U.S. Department of T ransporta t ion Federal Aviation Administration

May 17 ,2012

Mr. Nick Olmsted Director of Certification BaySys Techno logies , 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 requi r e additional information. Page numbers re fer to pages in your petition for exemption. 

### Page 2 , Section 3 Please clarify all types of operations to be carried o ut, and cargo to be carried on, the main deck ofthe airplane. Include conditions that require persons to access the cargo compmtment during night (all cargo, no cargo & only l ive 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 state s to exit the cargo compartment, but appears to apply to smoke events as well as turbulence. A rev ision 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 simi lar petition for these regulation s" 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 th e 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 dep loyed and automatically inflated escape slides, which are for diffe rent exits than on the 747-400F airplane that is the subject of this petition. Please consider thi s difference in yo ur 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 eme rg e ncy evacuation s
. We would consider a ladder more hazardous than stairs. Therefore , at a minimum starting point, the special conditions fo r this ladder would be Special Conditions no. 25-430-SC. In consideration of your petition fo r exemption, additional special conditions may b e required for your request. T he FAA r equires more detail regarding the design of the ladder y ou propose. 

### Page 8, Section 5, paragraph d.6 Ex it arrangements for passenger airplanes converted to freig hter airplanes diff er 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 fre ighter airplanes have automatically dep loyed and automatically inflated escape slides, which a re fo r different exits than on the 747-400F airplane that is the subject ofthis petition. Please consider this difference in yo ur 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 freig hter airplane. The FAA do es not broadly apply an exe mption fo r one petitioner across a spectrum ofpetitioners. Rather, we consider exemptions from the regulation s on a case-by-case basis, taking into consideration the specifics involved in a petitioner's request fo r 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 fo r 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 us e in evacuation viaL 1 in the event of smoke. The process of using PB E during an evacuation down a ladder, operating an e mergenc y exit, and then evacuating down an escape slide is a novel approach. T he FAA requires details regarding how this will be demonstrated to e nsure thi s is possible , as we ll as demonstratin g the evacuation capability with the propo sed PBE. The FAA also requests that B aySys describe how they plan to address potential damage to the escape slide caused by the proposed PB E.

### 3

Page 10, Section 5, paragraph h BaySys proposes tha t 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 requireme nts. That is , the automatic presentation requirement in § 25.1447 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 yo ur 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 Tiangs U Manager, AirfTame/Cabin Safety , ANM-115 Transport Standards Staff Transport Airplane Directorate Aircraft Cet1ification S ervice