U.S. Department 

of Transportation 

Federal Aviation 

Administration 

May 17,2012 

Mr. Nick Olmsted 

Director of Certification 

BaySys Technologies, LLC 

18321 Parkway 

Melfa, VA 2341 0 

Dear Mr. Olmstead: 

Transport Airplane Directorate 

1601 Lind Avenue, S.W. 

Renton, Washington 98057-3356 

We have received your April26, 2012 petition, on behalfofBaySys Technologies, LLC, 

requesting exemption from§§ 25.785(d), 25.807(c)(l), 25.807(c)(5), 25.809(£)(1 ), 

25.813(b), 25.813(e), 25.857(e), and 25.1447(c)(l) ofTitle 14, Code ofFederal Regulations, 

for the 747-400F, project no. ST7169NY -T. Before we can continue processing your 

petition, we require additional information. Page numbers refer to pages in your petition for 

exemption. 

Page 2, Section 3 

Please clarify all types of operations to be carried out, and cargo to be carried on, the main 

deck of the airplane. Include conditions that require persons to access the cargo 

compmtment during night (all cargo, no cargo & only live animals, or animal/cargo 

combinations). An example of what the FAA has accepted in the past is contained in 

exemption number 8590. 

Page 5, Section 5, paragraph a.3.i 

The Return to Seat notice docs not include a notice to don Protective Breathing Equipment 

(PBE). It states to exit the cargo compartment, but appears to apply to smoke events as well 

as turbulence. A revision to the warning for smoke events requires donning a PBE, which 

would be consistent with previous exemptions. An example of what the FAA has accepted 

in the past is contained in exemption number 8590. 

Page 6, Section 5, paragraph c.l 

The FAA suggests that BaySys re-write the sentence, "We note that Exemption 1870E 

grants a similar petition for these regulations" to read, "We note that Exemption 1870E 

grants a similar exemption from these regulations," as we suspect this is the intended 

wording. The FAA does not issue petitions, but exemptions from the regulations. 
2 

Page 6, Section 5, paragraph c.2 

Exit arrangements for passenger airplanes converted to freighter airplanes differ from 

airplanes originally designed and built as freighter airplanes. For the 747-400F crew-service 

door, the escape slide is manually deployed and is automatically inflated. Passenger 

airplanes that are converted to freighter airplanes have automatically deployed and 

automatically inflated escape slides, which are for different exits than on the 747-400F 

airplane that is the subject of this petition. Please consider this difference in your reply to 

this inquiry. 

Page 6, Section 5, paragraph c.3 

To evacuate 8 or more persons from the upper deck, this section proposes using the ladder, 

which is installed on the 747-400F, for emergency evacuation from the upper deck to the 

main deck of the airplane, and then using the Door 1 left emergency exit. The FAA has 

never developed special conditions for this type of ladder. We have developed special 

conditions for stairs between passenger decks that can be used in emergency evacuations. 

We would consider a ladder more hazardous than stairs. Therefore, at a minimum starting 

point, the special conditions for this ladder would be Special Conditions no. 25-430-SC. In 

consideration of your petition for exemption, additional special conditions may be required 

for your request. The FAA requires more detail regarding the design of the ladder you 

propose. 

Page 8, Section 5, paragraph d.6 

Exit arrangements for passenger airplanes converted to freighter airplanes differ from 

airplanes originally designed and built as freighter airplanes. For the 747-400F crew-service 

door, the escape slide is manually deployed and is automatically inflated. Passenger 

airplanes that are converted to freighter airplanes have automatically deployed and 

automatically inflated escape slides, which are for different exits than on the 747-400F 

airplane that is the subject of this petition. Please consider this difference in your reply to 

this inquiry. 

Page 9, Section 5, paragraph c.4 

This section proposes that the FAA extend exemption number 1870E to accommodate the 

BaySys freighter airplane. The FAA does not broadly apply an exemption for one petitioner 

across a spectrum of petitioners. Rather, we consider exemptions from the regulations on a 

case-by-case basis, taking into consideration the specifics involved in a petitioner's request 

for exemption. If the BaySys petition meets appropriate criteria, the FAA may grant an 

exemption to BaySys, unique to the request, for the subject airplane(s), and for relief from 

the petitioned regulations. 

Page 9, Section 5, paragraph f.3.c 

This section states that PBE is available on the upper deck, for use in evacuation viaL 1 in 

the event of smoke. The process of using PBE during an evacuation down a ladder, 

operating an emergency exit, and then evacuating down an escape slide is a novel approach. 

The FAA requires details regarding how this will be demonstrated to ensure this is possible, 

as well as demonstrating the evacuation capability with the proposed PBE. The FAA also 

requests that BaySys describe how they plan to address potential damage to the escape slide 

caused by the proposed PBE. 
3 

Page 10, Section 5, paragraph h 

BaySys proposes that supernumeraries carry oxygen into the cargo compartment, which 

meets § 25.14 3 9 as a compensating factor in support of their exemption request for the 

automatic presentation requirements in§ 25.1447. It appears that BaySys may be confusing 

two different requirements. That is, the automatic presentation requirement in § 25.144 7 is 

for hypoxia protection, not smoke. Likewise, the proposed oxygen equipment should meet 

the minimum mass-flow requirements in§ 25.1443 for protection from hypoxia in the event 

of a decompression. Because supernumeraries could be in the cargo compat1ment during a 

smoke event as well, the oxygen equipment they carry should also meet the PBE 

requirements in§ 25.1439. An example of what the FAA has accepted in the past is 

contained in exemption number 8590. 

Page 10, Section 5, paragraph h 

The FAA requests that BaySys address several other minor oxygen issues regarding the 10 

percent extra oxygen specified in§ 25.1447 (quantity indication, flow indication, etc.). An 

example of what the FAA has accepted in the past is contained in exemption number 8590. 

Please re-submit your petition to address these issues, or submit a petition withdrawal if 

BaySys Technologies, LLC, cannot address these issues. 

We will advise you of our final decision on your petition as soon as possible after receiving 

the additional information. 

If you have questions in the meantime, please contact Jayson Claar at (425) 227-2194. 

Sincerely, 

. 

ad&ht · 

Franklin TiangsU 

Manager, AirfTame/Cabin Safety, ANM-115 

Transport Standards Staff 

Transport Airplane Directorate 

Aircraft Cet1ification Service