Jamco America Inc.

1018 80 th 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 identif ied 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 m ain 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 Typ e III exit in lieu of Type IV due to overwing constraints;

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

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

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

• 25.1447(c)(1) **(3)** (amendment 25-41) automatic presentation of O2 mas ks 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) t hrough (7).

This petition is based on Exemption 10703 and is in large part identical to relevant information quote d from the petitioner’s request in Exemption 10703.

Jamco America, Inc. has been contracted by Dubai Ai r Wing (DAW) for the completion of an interior modification of a Boeing model 747-412F (Freighter) airplane. The serial number of the airplane is 28 032 and is registered in the United Arab Emirates as A6-GGP

.

**Discussion:**

The owner/operator of the aircraft intends to opera te this freighter aircraft to transport types of ca rgo that require care, or inspection, or both, during flight (e.g., live animals), in addition to continuing th e original mission of carrying cargo freight. To support this usage of the aircraft, the owner/operator has reque sted 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.

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Letter: JODA-13-191 as defined herein, and once trained and qualified a nd during specific flight operations as listed belo w, be permitted access to the main deck cargo compartment in flight under limitations proposed below. The designation and purpose of supernumeraries is discu ssed in subparagraph a.3 below. These purposes and the necessary configuration of the aircraft are not in accordance with 14 CFR Part 25 regulations; therefo re, this petition is submitted to request specific exemption s.

Summary of proposed aircraft operations and applica bility of proposed exemptions hereafter referred to as “operation type” by alpha designator:

A. Operations for carriage of live animals, and associ ated material, in the main deck cargo compartment requiring care/attention during flight; no other ca rgo on the main deck.

For these operations the maximum number of supernum eraries 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, cruis e, 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 supernum eraries is 6 and the total airplane occupancy
is 8. No access is allowed into the main deck Clas s E cargo compartment during any airplane operation.

C. Operations for carriage of cargo on the main deck c argo compartment requiring care/attention during flight, and other cargo.

For these operations the maximum number of supernum eraries is 6 and the total airplane occupancy is 8. Access to the main deck Class E cargo compar tment 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, perta ining 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, perta ining to Boeing 747-400F Series aircraft: exemption from 14 CFR 25.807(c)(1), 25.80 7(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 ai rcraft to attend to live animal cargo.

• FAA Exemption 7900, dated October 1, 2002, pertaini ng to B747-100/200 cargo aircraft: exemption from 14 CFR 25.855(a), 25.807(d)(1), 25.8 57(e), and 25.1447(c), Allowance of up to 28 supernumeraries on the main deck of Boeing 74 7-100, -200 Series airplanes to attend to live animal cargo.Jamco America Inc.

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Letter: JODA-13-191

• FAA Exemption 8587B, pertaining to Boeing 747-400 S eries “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 aircra ft.

• 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 Bulleti n: 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 ha ve a firm handhold, there must be a handgrip or rai l along each aisle to enable occupants to steady them selves while using the aisles in moderately rough a ir. There are no seatbacks and only cargo boxes or empt y 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 han drail 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; the refore, there will be walls upon which to
lean.

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

a. In order to optimize the usage of the Boeing 747-40 0F 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 car e of sensitive cargo and loading and unloading tasks at any port of arrival. Their prese nce in the aircraft ensures they will be immediately available on arrival to handle the carg o. This is most important in case of transport of live animals, perishable goods, and it ems of value.
b. Some of the cargo items being transported may inclu de large live animals or valuable or perishable goods that cannot be left unattended, ev en for the duration of the flight, and the presence of personnel trained and qualified in thei r handling is necessary on the aircraft on which they are carried. Horses are routinely shippe d by air. Large live animals, such as horses, can endanger flight safety if left unattend ed 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 ha ve ground maintenance centers capable of performing necessary maintenance tasks f or the operator’s aircraft nor passenger flights to carry maintenance personnel to the locat ion. The additional capacity for company maintenance personnel on company flights increases flexibility of operation.
d. Non-crew member passengers carried on Boeing 747-40 0F Series airplanes are limited. These non-crew members, referred to below as “super numeraries”, shall be:

i. physically capable of performing their emergency an d normal cargo handling duties;
andJamco America Inc.

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Letter: JODA-13-191

ii. briefed in the aircraft-specific limitations and us e 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) ma y 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 Transport ation 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 u nloading 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 accompan ying a shipment made by or under the authority of the United States

. 10. A military courier, military route supervisor, mili tary cargo contract coordinator, or a flight crew member of another mil itary cargo contract air carrier or commercial operator, carried by a milita ry cargo contract air carrier or commercial operator in operations under a military cargo contract, if that carriage is specifically authoriz ed by the appropriate armed
forces.

v. The following maximum number of supernumeraries wil l be permitted access to the main deck cargo compartment during climb, cruise, a nd approach phases of flight for each operation type according to limitations of this exemption petition:

1. Operation type A: a maximum of 15 supernumeraries m ay 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 ma y be permitted access to the main deck cargo compartment.

4. Handhold provisions on the upper deck per the requi rements of 14 CFR 25.785(d) are retained. The installation of handholds in the main deck carg o compartment is impractical. The absence of handholds is mitigated by a crew operated turbulenc e alert system to alert the supernumeraries in the cargo compartment to return to their seats a t the onset of turbulence. This mitigation is similar to FAA approved exemption 8587B.

5. We propose installation of modified aural/visual al erting systems. There will be three separate,
distinctive alerts:

i. Decompression Alert: Automatically activated aural and visual decompress ion 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 returnJamco America Inc.

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to their seats. As a backup to the automated alert system, the flight crew will be able to manually activate the alerts. The visual decompress ion alert will be distinguishable from the fire/smoke and turbulence alerts. The pre-flig ht 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 s ignal will be provided and immediately recognizable in accessible areas of the main deck C lass E cargo compartment to notify supernumeraries to immediately return to their seat s, secure the smoke barrier, and, as necessary, don their oxygen masks. As a backup to t he automated alert system, the flight crew will be able to manually activate the a lerts. The visual fire/smoke alert will be distinguishable from the decompression and turbulen ce 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 de ck Class E cargo compartment, will be installed to indicate during turbulence, or anticip ated turbulence, that supernumeraries
return to their seats. The visual turbulence alert will be distinguishable from the decompression and fire/smoke alerts. Appropriate p rocedures and limitations must be established to ensure that the flight crew member a lerts 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 m ain deck cargo compartment to permit announcements from the flight deck or any interphon e 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 limitati on 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 s pecified in 14 CFR 121.583(a)(1) through 121.583(a)(7).

iii. Supernumeraries are prohibited from being in the ca rgo area during taxi, takeoff, and landing. The pre-flight briefing will inform the s upernumeraries of this requirement.

iv. Access into the main deck cargo compartment in-flig ht is divided into three different operational types:

• Operation Type A: Carriage of live animals requirin g 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 mai n deck cargo compartment by a maximum of 15 supernumeraries is permitted dur ing climb, cruise, and approach.

• Operation Type B: Cargo only, which does not requir e care/attention during flight, and no live animals requiring care/attentio n during flight. The maximumJamco America Inc.

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Letter: JODA-13-191 number of supernumeraries is 6 and the total airpla ne 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 brie f 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 loc ations and orientations, during all expected operational conditions, including a ra pid 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 t he ambient noise level will
increase
vii. An aural, automatically activated decompression ale rt must be present and immediately recognizable in accessible areas of the Class E car go 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 ale rt. 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 activat ing 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 the ir seats. Appropriate procedures and
limitations must be established to ensure that the flightcrew signals the supernumeraries to return to their seats at the ons et 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, whic h is recognized in the Class E cargo compartment, must be installed. This aural or visua l signal is to indicate that, in the event of fire or smoke in the Class E cargo compart ment, 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 esta blished to ensure that, at the onset of a fire or smoke event, the flightcrew signals th e supernumeraries to return to their seats and secure the smoke barrier. The preflight b riefing must explain these signals to the supernumeraries.Jamco America Inc.

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Letter: JODA-13-191 **b. 25.807(c)(1)(5) (Amdt.25-67)** 

25.807(c)(1) requires that one Type III passenger e mergency 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 prov ided if Type IV exits are specified but cannot be located o ver the wing. Jamco America, Inc. requests that th e DAW Boeing 747-400F Series aircraft be exempted fro m 14 CFR 25.807(c)(1)(5) (Amdt.25-67).

**Justification:**

1. Exemptions 10703 and 1870E grant exemptions from th ese 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); how ever, this exit has a step up feature and cannot be classified as a Type I emergency exit. T his door was approved as an emergency exit for five flight crew members and three [supern umeraries] per the original exemption 1870. This door has an escape slide that is manual ly deployed, automatically inflated, and capable of withstanding 25 knot winds. We propose t o maintain this escape slide.
b. According to exemptions 10703 and 8536A the right s ide upper deck crew service door, with a manually deployed and automatically inflated esca pe 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 harne ss 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 Exem ption 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 ove rhead emergency hatch, with inertial drop reels, has been approved for evacuati on of up to 8 persons.

ii. Increasing the upper deck passenger count to 19 req uires that 11 of those use an alternate emergency escape path.
iii. We therefore propose an alternate left side path fo r evacuation for at least 11 of the 19 proposed supernumeraries on the upper deck.

iv. No flight deck door may be installed between the su pernumerary compartment and flight deck that would prevent access to the overhe ad 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.

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i. We propose that the left side main deck L1 door be utilized for evacuation, in addition to the left side flight deck overhead emer gency 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 certific ate 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 t his aircraft is more conservative than a passenger configured aircraft b ecause this aircraft is intended for private use only and the upper deck passengers would be supernumeraries, persons that are both physically qualified and spec ifically trained in the aircraft configuration and evacuation procedures. This train ing/qualification process can be reasonably expected to ensure that supernumeraries are more physically able and more mentally ready than the average commercial pas sengers to evacuate the upper deck, if necessary, down the stairs and out t he left side main deck L1 door. We propose to show this by demonstration, test, ana lysis, 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 trea ds.

3. With the airplane in level attitude and in each att itude resulting from the collapse of one or more legs of the landing gear, t he stairway will have entrance, exit, and gradient characteristics that a llow the upper deck supernumeraries to evacuate and exit the airplane t hrough the L1 main deck exit. This will be shown by demonstration, tes ts, analysis, or any
combination thereof.

4. The stairway must accommodate the carriage of an in capacitated occupant from the upper deck to the main deck and vice versa . The crew member procedures for such carriage must be established an d included in the Airplane Flight Manual.

5. The stairway must be located to provide occupants a n 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 minimi ze 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 illumin ation is not less than 0.05 foot-candle. This is in lieu of compliance with § 2 5.812(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), a t Amendment 25-116, will be provided on the upper deck near the stairwa y visible to supernumeraries on the upper deck as required by § 25.811(d)(1), at
Amendment 25-88.Jamco America Inc.

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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 s ide to allow occupants to steady themselves during foreseeable conditions, including, but not limited to, gear collapse on the ground and moderat e turbulence in flight. The handrail(s) must be constructed with no obstruc tion 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 t erminated in a manner that will neither interfere with occupants walking by nor create a hazard (such as catching clothing). The petitioner must de monstrate that the design can accommodate the stature of a fifth-perce ntile female and a ninety-fifth-percentile male.

12. The public-address system must be intelligible in t he stairway during all flight phases.

13. "No smoking" and "return to seat" signs must be ins talled and visible in the stairway both going up and down, and at the stairwa y entrances.
14. During any flight operation where more than 8 perso ns are on the flight, the stair must remain installed between upper and m ain 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 appro ximately 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.

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v. Pictures of the stairway are included for clarifica tion, showing the proximity of the stairway to the left side main deck L1 door.

**Figure 1: Main deck cargo compartment, facing forwa rd** 

**Figures 2: view looking up stairs Figure 3: view looking down stairs** Jamco America Inc.

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f. Smoke propagation testing:

i. Smoke propagation testing will be conducted to meas ure 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 wil l be provided to the FAA, including
video documentation.

ii. Testing will demonstrate whether there is a signifi cant “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 emergenc y hatch.

iii. Testing will demonstrate the ability of a crew to s afely 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 do or 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 unde r excessive smoke conditions.

g. There shall be door-operating markings on the insid e 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 testin g will not be required.

i. Evacuation procedures will be included in the FAA a pproved training plan for this exemption
& STC. j. The following limitations are proposed and limitati ons i-iii will be documented in the limitations section of the airplane flight manual:

i. Prior to each flight, a flightcrew member must brie f each supernumerary on the use of exits and emergency equipment, including evacuat ion instructions to inspect the ground to determine whether a safe landing can be a chieved before using an assist

means. ii. The operator must determine that each supernumerary is physically able and trained to accomplish the necessary emergency proce dures.
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 d rop reels adjacent to the door. This modification includes the door-operating markings o n the inside of the airplane; interior illumination system; assist means; attachm ent point for a liferaft mooring line; and exterior markings.
iv. The stairway will comply with the requirements list ed 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 ai d in evacuation in the event of smoke. The supernumeraries must be trained in the u se of the PBE.Jamco America Inc.

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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 th an six (6) feet from the ground with all landing gear extended and that the assist means deploy auto matically. 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 the se 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 as sist means. The right side upper deck crew service door is currently configured with a ma nually opened door with an automatically inflating escape slide. Exemption 18 70E and Boeing’s reported experience with 747 model aircraft equipped with this assist m eans as discussed in 1870E provides evidence that the current right side upper deck cre w service door meets the requirements of 25.809(f)(1)(i) and provides adequate means of egre ss for up to 19 persons when combined with limitations on supernumeraries that are physic ally 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 aircr aft have the manually deploying escape slide; commonality of configuration and crew traini ng is an economic benefit.

4. A Boeing survey of similar aircraft (discussed in 1 870E) documented that the majority of affected airplanes in service are equipped with man ually deployed escape slides. No adverse experience has been reported with these manually de ployed escape slides provided for specially trained crew which supports the continuat ion 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 perso ns 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 S eries aircraft meets the existing 25 knot wind requirement per the Type Certificate. We prop ose 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, su pplemental inertial drop reels and escape harnesses for each inertial drop reel will be insta lled 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 demonstra ted to be effective at providing safe evacuation out the right side upper deck crew servi ce 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 t he case of the 747-200F, and should not require demonstration of a right side evacuatio n. 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 brie f 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 minim um 8 inertia reels and harnesses installed on the flight deck, a minimum of 11 inert ia reels and harnesses must be
installed at a location that can be used for exitin g the crew-service door when the installed escape slide is not self-supporting on th e 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 an d 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 em ergency exit requires installation of 11 escape harnesses, 11 inertial drop reels, and one l ife raft mooring line attachment point adjacent to the main deck L1 door.

11. This modification will ensure that one escape harne ss 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 brie f 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 d rop reels adjacent to the door. This modification includes the door-operating markings o n 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 emergenc y exit covered by 25.809(f), there must be enough space next to the exit to allow a crew membe r to assist in the evacuation of passengers without reducing the unobstructed width of the pass ageway 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 th ese 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 no t have adequate space to provide the required assist space during an evacuation.
b. Adequate space has been demonstrated to be availabl e in the flight deck for flight crew to assist "crew" in evacuating from the left side flig ht deck overhead emergency hatch.

c. Adequate space exists in the vicinity of the left s ide 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, a nd how to evacuate the airplane with this equipment.

4. The flight crew and supernumeraries will be special ly trained and benefit from a higher level of aircraft knowledge than the common public on a comm ercial 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 ree ls. Since these persons will not be paying passengers but rather flight crew and specially tra ined and qualified supernumeraries, we feel that the absence of the required assist space at th e right side upper deck crew service door is compensated for by this additional training and kno wledge, 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 brie f 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 compa rtment to airplanes used only for the carriage of cargo. Jamco America, Inc. requests that the DAW B oeing 747-400F Series aircraft be exempted from 14 CFR 25.857(e) (Amdt.25-60).

**Justification:**

1. Exemptions 10703, 6463, and 7900 grant exemptions f rom these regulations for similar petitions.
2. One of the primary aspects of this petition is to p ermit access to the main deck cargo compartment during flight, under specific limitatio ns. 3. We propose to maintain the Class E classification o f 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 a nd upper decks, and during TTL for Operation Type A. If fire/smoke has been detec ted in the main deck cargo compartment during TTL for Operation Type A, the do or 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 compar tment 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 d eck 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 Oper ation 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 overhe ad) will be available in the main deck cargo compartment and in the path from the upp er deck to the left side main deck
L1 door.

12. Exit signage will be modified to the new configurat ion.
13. Additional firefighting gear (gloves, fire extingui shers) will be stored in the main deck
cargo compartment.
14. The following limitations are proposed and limitati ons a and b must be documented in the limitations section of the airplane flight manual:

a. The supernumeraries are limited to the categories s pecified 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 a re 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 si zed adequately for continuous and uninterrupted use during worst-case flight dura tion following decompression, or must be of sufficient duration to allow the supe rnumeraries to return to theirJamco America Inc.

Docket Management Facility Page 16 October 2, 2013

Letter: JODA-13-191 seats where oxygen for the remainder of the decompr ession is readily accessible. The portable oxygen equipment must meet the require ments in 14 CFR 25.1443(a) or (b), or the equipment must be shown to protect t he supernumeraries from hypoxia at an activity level required to return to their seats following a rapid decompression to 25,000 feet cabin altitude. Additi onally, the portable oxygen equipment must:

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

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

• prevent any outward leakage causing significant inc rease 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 c onspicuous location either on or adjacent to the smoke barrier, must indicate the fo llowing:

For operational type B

• no access to the Class E cargo compartment is allow ed during any airplane operation

• the smoke barrier must be secured (i.e., the door o r 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 acc ess to the Class E cargo compartment is limited to a maximum of three supern umeraries

• the smoke barrier must be secured (i.e., the door o r curtain must be closed) except when entering or leaving the cargo compartme nt

• 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 materia l

• the smoke barrier must be secured (i.e., the door o r curtain must be closed) except when entering or leaving the cargo compartme nt during cruise. The smoke barrier must be latched opened for TT&L for o perational type A unless fire/smoke has been detected in the main-dec k cargo compartment. If fire/smoke has been detected in the main-deck ca rgo compartment, the door may be closed if directed by the pilot in char ge

• 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 compartmentJamco 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 ai d in evacuation in the event of smoke. The supernumeraries must be trained in the u se 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 dispensin g units must be automatically presented to the occupants before the cabin pressur e altitude exceeds 15,000 feet and oxygen dispensing units be available in each lavatory. Th ese 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 f rom these regulations for similar petitions.
2. When supernumeraries are seated or while in the lav atory 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 syste m indicates to main deck cargo compartment occupants the need to immediately don t heir portable oxygen mask and return to their seats in the event of a decompressi on event.
3. Supernumeraries will be trained regarding the locat ion and use of the oxygen equipment and the alert conditions requiring their use. 4. Supernumeraries are required to carry portable oxyg en bottles, with a mask connected to it, while in the main deck Class E cargo compart ment. This equipment will be stored in the main deck cargo compartment, easily accessib le 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 al lowed 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 perform ance 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 sea t 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 emergen cy situations of short duration.

a. See AVOX Systems http://www.avoxsys.com/pdf/product s/portable-oxygensystems/MA-1-PN-9000A-3-portable-oxygen-cylinder-an d-regulator.pdfJamco 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 protect ive 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 dev ice 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 whe ther oxygen is being delivered to the dispensing units. Supernumeraries will be trai ned in making the determination whether oxygen is being delivered to the masks.

8. Due to the way that fire in the cargo compartment i s to be controlled, it is necessary to limit persons on board the airplane to those who th e 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 pe netration 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 in tended to allow supernumeraries to enter the main deck Class E cargo compartment an d hence open the smoke barrier between the cargo compartment and the supernumerary compartment. The smoke barrier will remain closed at all times, except dur ing 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 Oper ation Type A, the door may be closed if directed by the pilot in charge. A placa rd indicating that the smoke barrier is to be secured (i.e., the door or curtain must be close d) at all times, will be posted in a conspicuous place, either on or next to the smoke b arrier.
10. Smoking will not be permitted in the main deck carg o compartment during any phase of flight.

11. Live animals are less flammable cargo than other ty pes of cargo thereby reducing the potential risk of exposing supernumeraries to fire and/or smoke.

12. The following limitations are proposed and limitati ons a-c must be documented in the limitations section of the airplane flight manual:

a. Prior to each flight, a flightcrew member must brie f each supernumerary on the use of exits and emergency equipment, including evacuat ion instructions to inspect the ground to determine whether a safe landing can be a chieved before using an assist

means.
b. The operator must determine that each supernumerary is physically able and trained to accomplish the necessary emergency proce dures.

c. Each supernumerary must be provided with a portable oxygen unit with a mask attached to it that they must carry whenever they a re 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 si zed adequately for continuous and uninterrupted use during worst-case flight dura tion following decompression, or must be of sufficient duration to allow the supe rnumeraries to return to theirJamco America Inc.

Docket Management Facility Page 20 October 2, 2013

Letter: JODA-13-191 seats where oxygen for the remainder of the decompr ession is readily accessible. The portable oxygen equipment must meet the require ments in 14 CFR 25.1443(a) or (b), or the equipment must be shown to protect t he supernumeraries from hypoxia at an activity level required to return to their seats following a rapid decompression to 25,000 feet cabin altitude. Additi onally, the portable oxygen
equipment must:

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

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

• prevent any outward leakage causing significant inc rease in the oxygen content of the local atmosphere.

d. An aural, automatically activated decompression ale rt 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 res pond 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, th e 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, whic h is recognized in the Class E cargo compartment, must be installed. This aural or visua l signal is to indicate that, in the event of fire or smoke in the Class E cargo compart ment, persons must return to their seats and ensure that the smoke barrier is se cured (i.e., the door or curtain is closed). Appropriate procedures and limitations mus t be established to ensure that, at the onset of a fire or smoke event, the flightcr ew 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 c onspicuous location either on or adjacent to the smoke barrier, must indicate the fo llowing:

For operational type B

• no access to the Class E cargo compartment is allow ed during any airplane operation

• the smoke barrier must be secured (i.e., the door o r 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 acc ess to the Class E cargo compartment is limited to a maximum of three supern umeraries

• the smoke barrier must be secured (i.e., the door o r curtain must be closed) except when entering or leaving the cargo compartme nt

• 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 materia l

• the smoke barrier must be secured (i.e., the door o r curtain must be closed) except when entering or leaving the cargo compartme nt during cruise. The smoke barrier must be latched opened for TT&L for o perational type A unless fire/smoke has been detected in the main-dec k cargo compartment. If fire/smoke has been detected in the main-deck ca rgo compartment, the door may be closed if directed by the pilot in char ge

• 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 f or the following reasons:

• The FAA has previously granted several exemptions f or the carriage of supernumeraries on freighter airplanes for similar petitions;

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

• The owner/operator of the aircraft intends to use t he aircraft to transport race horses, show horses, and bloodstock. These animals are very valuable, ma ny worth over one million dollars each. The animals cannot be properly insured nor cared for du ring travel unless there are a sufficient number of qualified handlers on board who can access the a nimals during flight.

• The industry standard for the air transport of hors es recommends one supernumerary (groom/handler) for every three or four horses. Th e safe transport of large numbers of horses by air requires the carriage of a commensurate number of q ualified grooms/handlers in the main deck cargo compartment. The owner/operator has determine d that 15 supernumeraries will provide adequate care in all cases of expected operation.

• The carriage of an appropriate number of animal han dlers aboard an aircraft to monitor and to attend to the special requirements of live animal c argo, especially race horses and show horses, serves the public interest in raising the level of safety of the livestock, the airplane, the flight c rew, and consequently, the public in general; therefore, this exemption serves the public interest for safety reasons and also for increased air freight d eliveries 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 in stallation activity and the overall US economy
from this modification. Increased economic action i s of clear public interest to the United States.

• The passengers aboard these airplanes will not be r evenue paying customers of commercial for hire airlines, but rather employees of the owner operato r and specifically trained; therefore, there is no degradation to airline passenger safety and no detr imental impact on the public at large.

• The project in question on this Boeing 747-400F Ser ies aircraft is a case of the special market in which Jamco America, Inc. works. Owners and operato rs require configurations that use interior space in ways not anticipated in the original TCDS configurations which, in this case include access t o the main deck cargo compartment during flight in su pport of animal care. In order to satisfy the customer requirements and maintain our marketing co mpetitiveness, Jamco America, Inc. seeks to accommodate this configuration while providing an a dequate level of safety for the flight crew and supernumeraries.

• Jamco America, Inc. is a growing company based in W ashington 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 e conomy where these employees and facilities are located. Our success in an extremely competitive g lobal 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 t his project, which will provide a significant incom e 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 Washi ngton company working on Transport Category Airplanes to effectively compete in this global mar ket. Stability and improved financial performance of this Washington company gives greater job stabil ity to workers employed, thereby providing a stabilizing influence to the greater regional and t he larger US economy due to the increased consumer spending capacity associated with stable w orkers. Improved financial performance of Washington owned and operated corporations and incr eased workforce stability translates into continued and improved local, state, and federal ta x 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 rece ives in federal spending, thereby serving as a stabilizing influence to federal deficits.

• Improved financial performance allows Washington co rporations to continue to invest in Research and Development allowing the United States to maint ain and improve its competitive position in the global economy.

**Public Comment and Publication**

In accordance with 14 CFR 11.29 and 11.87 Jamco Ame rica, Inc. requests that the period for public comm ent 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 g ranted exemption 10703, and are already recognized by the FAA on similar model aircraft

• The issues are non-controversial

• Delaying approval will delay the engineering delive rable which will delay the scheduled completion of this project, with resulting schedule backups an d 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; p rior to FAA approval of PNL. In keeping with our program schedule, we request that review and decisi on be made as soon as possible.