Jamco America Inc.

1018 80th Street SW 

Everett, WA 98203, USA 

tel 425.347.4735 

fax 425.355.0237 

October 2, 2013 

Letter: JODA-13-191 

www.jamco-america.com 

U.S. Department of Transportation 

Docket Management Facility 

1200 New Jersey Ave., S.E. 

West Building Ground Floor 

Room W12-140 

Washington DC, 20590 

Subject: Amended Petition for Exemption (Docket No. FAA-2013-0680) from 25.785(d), 25.807(c)(1), 

25.807(c)(5), 25.809(f)(1), 25.813(b), 25.857(e), and 25.1447(c)(1)(3) for Dubai Air Wing Boeing 

model 747-412F (Freighter) Interior Modification; amended to include 25.1447(c)(3) 

The letter supersedes JODA-13-121. Changes identified in bold. 

The purpose of this letter is to submit a petition for exemption from the following 14 CFR part 25 

Airworthiness Standards: 

• 25.785(d) (amendment 25-64), Firm handhold on the main cargo deck; 

• 25.807(c)(1) (amendment 25-67), two Type III exits, one on each side on the upper deck; 

• 25.807(c)(5) (amendment 25-67), requirement for Type III exit in lieu of Type IV due to overwing constraints; 

• 25.809(f)(1) (amendment 25-47), Assist mechanism (slide) from Emergency exits; 

• 25.813(b) (amendment 25-46), assist space next to emergency exits; 

• 25.857(e) (amendment 25-60), Class E cargo compartment use for cargo only; 

• 25.1447(c)(1)(3) (amendment 25-41) automatic presentation of O2 masks while in the main 

deck cargo compartment and in lavatories installed in the main deck cargo compartment.

For the purpose of this petition, supernumeraries, who may have limited access to the main deck cargo 

compartment, are defined per 14 CFR 121.583(a)(1) through (7). 

This petition is based on Exemption 10703 and is in large part identical to relevant information quoted from 

the petitioner’s request in Exemption 10703. 

Jamco America, Inc. has been contracted by Dubai Air Wing (DAW) for the completion of an interior 

modification of a Boeing model 747-412F (Freighter) airplane. The serial number of the airplane is 28032 and 

is registered in the United Arab Emirates as A6-GGP. 

Discussion: 

The owner/operator of the aircraft intends to operate this freighter aircraft to transport types of cargo that 

require care, or inspection, or both, during flight (e.g., live animals), in addition to continuing the original 

mission of carrying cargo freight. To support this usage of the aircraft, the owner/operator has requested to 

increase the maximum number of persons carried from 8 to a maximum of 19, consisting of four seats on the 

flight deck and up to 15 seats on the upper deck, and install two lavatories in the main deck cargo

compartment. It is proposed that the 15 persons seated on the upper deck be qualified as “supernumeraries” 
Jamco America Inc.

Docket Management Facility 

Page 2 

October 2, 2013 

Letter: JODA-13-191 

as defined herein, and once trained and qualified and during specific flight operations as listed below, be 

permitted access to the main deck cargo compartment in flight under limitations proposed below. The 

designation and purpose of supernumeraries is discussed in subparagraph a.3 below. These purposes and the 

necessary configuration of the aircraft are not in accordance with 14 CFR Part 25 regulations; therefore, this 

petition is submitted to request specific exemptions. 

Summary of proposed aircraft operations and applicability of proposed exemptions hereafter referred to as 

“operation type” by alpha designator: 

A. Operations for carriage of live animals, and associated material, in the main deck cargo compartment 

requiring care/attention during flight; no other cargo on the main deck. 

For these operations the maximum number of supernumeraries on the upper deck is 15 and the 

total airplane occupancy is 19. Access to the main deck Class E cargo compartment by a maximum of 

15 supernumeraries is permitted during climb, cruise, and approach. 

B. Operations for carriage of cargo only as originally specified in the TCDS; no live animal(s) or other 

cargo requiring care/attention during flight. 

For these operations the maximum number of supernumeraries is 6 and the total airplane occupancy 

is 8. No access is allowed into the main deck Class E cargo compartment during any airplane 

operation. 

C. Operations for carriage of cargo on the main deck cargo compartment requiring care/attention 

during flight, and other cargo. 

For these operations the maximum number of supernumeraries is 6 and the total airplane occupancy 

is 8. Access to the main deck Class E cargo compartment by a maximum of 3 supernumeraries is 

permitted during climb, cruise, and approach. 

REFERENCES 

• Type Certificate Data Sheet A20WE, Boeing 747 

• FAA Exemption 10703, dated February 13, 2013, pertaining to Boeing 747-400F Series 

aircraft: partial exemption from 14 CFR 25.785(d), 25.807(c)(1), 25.807(c)(5), 25.809(f)(1), 

25.813(b), 25.857(e), and 25.1447(c)(1), Allowance of additional supernumeraries in the 

upper deck and access to the main cargo deck during certain phases of flight. 

• FAA Exemption 1870E, dated September 8, 1993, pertaining to Boeing 747-400F Series 

aircraft: exemption from 14 CFR 25.807(c)(1), 25.807(c)(5), 25.809(f)(1), 25.813(b), 

Allowance of non-crew members on the upper deck of 747-200F, 747-200C, certain 747-100 

when in the main deck cargo configuration, and 747-400F Series aircraft. 

• FAA Exemption 6463, dated June 19, 1996, pertaining to Boeing 747-100/200 Series cargo 

aircraft: exemption from 25.857(e) and 25.1447(c)(1), Allowance of 16 supernumeraries on 

the main deck of Boeing Model 747-100/-200 cargo aircraft to attend to live animal cargo. 

• FAA Exemption 7900, dated October 1, 2002, pertaining to B747-100/200 cargo aircraft: 

exemption from 14 CFR 25.855(a), 25.807(d)(1), 25.857(e), and 25.1447(c), Allowance of up 

to 28 supernumeraries on the main deck of Boeing 747-100, -200 Series airplanes to attend 

to live animal cargo. 
Jamco America Inc.

Docket Management Facility 

Page 3 

October 2, 2013 

Letter: JODA-13-191 

• FAA Exemption 8587B, pertaining to Boeing 747-400 Series “combi” aircraft 

• FAA Exemption 8536A, pertaining to Boeing 747-100, 747-100B, 747-100B SUD, 747-200B, 

747-200C, 747-200F, 747-400, 747-400F Series aircraft. 

• FAA Special Conditions 25-430-SC: Boeing Model 747-8 Airplanes; Stairway Between the 

Main Deck and Upper Deck 

• NM-09-27, Special Airworthiness Information Bulletin: In-flight access to Class E cargo 

compartments, May 12, 2009 

Exemption(s) Requested: 

a. 25.785(d)(Amdt.25-64) 

25.785(d) requires that if the seat backs do not have a firm handhold, there must be a handgrip or rail 

along each aisle to enable occupants to steady themselves while using the aisles in moderately rough air. 

There are no seatbacks and only cargo boxes or empty bays in the main deck cargo compartment and 

firm handholds may not be available. Jamco America, Inc. requests that the DAW Boeing 747-400F Series

aircraft be exempted from 14 CFR 25.785(d) (Amdt.25-64). 

Justification: 

1. Exemptions 10703 and 8587B grant exemptions from 25.785(d) (Amdt.25-64) and 25.785(j) 

(Amdt.25-88) respectively, for similar petitions. 

2. The main deck cargo compartment does not have a handrail or firm handholds installed the 

length of the main deck cargo compartment, nor bag bins. The likely configuration will contain 

only cargo boxes and/or empty pallet locations; therefore, there will be walls upon which to 

lean. 

3. Purpose of personnel in the main deck cargo compartment in flight: 

a. In order to optimize the usage of the Boeing 747-400F Series aircraft as a cargo airplane 

carrying live animals or other cargo requiring care, operators need to be able to accompany 

their cargo by people whose function is to take care of sensitive cargo and loading and 

unloading tasks at any port of arrival. Their presence in the aircraft ensures they will be 

immediately available on arrival to handle the cargo. This is most important in case of 

transport of live animals, perishable goods, and items of value. 

b. Some of the cargo items being transported may include large live animals or valuable or 

perishable goods that cannot be left unattended, even for the duration of the flight, and the 

presence of personnel trained and qualified in their handling is necessary on the aircraft on 

which they are carried. Horses are routinely shipped by air. Large live animals, such as 

horses, can endanger flight safety if left unattended due the brute force of which they are 

capable. In-flight inspection of live animal cargo enhances safety. 

c. Some of the destinations serviced by DAW may not have ground maintenance centers 

capable of performing necessary maintenance tasks for the operator’s aircraft nor passenger 

flights to carry maintenance personnel to the location. The additional capacity for company 

maintenance personnel on company flights increases flexibility of operation. 

d. Non-crew member passengers carried on Boeing 747-400F Series airplanes are limited. 

These non-crew members, referred to below as “supernumeraries”, shall be: 

i. physically capable of performing their emergency and normal cargo handling duties; 

and 
Jamco America Inc.

Docket Management Facility 

Page 4 

October 2, 2013 

Letter: JODA-13-191 

ii. briefed in the aircraft-specific limitations and use of emergency equipment; and 

iii. Permitted access to the main deck cargo compartment during climb, cruise and 

approach phases of flight according to limitations of this exemption and the 

approved STC. 

e. “Supernumeraries” per 121.583 (a)(1) through (7) may include: 

i. A crew member. 

ii. A company employee. 

iii. An FAA air carrier inspector, a DOD commercial air carrier evaluator, or an 

authorized representative of the National Transportation Safety Board who is 

performing official duties. 

iv. A person necessary for— 

1. The safety of the flight; 

2. The safe handling of animals; 

3. The security of valuable or confidential cargo; 

4. The preservation of fragile or perishable cargo; 

5. Experiments on, or testing of, cargo containers or cargo handling devices; 

6. The operation of special equipment for loading or unloading cargo; and 

7. The loading or unloading of outsize cargo. 

8. A person described above, when traveling to or from his assignment. 

9. A person performing duty as an honor guard accompanying a shipment 

made by or under the authority of the United States. 

10. A military courier, military route supervisor, military cargo contract 

coordinator, or a flight crew member of another military cargo contract air 

carrier or commercial operator, carried by a military cargo contract air 

carrier or commercial operator in operations under a military cargo 

contract, if that carriage is specifically authorized by the appropriate armed 

forces. 

v. The following maximum number of supernumeraries will be permitted access to the 

main deck cargo compartment during climb, cruise, and approach phases of flight 

for each operation type according to limitations of this exemption petition: 

1. Operation type A: a maximum of 15 supernumeraries may be permitted 

access to the main deck cargo compartment. 

2. Operation type B: no persons or supernumeraries are permitted access to 

the main deck cargo compartment. 

3. Operation type C: a maximum of 3 supernumeraries may be permitted 

access to the main deck cargo compartment. 

4. Handhold provisions on the upper deck per the requirements of 14 CFR 25.785(d) are retained. 

The installation of handholds in the main deck cargo compartment is impractical. The absence of 

handholds is mitigated by a crew operated turbulence alert system to alert the supernumeraries 

in the cargo compartment to return to their seats at the onset of turbulence. This mitigation is 

similar to FAA approved exemption 8587B. 

5. We propose installation of modified aural/visual alerting systems. There will be three separate, 

distinctive alerts: 

i. Decompression Alert: 

Automatically activated aural and visual decompression alerts will be provided and 

immediately recognizable in accessible areas of the main deck Class E cargo 

compartment to notify supernumeraries to don their portable oxygen masks and return 
Jamco America Inc.

Docket Management Facility 

Page 5 

October 2, 2013 

Letter: JODA-13-191 

to their seats. As a backup to the automated alert system, the flight crew will be able to 

manually activate the alerts. The visual decompression alert will be distinguishable from 

the fire/smoke and turbulence alerts. The pre-flight briefing will include training in 

recognizing the alerts and the appropriate response to the alerts (i.e., procedures for 

donning masks and activating the flow of oxygen). 

ii. Fire/Smoke Alert: 

A flightcrew-activated aural or visual fire/smoke signal will be provided and immediately 

recognizable in accessible areas of the main deck Class E cargo compartment to notify 

supernumeraries to immediately return to their seats, secure the smoke barrier, and, as 

necessary, don their oxygen masks. As a backup to the automated alert system, the 

flight crew will be able to manually activate the alerts. The visual fire/smoke alert will be 

distinguishable from the decompression and turbulence alerts. The pre-flight briefing 

will include training in recognizing the alert and the appropriate response to the alert 

(i.e., procedures for donning masks and activating the flow of oxygen). 

iii. Turbulence Alert: 

A flightcrew-operated aural or visual alert, which is recognized in the supernumerary 

seating area and in accessible areas in the main deck Class E cargo compartment, will be 

installed to indicate during turbulence, or anticipated turbulence, that supernumeraries 

return to their seats. The visual turbulence alert will be distinguishable from the 

decompression and fire/smoke alerts. Appropriate procedures and limitations must be 

established to ensure that the flight crew member alerts the supernumeraries to return 

to their seats at the onset of turbulence. The pre-flight briefing will include training in 

recognizing the alert and the appropriate response to the alert. 

6. The Public address system will be extended to the main deck cargo compartment to permit 

announcements from the flight deck or any interphone location. 

7. Intercom phones (interphone) will also be placed in the main deck cargo compartment for two 

way communications. 

8. This modified aircraft will be operated for private, not for common public, airline passenger 

service. 

9. The following limitations are proposed and limitation numbers i-v will be documented in the 

limitations section of the airplane flight manual: 

i. A maximum of 15 supernumeraries may occupy the area just aft of the flight deck. The 

total maximum occupancy of the airplane is limited to 8 or 19 persons, including the 

flight crew, depending on the operational type. See item iv below. 

ii. The supernumeraries are limited to the categories specified in 14 CFR 121.583(a)(1) 

through 121.583(a)(7). 

iii. Supernumeraries are prohibited from being in the cargo area during taxi, takeoff, and 

landing. The pre-flight briefing will inform the supernumeraries of this requirement. 

iv. Access into the main deck cargo compartment in-flight is divided into three different 

operational types: 

• Operation Type A: Carriage of live animals requiring care/attention during flight 

and associated material only, no other cargo in the main deck cargo 

compartment. The maximum number of supernumeraries is 15 and the total 

airplane occupancy is 19. Access to the Class E main deck cargo compartment 

by a maximum of 15 supernumeraries is permitted during climb, cruise, and 

approach. 

• Operation Type B: Cargo only, which does not require care/attention during 

flight, and no live animals requiring care/attention during flight. The maximum 
Jamco America Inc.

Docket Management Facility 

Page 6 

October 2, 2013 

Letter: JODA-13-191 

number of supernumeraries is 6 and the total airplane occupancy is 8. No 

access is allowed into the Class E main deck cargo compartment during any 

airplane operation. 

• Operation Type C: Carriage of cargo requiring care/attention during flight, and 

other cargo. The maximum number of supernumeraries is 6 and the total 

airplane occupancy is 8. Access to the Class E main deck cargo compartment by 

a maximum of 3 supernumeraries is permitted during climb, cruise and 

approach. 

v. Prior to each flight, a flightcrew member must brief each supernumerary on the use of 

exits and emergency equipment, including evacuation instructions to inspect the ground 

to determine whether a safe landing can be achieved before using an assist means. 

vi. Alerting requirements 

• must be distinctive and effective 

• visual alerts must be visible from all occupant locations and orientations, during 

all expected operational conditions, including a rapid decompression where 

moisture in the air may condense 

• aural alerts must be loud enough to be heard during all expected operational 

conditions, including a rapid decompression where the ambient noise level will 

increase 

vii. An aural, automatically activated decompression alert must be present and immediately 

recognizable in accessible areas of the Class E cargo compartment to notify 

supernumeraries when to don oxygen masks. If there are two or more alerts that a 

supernumerary may hear or is expected to respond to, there must be an automatic 

visual alert in addition to the automatic aural alert. The pre-flight briefing must include 

training in the sound of the alert, the meaning of the alert, and the response to the alert 

(i.e., procedures for donning the masks and activating the flow of oxygen). 

viii. A flightcrew-operated aural or visual alert, which is recognized in accessible areas in the 

Class E cargo compartment, must be installed. This aural or visual alert is to indicate 

that, during turbulence, persons must return to their seats. Appropriate procedures and 

limitations must be established to ensure that the flightcrew signals the 

supernumeraries to return to their seats at the onset of turbulence and prior to landing. 

The pre-flight briefing must explain this signal to the supernumeraries. 

ix. A flightcrew-activated aural or visual signal, which is recognized in the Class E cargo 

compartment, must be installed. This aural or visual signal is to indicate that, in the 

event of fire or smoke in the Class E cargo compartment, persons must return to their 

seats and ensure that the smoke barrier is secured (i.e., the door or curtain is closed). 

Appropriate procedures and limitations must be established to ensure that, at the onset 

of a fire or smoke event, the flightcrew signals the supernumeraries to return to their 

seats and secure the smoke barrier. The preflight briefing must explain these signals to 

the supernumeraries. 

 
Jamco America Inc.

Docket Management Facility 

Page 7 

October 2, 2013 

Letter: JODA-13-191 

b. 25.807(c)(1)(5) (Amdt.25-67) 

25.807(c)(1) requires that one Type III passenger emergency exit be provided on each side of the 

fuselage. 25.807(c)(5) requires that at least one pair of Type III passenger emergency exits be provided if 

Type IV exits are specified but cannot be located over the wing. Jamco America, Inc. requests that the 

DAW Boeing 747-400F Series aircraft be exempted from 14 CFR 25.807(c)(1)(5) (Amdt.25-67). 

Justification: 

1. Exemptions 10703 and 1870E grant exemptions from these regulations for similar petitions. 

1870E applies to this aircraft model; however, the proposed DAW configuration exceeds the 

limitations of number of persons per 1870E and the TCDS, and 1870E does not permit access to 

the main deck cargo compartment in flight. 

2. Configuration during TTL on upper deck with respect to egress: 

Right Side: 

a. The right side upper deck crew service door has the dimensions, 24”x48”, of a Type I 

emergency exit (larger than Types II, III, IV); however, this exit has a step up feature and 

cannot be classified as a Type I emergency exit. This door was approved as an emergency 

exit for five flight crew members and three [supernumeraries] per the original exemption 

1870. This door has an escape slide that is manually deployed, automatically inflated, and 

capable of withstanding 25 knot winds. We propose to maintain this escape slide. 

b. According to exemptions 10703 and 8536A the right side upper deck crew service door, with 

a manually deployed and automatically inflated escape slide, has been approved for 

evacuation of up to 19 and 24 persons, respectively; therefore, we estimate that all 19 

persons proposed in this petition could safely exit from the right side upper deck crew 

service door in the event of an emergency landing. 

c. This modification will ensure that one escape harness is installed for each existing and/or 

new inertial drop reel installed on the aircraft. 

Left Side: 

d. The left side flight deck overhead emergency hatch currently satisfies the flight crew escape 

requirements per 25.805. This was approved in Exemption 1870 for use as the second exit 

for upper deck supernumeraries, using inertial drop reels and escape harness provisions that 

are installed in the overhead of the upper deck, to a maximum of 8 persons. 

i. According to exemptions 8170 through 8170E, the overhead emergency hatch, with 

inertial drop reels, has been approved for evacuation of up to 8 persons. 

ii. Increasing the upper deck passenger count to 19 requires that 11 of those use an 

alternate emergency escape path. 

iii. We therefore propose an alternate left side path for evacuation for at least 11 of 

the 19 proposed supernumeraries on the upper deck. 

iv. No flight deck door may be installed between the supernumerary compartment and 

flight deck that would prevent access to the overhead hatch and 8 inertial drop 

reels and escape harnesses. 

e. Left side main deck L1 door evacuation is required when more than 8 persons are carried on 

the upper deck. In such cases: 
Jamco America Inc.

Docket Management Facility 

Page 8 

October 2, 2013 

Letter: JODA-13-191 

i. We propose that the left side main deck L1 door be utilized for evacuation, in 

addition to the left side flight deck overhead emergency hatch, in the event that the 

right side upper deck crew service door is blocked.

ii. There are several precedents for use of a main deck exit for passengers seated at 

TT&L on the upper deck, reference the type certificate A20WE, for 747’s configured 

for commercial operations. Reference TCDS A20WE and special conditions 25-61-

NW-1, 25-71-NW-3, and 25-430-SC. The situation in this aircraft is more 

conservative than a passenger configured aircraft because this aircraft is intended 

for private use only and the upper deck passengers would be supernumeraries, 

persons that are both physically qualified and specifically trained in the aircraft 

configuration and evacuation procedures. This training/qualification process can be 

reasonably expected to ensure that supernumeraries are more physically able and 

more mentally ready than the average commercial passengers to evacuate the 

upper deck, if necessary, down the stairs and out the left side main deck L1 door. 

We propose to show this by demonstration, test, analysis, or any combination 

thereof. Evacuation demonstration testing will not be required. 

iii. We propose that the stairway between upper deck and main deck cargo 

compartment comply with the following requirements, similar to those of 24-430-

SC, for operational type A only: 

1. The stairway will be essentially straight. 

2. The stairway will have essentially rectangular treads. 

3. With the airplane in level attitude and in each attitude resulting from the 

collapse of one or more legs of the landing gear, the stairway will have 

entrance, exit, and gradient characteristics that allow the upper deck 

supernumeraries to evacuate and exit the airplane through the L1 main 

deck exit. This will be shown by demonstration, tests, analysis, or any 

combination thereof. 

4. The stairway must accommodate the carriage of an incapacitated occupant 

from the upper deck to the main deck and vice versa. The crew member 

procedures for such carriage must be established and included in the 

Airplane Flight Manual. 

5. The stairway must be located to provide occupants an adequate descent 

rate under probable emergency conditions, including a condition in which 

an occupant falls or is incapacitated while on the stairway. 

6. The stairway must be designed and located to minimize damage to its 

structure during an emergency landing or ditching. 

7. General illumination will be provided so that, when measured along the 

center lines of each tread and landing, the illumination is not less than 0.05 

foot-candle. This is in lieu of compliance with § 25.812(c) at Amendment 

25-116. 

8. Means will be provided to assist supernumeraries in locating the stairway in 

dense smoke conditions as part of compliance with § 25.811(c), 

Amendment 25-88. 

9. An emergency-exit sign meeting § 25.812(b)(1)(i), at Amendment 25-116, 

will be provided on the upper deck near the stairway visible to 

supernumeraries on the upper deck as required by § 25.811(d)(1), at 

Amendment 25-88. 
Jamco America Inc.

Docket Management Facility 

Page 9 

October 2, 2013 

Letter: JODA-13-191 

10. Floor-proximity lighting, required by § 25.812(e), at Amendment 25-120, 

must be provided along the stairs. 

11. The stairway must have a handrail on at least one side to allow occupants 

to steady themselves during foreseeable conditions, including, but not 

limited to, gear collapse on the ground and moderate turbulence in flight. 

The handrail(s) must be constructed with no obstruction on them that 

causes the user to release their grip or hinder the continuous movement of 

the hands along the handrail. Handrail(s) must be terminated in a manner 

that will neither interfere with occupants walking by nor create a hazard 

(such as catching clothing). The petitioner must demonstrate that the 

design can accommodate the stature of a fifth-percentile female and a 

ninety-fifth-percentile male. 

12. The public-address system must be intelligible in the stairway during all 

flight phases. 

13. "No smoking" and "return to seat" signs must be installed and visible in the 

stairway both going up and down, and at the stairway entrances. 

14. During any flight operation where more than 8 persons are on the flight, 

the stair must remain installed between upper and main decks during the 

entire flight. 

15. Demonstrate that a liferaft can be transported from the upper deck to the 

main deck with the assistance of two people. 

iv. In the event of failure of landing gear on one side, and aircraft tip-over, calculations 

show that the maximum increased angle will be approximately five degrees. The 

existing stair, with both non-skid treads and firm railing, is easily navigable at +/- 

five degrees for a physically fit individual. 

 
Jamco America Inc.

Docket Management Facility 

Page 10 

October 2, 2013 

Letter: JODA-13-191 

v. Pictures of the stairway are included for clarification, showing the proximity of the 

stairway to the left side main deck L1 door. 

Figure 1: Main deck cargo compartment, facing forward 

 Figures 2: view looking up stairs Figure 3: view looking down stairs

 
Jamco America Inc.

Docket Management Facility 

Page 11 

October 2, 2013 

Letter: JODA-13-191 

f. Smoke propagation testing: 

i. Smoke propagation testing will be conducted to measure the concentration/density 

of smoke present in the stairwell, upper deck, and flight deck under specified 

conditions. A copy of the test plan and report will be provided to the FAA, including 

video documentation. 

ii. Testing will demonstrate whether there is a significant “smoke chimney” effect in 

case of emergency landing where ECS is turned off, evacuation is ordered, and both 

the left side flight deck overhead emergency hatch and the left side main deck L1 

door are used. Under these conditions, there is a potential path for smoke 

propagation up the stair, into the upper deck, and out the right side upper deck 

door and/or left side flight deck overhead emergency hatch. 

iii. Testing will demonstrate the ability of a crew to safely egress down the stairs to the 

left side main deck L1 door under anticipated dense smoke conditions. Testing will 

include training/qualification of a similar nature that will be required of 

supernumeraries as previously discussed. 

iv. Due to the direct path down the stairs to the L1 door and close proximity of the 

stairs to the L1 door (see pictures in figures 2 & 3), a trained, qualified and 

physically fit crew should be able to don breathing devices/masks, descend the 

stairs, and exit the L1 door within 90 seconds under excessive smoke conditions. 

g. There shall be door-operating markings on the inside of the airplane. 

h. Evacuation procedures will be developed so that at least 11 of 19 persons can descend and 

exit via the left side main deck L1 door, including an incapacitated person, with a goal to 

show that all 19 persons located on the upper deck are able to exit within the prescribed 90 

second time limit. Evacuation demonstration testing will not be required. 

i. Evacuation procedures will be included in the FAA approved training plan for this exemption 

& STC. 

j. The following limitations are proposed and limitations i-iii will be documented in the 

limitations section of the airplane flight manual: 

i. Prior to each flight, a flightcrew member must brief each supernumerary on the use 

of exits and emergency equipment, including evacuation instructions to inspect the 

ground to determine whether a safe landing can be achieved before using an assist 

means. 

ii. The operator must determine that each supernumerary is physically able and 

trained to accomplish the necessary emergency procedures. 

iii. The existing left side main-deck L1 entry door must be modified to function as an 

emergency exit by installing at least 11 inertial drop reels adjacent to the door. This 

modification includes the door-operating markings on the inside of the airplane; 

interior illumination system; assist means; attachment point for a liferaft mooring 

line; and exterior markings. 

iv. The stairway will comply with the requirements listed above in paragraph (b.2.e.iii) 

v. A minimum of 11 portable PBE units, as defined in § 25.1439(a), and which will 

provide a minimum 90-second breathing supply, must be installed such that they 

are readily accessible to the supernumeraries to aid in evacuation in the event of 

smoke. The supernumeraries must be trained in the use of the PBE. 

 
Jamco America Inc.

Docket Management Facility 

Page 12 

October 2, 2013 

Letter: JODA-13-191 

c. 25.809(f)(1) (Amdt.25-47) 

25.809(f)(1) requires that a self-supporting escape slide or equivalent be provided as the assist 

means at passenger emergency exits that are more than six (6) feet from the ground with all landing 

gear extended and that the assist means deploy automatically. Jamco America, Inc. requests that 

the DAW Boeing 747-400F Series aircraft be exempted from 14 CFR 25.809(f)(1) (Amdt.25-47). 

Justification: 

1. Exemptions 10703 and 1870E grant exemption from these regulations for similar petitions. 

1870E applies to this aircraft model; however, the proposed DAW configuration exceeds the 

limitations of number of persons per 1870E and the TCDS, and 1870E does not permit access 

to the main deck cargo compartment in flight. 

Right Side: 

2. 25.809(f)(1)(i) requires automatically deploying assist means. The right side upper deck 

crew service door is currently configured with a manually opened door with an 

automatically inflating escape slide. Exemption 1870E and Boeing’s reported experience 

with 747 model aircraft equipped with this assist means as discussed in 1870E provides 

evidence that the current right side upper deck crew service door meets the requirements of 

25.809(f)(1)(i) and provides adequate means of egress for up to 19 persons when combined 

with limitations on supernumeraries that are physically capable and specifically briefed. This 

escape means has been demonstrated to be effective at providing safe evacuation of 

occupants to the ground. 

3. Many Boeing 747-200F, -200C, and -400F Series aircraft have the manually deploying escape 

slide; commonality of configuration and crew training is an economic benefit. 

4. A Boeing survey of similar aircraft (discussed in 1870E) documented that the majority of 

affected airplanes in service are equipped with manually deployed escape slides. No adverse 

experience has been reported with these manually deployed escape slides provided for 

specially trained crew which supports the continuation of this exemption. 

5. All the persons carried as supernumeraries will be specially trained and qualified in the 

escape methods listed above and none of these persons will be commercial or fare-paying; 

therefore, a higher expectation of their capability and familiarity with the exit systems is 

anticipated. 

6. The escape slide installed on the Boeing 747-400F Series aircraft meets the existing 25 knot 

wind requirement per the Type Certificate. We propose to maintain this escape slide. 

7. The escape slide for the right side upper deck crew service door is not self-supporting on the 

ground in all cases of gear collapse; therefore, supplemental inertial drop reels and escape 

harnesses for each inertial drop reel will be installed to provide for evacuation of up to all 19 

persons from the right side upper deck crew service door under these conditions. The same 

inertial drop reel part numbers have been demonstrated to be effective at providing safe 

evacuation out the right side upper deck crew service door after the escape slide has been 

deployed and inflated to address this condition. This mitigation is already approved for up 

to 19 persons on the upper deck per TCDS A20WE in the case of the 747-200F, and should 

not require demonstration of a right side evacuation. 

8. The following limitations are proposed and must be documented in the limitations section of 

the airplane flight manual: 
Jamco America Inc.

Docket Management Facility 

Page 13 

October 2, 2013 

Letter: JODA-13-191 

a. Prior to each flight, a flightcrew member must brief each supernumerary on the use of 

exits and emergency equipment, including evacuation instructions to inspect the ground 

to determine whether a safe landing can be achieved before using an assist means. 

b. The operator must determine that each supernumerary is physically able and trained to 

accomplish the necessary emergency procedures. 

c. A minimum of 8 inertia reels and harnesses must be installed on the flight deck for 

operational types B and C. In addition to the minimum 8 inertia reels and harnesses 

installed on the flight deck, a minimum of 11 inertia reels and harnesses must be 

installed at a location that can be used for exiting the crew-service door when the 

installed escape slide is not self-supporting on the ground. No flightdeck door may be 

installed between the supernumerary compartment and flight deck that would prevent 

access to the overhead hatch and 8 inertia reels and harnesses. 

Left Side: 

9. The left side flight deck overhead emergency hatch is outside the scope of this regulation; 

however, as discussed elsewhere, it is approved for use by up to eight persons with use of 

inertial drop reels. 

10. The use of the left side main deck L1 door as an emergency exit requires installation of 11 

escape harnesses, 11 inertial drop reels, and one life raft mooring line attachment point 

adjacent to the main deck L1 door. 

11. This modification will ensure that one escape harness is installed for each existing and/or 

new inertial drop reel installed on the aircraft. 

12. The same inertial drop reel part numbers have been demonstrated to be effective at 

providing safe evacuation out the left side flight deck overhead emergency hatch. 

13. The following limitations are proposed and must be documented in the limitations section of 

the airplane flight manual: 

a. Prior to each flight, a flightcrew member must brief each supernumerary on the use of 

exits and emergency equipment, including evacuation instructions to inspect the ground 

to determine whether a safe landing can be achieved before using an assist means. 

b. The operator must determine that each supernumerary is physically able and trained to 

accomplish the necessary emergency procedures. 

c. The existing left side main-deck L1 entry door must be modified to function as an 

emergency exit by installing at least 11 inertial drop reels adjacent to the door. This 

modification includes the door-operating markings on the inside of the airplane; interior 

illumination system; assist means; attachment point for a liferaft mooring line; and 

exterior markings. 

 
Jamco America Inc.

Docket Management Facility 

Page 14 

October 2, 2013 

Letter: JODA-13-191 

d. 25.813(b) (Amdt.25-46) 

25.813(b) requires that for each passenger emergency exit covered by 25.809(f), there must be 

enough space next to the exit to allow a crew member to assist in the evacuation of passengers 

without reducing the unobstructed width of the passageway below that required for the exit. Jamco 

America, Inc. requests that the DAW Boeing 747-400F Series aircraft be exempted from 14 CFR 

25.813(b) (Amdt.25-46). 

Justification: 

1. Exemptions 10703 and 1870E grant exemptions from these regulations for similar petitions. 

1870E applies to this aircraft model; however, the proposed DAW configuration exceeds the 

limitations of number of persons per 1870E and the TCDS, and 1870E does not permit access 

to the main deck cargo compartment in flight. 

2. Assist space configurations: 

a. The right side upper deck crew service door does not have adequate space to provide the 

required assist space during an evacuation. 

b. Adequate space has been demonstrated to be available in the flight deck for flight crew to 

assist "crew" in evacuating from the left side flight deck overhead emergency hatch. 

c. Adequate space exists in the vicinity of the left side main deck L1 door to provide 

assistance during evacuation. 

3. The airplane contains adequate space for the flight crew to demonstrate the donning of 

escape harnesses, use of the inertial drop reels, and how to evacuate the airplane with this 

equipment. 

4. The flight crew and supernumeraries will be specially trained and benefit from a higher level of 

aircraft knowledge than the common public on a commercial carrier. Their additional training 

will include safety procedures, evacuation methods for the upper deck escape slide, donning 

of escape harnesses, and usage of inertial drop reels. Since these persons will not be paying 

passengers but rather flight crew and specially trained and qualified supernumeraries, we feel 

that the absence of the required assist space at the right side upper deck crew service door is 

compensated for by this additional training and knowledge, and provides a level of safety 

exceeding that provided by an assist space.

5. The following limitations are proposed and will be documented in the limitations section of 

the airplane flight manual: 

a. Prior to each flight, a flightcrew member must brief each supernumerary on the use of 

exits and emergency equipment, including evacuation instructions to inspect the ground 

to determine whether a safe landing can be achieved before using an assist means. 

b. The operator must determine that each supernumerary is physically able and trained to 

accomplish the necessary emergency procedures. 

 
Jamco America Inc.

Docket Management Facility 

Page 15 

October 2, 2013 

Letter: JODA-13-191 

e. 25.857(e) (Amdt.25-60) 

25.857(e) (Amdt.25-60) limits a Class E cargo compartment to airplanes used only for the carriage of 

cargo. Jamco America, Inc. requests that the DAW Boeing 747-400F Series aircraft be exempted 

from 14 CFR 25.857(e) (Amdt.25-60). 

Justification: 

1. Exemptions 10703, 6463, and 7900 grant exemptions from these regulations for similar 

petitions. 

2. One of the primary aspects of this petition is to permit access to the main deck cargo 

compartment during flight, under specific limitations. 

3. We propose to maintain the Class E classification of the main deck cargo compartment. 

4. A smoke barrier will be established and maintained to isolate the upper deck at all times 

except when supernumeraries pass between the main and upper decks, and during TTL 

for Operation Type A. If fire/smoke has been detected in the main deck cargo 

compartment during TTL for Operation Type A, the door may be closed if directed by the 

pilot in charge. 

5. Additional first aid kits will be installed at the front and rear of the main deck cargo 

compartment. 

6. Smoking is prohibited in the main deck cargo compartment during all phases of flight. 

7. A fixed oxygen source (drop mask) will be available at each upper deck TT&L seat. 

8. A training plan will be submitted for FAA approval as part of the STC project. 

9. The smoke barrier between the upper deck and main deck cargo compartment must 

remain in place at all times except during TTL for Operation Type A and during passage 

between the upper and main decks per NM-09-27. If fire/smoke has been detected in 

the main deck cargo compartment during TTL for Operation Type A, the door may be 

closed if directed by the pilot in charge. 

10. Public address speakers and interphone capabilities per 25.1423 will be available in the 

main deck cargo compartment. 

11. Emergency lighting per 25.812 (foot path and overhead) will be available in the main 

deck cargo compartment and in the path from the upper deck to the left side main deck 

L1 door. 

12. Exit signage will be modified to the new configuration. 

13. Additional firefighting gear (gloves, fire extinguishers) will be stored in the main deck 

cargo compartment. 

14. The following limitations are proposed and limitations a and b must be documented in the 

limitations section of the airplane flight manual: 

a. The supernumeraries are limited to the categories specified in 14 CFR 121.583(a)(1) 

through 121.583(a)(7). 

b. Each supernumerary must be provided with a portable oxygen unit with a mask 

attached to it that they must carry whenever they are in the Class E cargo 

compartment. The supernumeraries must be trained in the use of the oxygen 

equipment. The supernumeraries must also be trained in making the determination 

whether oxygen is being delivered to the masks. The equipment must provide 

oxygen-flow indication. The oxygen units must be sized adequately for continuous 

and uninterrupted use during worst-case flight duration following decompression, 

or must be of sufficient duration to allow the supernumeraries to return to their 
Jamco America Inc.

Docket Management Facility 

Page 16 

October 2, 2013 

Letter: JODA-13-191 

seats where oxygen for the remainder of the decompression is readily accessible. 

The portable oxygen equipment must meet the requirements in 14 CFR 25.1443(a) 

or (b), or the equipment must be shown to protect the supernumeraries from 

hypoxia at an activity level required to return to their seats following a rapid 

decompression to 25,000 feet cabin altitude. Additionally, the portable oxygen 

equipment must: 

• meet § 25.1439(b)(1), (2), and (4), and 

• be designed to prevent any inward leakage to the inside of the mask, and 

• prevent any outward leakage causing significant increase in the oxygen content of 

the local atmosphere. 

c. Three separate, distinctive visual and aural alerts for decompression, fire/smoke, 

and turbulence must be installed per subparagraphs a.9.vi-ix above. 

d. A placard located in the supernumerary area, in a conspicuous location either on or 

adjacent to the smoke barrier, must indicate the following: 

For operational type B 

• no access to the Class E cargo compartment is allowed during any airplane 

operation 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except for ground operations 

The pre-flight briefing must inform supernumeraries of these requirements. 

For operational type C 

• access to the Class E cargo compartment is limited to the care and handling 

of cargo requiring care/attention during flight access to the Class E cargo 

compartment is limited to a maximum of three supernumeraries 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except when entering or leaving the cargo compartment 

• a portable oxygen bottle (with mask attached) must be carried upon 

entering and while accessing the cargo compartment 

• smoking is not allowed within the cargo compartment

The pre-flight briefing must inform supernumeraries of these requirements. 

For operational type A 

• access to the Class E cargo compartment is limited to the care and handling 

of animals and cargo only 

• access to the Class E cargo compartment is limited to a maximum of 15 for 

the carriage of live animals and associated material 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except when entering or leaving the cargo compartment during cruise. The 

smoke barrier must be latched opened for TT&L for operational type A 

unless fire/smoke has been detected in the main-deck cargo compartment. 

If fire/smoke has been detected in the main-deck cargo compartment, the 

door may be closed if directed by the pilot in charge 

• a portable oxygen bottle (with mask attached) must be carried upon 

entering and while accessing the cargo compartment 

• smoking is not allowed within the cargo compartment
Jamco America Inc.

Docket Management Facility 

Page 17 

October 2, 2013 

Letter: JODA-13-191 

• the compartment must not be entered in case of fire/smoke being detected 

inside the Class E cargo compartment except during evacuation 

The pre-flight briefing must inform supernumeraries of these requirements. 

e. A minimum of 11 portable PBE units, as defined in § 25.1439(a), and which will 

provide a minimum 90-second breathing supply, must be installed such that they 

are readily accessible to the supernumeraries to aid in evacuation in the event of 

smoke. The supernumeraries must be trained in the use of the PBE. 

 
Jamco America Inc.

Docket Management Facility 

Page 18 

October 2, 2013 

Letter: JODA-13-191 

f. 25.1447(c)(1)(3) (Amdt.25-41) 

25.1447(c)(1)(3) requires, in pertinent part, that oxygen dispensing units must be automatically 

presented to the occupants before the cabin pressure altitude exceeds 15,000 feet and oxygen 

dispensing units be available in each lavatory. These requirements will be met on the upper deck; 

however, the requirement will not be met while the supernumeraries are accessing the main deck 

cargo compartment or within the lavatories installed in the main deck cargo compartment. Jamco 

America, Inc. requests that the DAW Boeing 747-400F Series aircraft be exempted from 14 CFR 

25.1447(c)(1)(3) (Amdt.25-41). 

Justification: 

1. Exemptions 10703, 6463, and 7900 grant exemptions from these regulations for similar 

petitions. 

2. When supernumeraries are seated or while in the lavatory on the upper deck, selfpresenting oxygen masks indicate the need to don an oxygen mask. Self-presenting 

oxygen masks are not available to persons accessing the main deck Class E cargo 

compartment; however, the decompression alert system indicates to main deck cargo 

compartment occupants the need to immediately don their portable oxygen mask and 

return to their seats in the event of a decompression event.

3. Supernumeraries will be trained regarding the location and use of the oxygen 

equipment and the alert conditions requiring their use.

4. Supernumeraries are required to carry portable oxygen bottles, with a mask connected 

to it, while in the main deck Class E cargo compartment. This equipment will be stored 

in the main deck cargo compartment, easily accessible to supernumeraries, and in close 

proximity to the stairs. There will be at least one portable oxygen bottle, with a mask 

connected to it, provided for each supernumerary allowed to enter the main deck Class 

E cargo compartment during flight and an additional 2 units to meet the 10% overage 

requirement of 25.1447(c)(1).

5. The portable oxygen equipment will meet the performance standards of 25.1443(a) or 

(b), or the equipment will be shown to protect the supernumerary from hypoxia at the 

activity level required to return to his or her seat following a rapid decompression to 

25,000 feet cabin altitude. An example of equipment that meets these criteria is the 

AVOX Systems portable O2 cylinder MA-1 p/n 9000A-3 with mask 358, used by USAF 

and designed for use with masks at altitudes to 43,000 feet by moderately active flight 

personnel – or up to 45,000 feet in extreme emergency situations of short duration. 

a. See AVOX Systems http://www.avoxsys.com/pdf/products/portable-oxygensystems/MA-1-PN-9000A-3-portable-oxygen-cylinder-and-regulator.pdf 
Jamco America Inc.

Docket Management Facility 

Page 19 

October 2, 2013 

Letter: JODA-13-191 

 Figure 4 AVOX Systems MA-1 and Mask 358 

6. The portable oxygen equipment will meet the protective breathing equipment (PBE) 

requirements in 25.1439(b)(1), (2), and (4) and the PBE equipment will be designed to 

prevent any inward leakage to the inside of the device and prevent any outward leakage 

causing significant increase in the oxygen content of the local atmosphere (i.e., full face 

mask type.) 

7. The oxygen equipment will also meet the requirement in 25.1449, which states that 

there must be a means for the crew to determine whether oxygen is being delivered to 

the dispensing units. Supernumeraries will be trained in making the determination 

whether oxygen is being delivered to the masks. 

8. Due to the way that fire in the cargo compartment is to be controlled, it is necessary to 

limit persons on board the airplane to those who the airplane operator has found to be 

physically fit and who have been briefed on the use of the emergency equipment. 

9. There must be suitable means of preventing smoke penetration into areas that are 

occupied. The proposed design accounts for this by proposing a barrier, which must 

comply with the smoke penetration requirements for the flight deck and the 

supernumerary compartment. This configuration is intended to allow supernumeraries 

to enter the main deck Class E cargo compartment and hence open the smoke barrier 

between the cargo compartment and the supernumerary compartment. The smoke 

barrier will remain closed at all times, except during TTL for Operation Type A and 

during passage between the upper and main decks. If fire/smoke has been detected in 

the main deck cargo compartment during TTL for Operation Type A, the door may be 

closed if directed by the pilot in charge. A placard indicating that the smoke barrier is to 

be secured (i.e., the door or curtain must be closed) at all times, will be posted in a 

conspicuous place, either on or next to the smoke barrier. 

10. Smoking will not be permitted in the main deck cargo compartment during any phase of 

flight. 

11. Live animals are less flammable cargo than other types of cargo thereby reducing the 

potential risk of exposing supernumeraries to fire and/or smoke. 

12. The following limitations are proposed and limitations a-c must be documented in the 

limitations section of the airplane flight manual: 

a. Prior to each flight, a flightcrew member must brief each supernumerary on the use 

of exits and emergency equipment, including evacuation instructions to inspect the 

ground to determine whether a safe landing can be achieved before using an assist 

means. 

b. The operator must determine that each supernumerary is physically able and 

trained to accomplish the necessary emergency procedures. 

c. Each supernumerary must be provided with a portable oxygen unit with a mask 

attached to it that they must carry whenever they are in the Class E cargo 

compartment. The supernumeraries must be trained in the use of the oxygen 

equipment. The supernumeraries must also be trained in making the determination 

whether oxygen is being delivered to the masks. The equipment must provide 

oxygen-flow indication. The oxygen units must be sized adequately for continuous 

and uninterrupted use during worst-case flight duration following decompression, 

or must be of sufficient duration to allow the supernumeraries to return to their 
Jamco America Inc.

Docket Management Facility 

Page 20 

October 2, 2013 

Letter: JODA-13-191 

seats where oxygen for the remainder of the decompression is readily accessible. 

The portable oxygen equipment must meet the requirements in 14 CFR 25.1443(a) 

or (b), or the equipment must be shown to protect the supernumeraries from 

hypoxia at an activity level required to return to their seats following a rapid 

decompression to 25,000 feet cabin altitude. Additionally, the portable oxygen 

equipment must: 

• meet § 25.1439(b)(1), (2), and (4), and 

• be designed to prevent any inward leakage to the inside of the mask, and 

• prevent any outward leakage causing significant increase in the oxygen content 

of the local atmosphere. 

d. An aural, automatically activated decompression alert must be present and 

immediately recognizable in accessible areas of the Class E cargo compartment to 

notify supernumeraries when to don oxygen masks. If there are two or more alerts 

that a supernumerary may hear or is expected to respond to, there must be an 

automatic visual alert in addition to the automatic aural alert. The pre-flight briefing 

must include training in the sound of the alert, the meaning of the alert, and the 

response to the alert (i.e., procedures for donning the masks and activating the flow 

of oxygen). 

e. A flightcrew-activated aural or visual signal, which is recognized in the Class E cargo 

compartment, must be installed. This aural or visual signal is to indicate that, in the 

event of fire or smoke in the Class E cargo compartment, persons must return to 

their seats and ensure that the smoke barrier is secured (i.e., the door or curtain is 

closed). Appropriate procedures and limitations must be established to ensure that, 

at the onset of a fire or smoke event, the flightcrew signals the supernumeraries to 

return to their seats and secure the smoke barrier. The preflight briefing must 

explain these signals to the supernumeraries. 

 
Jamco America Inc.

Docket Management Facility 

Page 21 

October 2, 2013 

Letter: JODA-13-191 

f. A placard located in the supernumerary area, in a conspicuous location either on or 

adjacent to the smoke barrier, must indicate the following: 

For operational type B 

• no access to the Class E cargo compartment is allowed during any airplane 

operation 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except for ground operations 

The pre-flight briefing must inform supernumeraries of these requirements. 

For operational type C 

• access to the Class E cargo compartment is limited to the care and handling 

of cargo requiring care/attention during flight access to the Class E cargo 

compartment is limited to a maximum of three supernumeraries 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except when entering or leaving the cargo compartment 

• a portable oxygen bottle (with mask attached) must be carried upon 

entering and while accessing the cargo compartment 

• smoking is not allowed within the cargo compartment

The pre-flight briefing must inform supernumeraries of these requirements. 

For operational type A 

• access to the Class E cargo compartment is limited to the care and handling 

of animals and cargo only 

• access to the Class E cargo compartment is limited to a maximum of 15 for 

the carriage of live animals and associated material 

• the smoke barrier must be secured (i.e., the door or curtain must be closed) 

except when entering or leaving the cargo compartment during cruise. The 

smoke barrier must be latched opened for TT&L for operational type A 

unless fire/smoke has been detected in the main-deck cargo compartment. 

If fire/smoke has been detected in the main-deck cargo compartment, the 

door may be closed if directed by the pilot in charge 

• a portable oxygen bottle (with mask attached) must be carried upon 

entering and while accessing the cargo compartment 

• smoking is not allowed within the cargo compartment

• the compartment must not be entered in case of fire/smoke being detected 

inside the Class E cargo compartment except during evacuation 

The pre-flight briefing must inform supernumeraries of these requirements. 

 
Jamco America Inc.

Docket Management Facility 

Page 22 

October 2, 2013 

Letter: JODA-13-191 

Public Interest 

Granting this exemption is in the public interest for the following reasons: 

• The FAA has previously granted several exemptions for the carriage of supernumeraries on freighter 

airplanes for similar petitions; 

• A significant disruption of air commerce could occur if the petition were not granted. 

• The owner/operator of the aircraft intends to use the aircraft to transport race horses, show horses, 

and bloodstock. These animals are very valuable, many worth over one million dollars each. The 

animals cannot be properly insured nor cared for during travel unless there are a sufficient number 

of qualified handlers on board who can access the animals during flight. 

• The industry standard for the air transport of horses recommends one supernumerary 

(groom/handler) for every three or four horses. The safe transport of large numbers of horses by air 

requires the carriage of a commensurate number of qualified grooms/handlers in the main deck 

cargo compartment. The owner/operator has determined that 15 supernumeraries will provide 

adequate care in all cases of expected operation. 

• The carriage of an appropriate number of animal handlers aboard an aircraft to monitor and to 

attend to the special requirements of live animal cargo, especially race horses and show horses, 

serves the public interest in raising the level of safety of the livestock, the airplane, the flight crew, 

and consequently, the public in general; therefore, this exemption serves the public interest for 

safety reasons and also for increased air freight deliveries of these animals internationally. 

• Other owners/operators may have a similar interest in this solution as there is clear economic 

benefit to both owners/operators as well as this installation activity and the overall US economy 

from this modification. Increased economic action is of clear public interest to the United States. 

• The passengers aboard these airplanes will not be revenue paying customers of commercial for hire 

airlines, but rather employees of the owner operator and specifically trained; therefore, there is no 

degradation to airline passenger safety and no detrimental impact on the public at large. 

• The project in question on this Boeing 747-400F Series aircraft is a case of the special market in 

which Jamco America, Inc. works. Owners and operators require configurations that use interior 

space in ways not anticipated in the original TCDS configurations which, in this case include access to 

the main deck cargo compartment during flight in support of animal care. In order to satisfy the 

customer requirements and maintain our marketing competitiveness, Jamco America, Inc. seeks to 

accommodate this configuration while providing an adequate level of safety for the flight crew and 

supernumeraries. 

• Jamco America, Inc. is a growing company based in Washington that provides aerospace engineering, 

certification, and manufactured assemblies for part 25 aircraft. The company employs over 300 US 

citizens and provides strong support to the local economy where these employees and facilities are 

located. Our success in an extremely competitive global economy will have a significant positive 

impact on the local and regional economy. 
Jamco America Inc.

Docket Management Facility 

Page 23 

October 2, 2013 

Letter: JODA-13-191 

• Granting this exemption will permit conclusion of this project, which will provide a significant income 

with positive impact on both the local and regional economies. This will aid both in the case of this 

specific project and future projects. 

• Approval of these exemptions will enable this Washington company working on Transport Category 

Airplanes to effectively compete in this global market. Stability and improved financial performance 

of this Washington company gives greater job stability to workers employed, thereby providing a 

stabilizing influence to the greater regional and the larger US economy due to the increased 

consumer spending capacity associated with stable workers. Improved financial performance of 

Washington owned and operated corporations and increased workforce stability translates into 

continued and improved local, state, and federal tax revenues, which in turn add to the stability of 

the overall United States economy. Washington is a net federal tax provider, that it to say that 

Washington provides more federal taxes than it receives in federal spending, thereby serving as a 

stabilizing influence to federal deficits. 

• Improved financial performance allows Washington corporations to continue to invest in Research 

and Development allowing the United States to maintain and improve its competitive position in the 

global economy. 

Public Comment and Publication 

In accordance with 14 CFR 11.29 and 11.87 Jamco America, Inc. requests that the period for public comment 

and publication be waived for the following reasons: 

• We do not expect any adverse comments 

• Granting these exemptions would not set precedents 

• These exemptions are near identical to previously granted exemption 10703, and are already 

recognized by the FAA on similar model aircraft 

• The issues are non-controversial 

• Delaying approval will delay the engineering deliverable which will delay the scheduled completion 

of this project, with resulting schedule backups and additional expense; 

• The inherent delaying action caused by publication in the Federal Register may cause delays in 

modifying the aircraft 

• Our petitions have been filed in a timely manner; prior to FAA approval of PNL. In keeping with our 

program schedule, we request that review and decision be made as soon as possible.