# fM-ZOID -035

# I

March 22, 2010 Mr, Clint Jones or Mr. Phil Ford Federal Aviation Administration Transport Aircraft Directorate, ANM-100 1601 Lind Avenue, SW Renton, WA 98057-3356 ST00040NY Single AC Config PETITION FOR EXEMPTION

The leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder of ST00040NY requests FAR compliance relief and submits this Petition for Exemption (PIE) to FAA rulemaking established under 14CFR Sect 26.47(c) & (e)(2). LEG petitions the US Government for engineering task relief on a Single Configuration of ST00040NY for (1) 8737-500 aircraft, SN 24970 with LEG/pats Auxiliary Fuel System (AFS) in VIP LOPA Configuration. 8737-500 (Reg. C-FPHS) is operated private VIP service by Pacific Sky Aviation.

1.This SN contains aVIP stateroom and isconfigured for HOS service. 2. This SN operates exclusively inprivate service. 3.This SN is listed only on Canadas foreign registry. 4. This SN will require extensive engineering changes for adeck plan (LOPA) to be suitable for EASA or US commercial revenue service under FAR 121 (125 or 135). 5_ Responsive engineering resources ofthe FAA can be conserved and financial relief to the US Govt. can be realized on behalf ofthe DAH, upon timely approval ofthis PIE. 6. Air safety will not beadversely impacted given the Operators attention to FAR compliance with a limited VIP flight operation.
Inthe event this SN istransferred toathird party and an interior reconfiguration (LOPA) is completed, acurrent airframe survey to include #4 changes can be reviewed and specific airframe load and inspection analysis (OTE lOTI) due FAA under the Aging Aircraft Safety Rule forthe AFS (and the attach points) can be completed inaccordance with FAR 26.47(c) and (e){2).

g, Managing Director AS£ i00117. _Ill Proprietary YIN FAA Y

### IN Notary Y

### IN

COtpol"iJ(-eoffice 3425 emf/oil Point Kitkl:m4 Washington 98033 Mqin (425) 576-4030

# /ui-~-L;

ccLi.

1",~

# I www.airspeed.us.com
March 25, 2010 ASE 100325-18 FRPE PUBUCCOMMENT

Federal Register Petition for Exemption submittal for public comment: The Leading Edge Group, LLC(LEG), as FAASupplemental Type Certificate (STC) holder of ST00040NY requests FARcompliance relief and submits this Petition for Exemption (P/E) to FAArule making established under 14CFRSect. 26,47(c) & (e)(2). LEG petitions for US Govt. engineering task relief on a single tank Configuration of ST00040NY for B737-500 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in V1Ppassenger cabin (LOPA) deck plans. Boeing SN24970: 1. This SN contains a VIP stateroom and isconfigured for HOS service. 2. This SN operates exclusively in private or Head of State (HOS) service. 3. This SNis listed on foreign Registry. 4. This SNwill require extensive engineering changes for adeck plan (LOPA)to be suitable for EASA or US commercial revenue service under FAR 121. 5. Responsive engineering resources of the FAA can be conserved and financial relief can be realized on behalf ofthe DAH and US Government; upon timely approval of this PIE. 6. The Operator nor STC holder are not able to determine if modifications to the AFS loading points on this airframe have been altered, AFS brackets removed or, ifthe AFS attach points have been adapted for other purposes; requiring in themselves new lCAs. 7. Operator disclosure and DAH-onboard AFS survey of the aircraft isrequired to submit useful engineering to FAAthat isrelevant to SN existing condition. 8. 1tisthe position of the STCholder that airsafety will not be adversely impacted given this SN has limited private use and with over 30-years of airframe age, will likely never return to commercial FAA/EASA air carrier service.
In the event this SN istransferred to athird party and an interior reconfiguration (LOPA) iscompleted, a current airframe survey to include #6 changes can be reviewed and specific airframe load and inspection analysis (DTE/ DTl) due FAAunder the Aging Aircraft Safety Rule for the AFS (and the attach points) can be completed in accordance with FAR26,47(c) and (e)(2). Thank you.
Karl Seuring, Managing Director The Leading EdgeGroup, LLC Kirkland, WA 98033 CotpOt,lteOf1ice 3425 Cm//of} Point Kitk/q/JdWashillgtoll 98033 Mall)(425) 576-4030