 812-1691. 

Regards, 

Ed Shockley 

Director of Technical Services 
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AIR TRANSPORT INTERNATIONAL 

April25, 2013 

U.S Department of Transportation 

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: A TI Request for Equivalent Level of Safety to comply with 14 CFR § 121.3130), 

(1), (ii) 

Reference: FAA -2007-0001-0001 

Dear Mr. Abbott: 

In lieu of our original referenced request for exemption, Air Transport International Inc. (ATI) is 

revising its request to seek an equivalent level of safety to comply with the requirements of 

§121.JBG), (l),(ii) ofTitle 14, Code of Federal 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 of Exemption' 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 of Flight in the event of an incapacitated crew member 

2. Infrequency of pilot 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.cc 
3. 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 of supernumeraries 

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 of a failed intercom 

The key is to show that an equivalent level of safety in the tasks listed in item 3 can be 

demonstrated using an additional flight crew member. The primary difference in the A TI 

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 of the 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). 

A TI will maintain an equivalent level of 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 of the 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 of safety 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. If you 

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 

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

Phone: 501-615-3500 • www.airtransportcc 
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Cockpit Supernumerary 

Compartment 

8757-200 Combi Layout 

PEMCOSTC 

Class C Cargo Compartment 

NOTE 1: Hardened door is installed between flight deck and supernumerary compartment. 

NOTE 2: Bulkhead between passenger compartment and Class C cargo Compartment is completely sealed off and has no physical access fore or aft in flight or on 

See Note 1 See Note 2 

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