AERO UNION CORPORATibN r 

100 Lockheed Avenue 

Chico, CA 95973 

Phone: (530) 230-1900 Fax: (530) 230-1926 

To: The US Department of Transportation CC: Federal Aviation Administration 

Docket Operations Los Angeles Aircraft Certification Office 

Wes^Building Ground Floor^ _ ___Att"-¥''-il^LAtimjr^N\^J^20L)^ 

Rbom^T^T40 "^^"^ 3960 Paramount Blvd. 

1200 Jersey Avenue, SE Lakewood, CA 90712 

Washington, DC 20590 

PETITION FOR EXEMPTION 

Through submission to the Department of Transportation's Federal Docket Management 

System (FDMS) I am petitioning the Federal Aviation Administration (FAA) for an 

exemption from the requirements of Title 14, Code of Federal Regulations (CFR) part 

26.47. This exemption is requested for supplemental type certificates (STCs) 

ST00353LA and SA8009NM held by Aero Union Corporation. These STCs install 3000 

gallon retardant tanks on Lockheed 188A and 188C airplanes for the purpose of 

dispensing of fire fighting materials. 

We request relief from the following regulation: 

26.47 Holders of and applicants for a supplemental type certificate—Alterations 

and repairs, which requires development of damage tolerance data for repairs and 

alterations. 

We support this request with the following information: 

Reasons Why the Exemption Would Not Adversely Affect 

Public Safety 

Granting this exemption would not adversely affect safety as the 

two subject STCs are for aerial dispensing of liquids. As part of 

the certification, we obtained an exemption to the noise 

requirements in accordance with 14 CFR part 21.93(b)(3)(ii). 

Which specifically exempts propeller driven transport airplanes 

designated for dispensing of fire fighting materials from the noise 

requirements. Therefore, these aircraft can not be operated under 

14 CFR part 121 or 129 without a further showing of compliance 

to the noise regulations. The exemption to 14 CFR part 

21.93(b)(3)(ii) is specifically documented on the subject STCs. 

As the aircraft modified by these STCs can not operate under 14 

CFR parts 121 or 129, without further showings of compliance, a 

Aero Union Corporation 1 of 2 03/08/2010 
damage tolerance based inspection program for 14 CFR part 121 or 

129 operators would not add any benefit to the public. 

In addition, because these aircraft have been modified specifically 

for the purpose of aerial dispensing of liquids it is unlikely that 

they would be utilized for 14 CFR part 121 or 129 operations in 

the future. 

The FAA in its published final rule excluded a number of different 

transport category aircraft types from the Design Approval Holder, 

Electrical Wiring Interconnection Systems, and Aging Aircraft 

Safety Rule Damage Tolerance operating requirements. These 

aircraft types were excluded on the basis that no examples were 

currently operating under 14 CFR parts 121 or 129. The reasons 

presented above are consistent with the FAA's approach and, 

therefore. Aero Union Corporation should not be required to 

develop the data required by 14 CFR part 26, Subpart E, 26.47 

requirements to support compliance with the operating rules for 

STCs ST00353LA and SA8009NM. 

Reason the Exemption Would Benefit the Public Interest 

Aero Union Corporation considers that grant of this exemption 

would negate the need for FAA to evaluate the large quantity of 

data required to support compliance with these regulations; none of 

these aircraft currently operate in the United States under Part 121 

or Part 129 and as discussed above are unlikely to do so in the 

future. Therefore, grant of this exemption would in turn reduce the 

burden on FAA resources and consequently public expenditure. 

Additional Information 

Aero Union Corporation is a commercial entity, and as such would 

be required to recover any costs associated with developing the 

damage-telefanee-based inspection programs^ required by"the^4 — 

CFR part 26.47 regulation. However, as none of these airplanes are 

operating under Part 121 or Part 129 there is no possibility of Aero 

Union Corporation ever recovering these costs. 

Sincerely, 

I(?>&1vlueller 

Engineering Manager 

FAA DER Candidate 

Aero Union Corporation 

(510)304-6453 

Jmueller(g)aerounion.com 

Aero Union Corporation 2 of 2 03/08/2010