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 freighter 

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 turbulence, that persons must 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.

BACKGROUND:

VT MAE is the applicant for a multiple 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 supernumeraries are situated within the 

boundaries of the flight deck itself.
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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 small confine of the flight deck means that all supernumeraries and observers can 

easily hear any aural alerts through the flight deck speakers. 

iv. In any emergency, the flight crew can also easily sight and provide instructions and 

awareness to the supernumeraries. 

v. Furthermore, there will be instructions to the supernumeraries to remain 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 level 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 unintelligible.

vii. As such, ST Aero believes there is no need for a PA system.

EVALUATION 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 Attachment
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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 management personnel will be available at each flight 

destination. This will reduce shipping costs and transit time, 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 Amendments. Over time, this will have the effect of raising the safety level of 

the passenger airline fleets, which is in the public interest.

PETITION FOR EXEMPTION:

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 must 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 SUBRAMANIAM

Engineering Director

VT Mobile Aerospace Engineering, Inc.

Office: (251) 436-0186

E-mail: kumaresan.subramaniam@vtmae.com