FAA Atlanta 30th October, 2014

Subject: Petition for Revision to Exemption No. 11060 Reference: FAA Project Number ST14446AT-T Dear Mr. Avella, VT Mobile Aerospace Engineering, Inc. (VT MAE, formerly known as ST Aerospace Mobile , Inc) respectfully submits this letter to petition for a revision to Exemption Number 11060 (Attached to this letter as Appendix A). The exemption allowed the VT MAE Boeing 757-200 15- P freig hter configuration aircraft (757-200 15- ULD) to allow carriage of non -crewmembers, or ‘supernumerary’ personnel. However, an aural or visual annunciation that would be recognized in the supernumerary seating area had to be installed, to indicate, during tu rbulence, that persons mu st return to their seats (requirement 6 in the Exemption). A standard airplane public address (PA) system that is audible throughout the supernumeraries’ seating area also had to be installed (requirement 11 in the Exemption). VT MAE is requesting for a revision to the exemption so that the above 2 requirements are removed, for the following reasons set out in the letter below. **BA CKGROUND:**  VT MAE is the applicant for a mu ltiple aircraft Supplemental Type Certificate (STC) for conversion of Boeing 757-200 passenger aircraft into a 15- Unit Load device (ULD) position (15- P) freighter configuration under FAA Project Number ST14446AT-T. Under Exemption Number 11060 granted by the FAA on 23 September 2014, VT MAE was granted an exemption from 14 CFR 25.785(j), 25.785(g)(1) and (i)(1), 25.810(a)(1), 25.813(b)(1) and (6), 25.1445(a)(2) and 25.1447(c)(1) with certain limitations to allow the carriage of non -crewmembers or ‘supernumerary’ personnel. It is pertinent to note that the s upernumeraries are situated within the boundaries of the flight deck itself.Page 2

**GROUNDS FOR REVISION TO EXEMPTION NUMBER**  **11060:** i. The flight deck is enlarged to accommodate the additional supernumeraries, who will be seated directly behind the observers. See figure below on flight deck layout. ii. There is no obstacle or obstruction view between the flight crew and the supernumeraries. Hence there is no hindrance for visual and/or aural communications. iii. The sm all confine of the fl ight deck means that all supernumeraries and observers can easily hear any aural alerts through the flight deck speakers. iv. In any

e me rgency, the flight crew can also easily sight and provide instructions and awareness to the supernumeraries. v. Furthermore, there will be instruction s to the supernumeraries to rem ain seated with their seat belts fastened (see FAA Exemption Letter No. 11060, page 5, Section 25.785(j) Justification (last paragraph)). This will further enhance safety l evel during turbulence, take-off and landing. vi. There are also concerns that installing a speaker in the supernumeraries' seating area may cause feedback to the PA system; hence creating echo within the cockpit and making the announcement un intelligible. vii. As such, ST Aero believes there is no need for a PA system.

**EVA LUA** 

**TION OF PUBLIC INTEREST:**  Granting this petition is in the public interest because:  The presence of trained personnel on board the airplane when cargo is carried will enhance flight safety, which is in the public interest. Having a standard public address Inertia Reel Descent Device Holder Inertia Reel Descent Device AttachmentPage 3 system and aural annunciations that are audible by the supernumeraries in the flight deck will disturb and confuse the flight crew, which affects safety of flight.  Granting this exemption will enhance the utility of the airplane for the operator by ensuring that needed cargo ma nagem ent personnel will be available at each flight destinatio n. This will reduce shipping costs and transit tim e, which is in the public interest.  As Boeing 757-200 passenger airplanes are converted into 15P-configured airplanes, airlines will replace them with new passenger airplanes which meet newer 14 CFR Part 25 Am endm ents. Over tim e, this will have the effect of raising the safety l evel of the passenger airline fleets, which is in the public interest. **PETITION FOR EXEMPTI ON:**  Based on the information provided, VT MAE, hereby petitions for an amendment to Exemption Number 11060, for the removal of the requirements for the aural or visual annunciation that would be recognized in the supernumerary seating area to indicate, during turbulence, that persons mu st return to their seats (requirement 6 in the Exemption) and the installation of a standard airplane public address (PA) system that is audible throughout the supernumeraries’ seating area (requirement 11 in the Exemption). VT MAE respectfully requests favorable FAA consideration of this petition. Sincerely,

**Kumaresan SUBRA MA** **NIA M**  Engineering Director VT Mobile Aerospace Engineering, Inc. Office: (251) 436-0186 E- ma il: kum aresan. subramaniam @vtm ae.com