March 22, 2010

Mr. Clint Jones or Mr. Phil Ford

Federal Aviation Administration

Transport Aircraft Directorate, ANM-100

1601 Lind Avenue, SW

Renton, WA 98057-3356

SA496NE Config #1,3,4,5, 7 & 9

PETITION FOR EXEMPTION

The Leading Edge Group, LLC (LEG), as FAA Supplemental Type Certificate (STC) holder of

SA496NE requests FAR compliance relief and submits this Petition for Exemption (P/E) to FAA

rulemaking established under 14 CFR Sect. 26.47(c) & (e)(2).

LEG petitions the US Government for engineering task relief on Configuration #1,3,4,7, & 9 of

SA496NE for 8727-200 aircraft, with LEG/pats Auxiliary Fuel Systems (AFS) in active Head of

State (HOS) service under US and foreign registry.

8727-200 are no longer flying in active EASA or FAR 121 commercial service.

1. All SNs except SN 22536 & SN 22537 are configured for VIP service.

2. SN 20641 has been destroyed.

2. SN 22536 & 22537 are owned by LEG (LEG/pats STC holder); configured in 156~seat

passenger LOPA, and are scheduled for VIP conversion and no commercial service ..

2. All SNs operate exclusively in private/HaS service.

3. The SN are / were registered in US and foreign registry.

4. All SNs will require extensive engineering changes for a deck plan (LOPA) to be

suitable for EASA or US commercial revenue service under FAR 121 (125 or 135).

5. Engineering resources of the US Govt. can be conserved and financial relief can be

realized on behalf of the DAH; upon timely approval of this PIE.

6. Air safety will not be adversely impacted given the limited VIP use and no active return

planned to FAR 121 service.

In the event these SNs are transferred to a third party and an interior change to the LOPA is

completed or, this 25-year old aircraft returns to US or EASA revenue passenger service that

specific AFS airframe load and inspection analysis (DTE / DTI) due FAA under the Aging Aircraft

Safety Rule for the LEG/pats system will be required by FAA to comply with §26.47(c) and (e}(2).

Sincerely,

T~'6 EOGE GROUP, LLC

Capt. K-ar Seuring, Managing Director

AirSpee~

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Cotporate Office 3425CHi/Ion Point Kirkland Washington 98033 Main (425) 576-4030
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March 25, 2010

ASE 100325·20 FRPE

PUBliC COMMENT

Federal Register Petition for Exemption submittal for public comment:

The Leading Edge Group, LLC (LEG), as FAA 5upplemental Type Certificate (STC) holder

of SA496NE requests FAR compliance reiief and submits this Petition for Exemption (P/E)

to FAA rule making estabiished under 14 CFR Sect. 26,47(c) & (e)(2).

LEG petitions for US Govt. engineering task relief on Configurations 1,3,4,5,7,8 & 9 of

SA496NE for B727-200 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP

passenger cabin (LOPA) deck plans,

SNs 21113, 20641, 21068, 21474, 21595, 21824, 21948, 22536, 22537 & 22359

L All SNs except SN 22536 & SN 22537 are configured for VIP service.

2, SN 20641 has been destroyed,

2, SN 22536 & 22537 are owned by LEG (LEG/pats STC holder); configured in

156-seat passenger LOPA, and are scheduled for VIP conversion and no

commercial service is planned.

3. The above SNs are or were registered in US and foreign registry.

4, All SNs will require extensive engineering changes for a deck plan (LOPA) to

be suitable for EASA or US commercial revenue service under FAR 121 (125 or

135),

5. Engineering resources of the US Govt. can be conserved and financial relief

can be realized on behalf of the DAH; upon timely approval of this PIE,

6. Air safety will not be adversely impacted given the limited VIP use and no

active return planned to FAR 121 service.

In the event these SNs are transferred to a third party and an interior reconfiguration

(LOPA) is completed, a current airframe survey to include #6 changes can be reviewed

and specific airframe load and inspection analysis (DTE / D11) due FAA under the Aging

Aircraft:Safety Rule for the AFS (and the attach points) can be completed in accordance

with FAR 26,47(c) and (e)(2),

Thank you,

Karl Seuring, Managing Director

The Leading Edge Group, LLC

Kirkland, WA 98033

Cotpotqfe ofJice 3425 Cm//on Poinf Kitk6nci Wqshingfon 96033 Mqli7 (425) 576-4030