FAA-lDtD -05'11

March 18, 2010

Mr. Clint Jones or Mr. Phil Ford

Federal Aviation Administration

Transport Aircraft Directorate, ANM-1DO

1601 Lind Avenue, SW

Renton, WA 98057-3356

SA84NE Single Configuration

PETITION FOR EXEMPTION

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

SA84NE requests FAR compliance relief and submits this Petition for Exemption (PIE) to FAA

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

LEG petitions for US Govt. engineering relief on single tank Configuration of SA84NE for

8727-200 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP passenger cabin

(lOPA) deck plans.

Boeing SN 21460:

L This SN contains a VIP stateroom and are configured for HOS service.

2. This SN operates exclusively in private or Head of State (HOS) service.

3. This $N is listed on a foreign Registry.

4. This SN 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. Responsive engineering resources of the FAA can be conserved and financial relief

can be realized on behalf of the DAH and US Govt; upon timely approval of this PIE.

6. The Operator nor STC holder are able to determine if modifications to the AFS loading

points on this airframe have been altered, AFS brackets removed or, if the AFS attach

points have been adapted for other purposes; requiring in themselves new ICAs.

7. Operator disclosure and DAH-onboard AFS survey of the aircraft is required to submit

useful engineering for FAA that is relevant to SN existing condition.

8. It is the position of the STC holder that air safety will not be adversely impacted given

this SN has limited private use and, each at over 3D-years of airframe age, will likely

never return to commercial FAA/EASA air carrier service.

In the event this SN is 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 I DTI) 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).

Sincerely,

AS!' '0 0; i11'-iII'ropri<'<a<y (;)1•

~ FAAtJN

5;;-84'-'b Nola" Y1~

M:Jin office 3425 Gm//on Point Kirkbml WJS/,il}gton 9B03?, M:Jli) (425) 576-4030
L~Lz-~7)~~L-L

i

www.airspeed.us.com

March 25, 2010

ASE 100325-11 FRPE

PUBLIC COMMENT

Federal Register Petition for Exemption submittal for public comment:

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

of SA84NE requests FAR compliance relief and submits this Petition for Exemption (P/E)

to FAA rule making established under 14 CFR Sect. 26.47(c) & (e)(2).

LEG petitions for US Govt. engineering task relief on a single Configuration of SA84NE

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

cabin (LOPA) deck plans.

Boeing SNs 21460:

L This SN contains a VIP stateroom and is configured for HOS service.

2. This SN operates exclusively In private or Head of State (HOS) service.

3. This SN is listed on foreign Registry.

4. This SN will require extensive engineering changes for a deck plan (LOPA) to

be suitable for EASAor US commercial revenue service under FAR 121.

5, Responsive engineering resources of the FAA can be conserved and financial

relief can be realized on behalF of the DAH and US Government; upon timely

approval of this PIE.

6. The Operator nor STC holder are not able to determine if modifications to the

AFS loading points on this airframe have been altered, AFS brackets removed or,

if the AFS attach points have been adapted for other purposes; requiring in

themselves new lCAs.

7. Operator disclosure and DAH-onboard AFS survey of the aircraft is required to

submit useful engineering to FAA that is relevant to SN existing condition.

8. It is the position of the STC holder that air safety will not be adversely

impacted given this SN has limited private use and with over 3D-years of

airframe age, will likely never return to commercial FAAjEASA air carrier service.

In the event this SN is 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 (OTE j OTI) due FAA under the Aging

Aircraft Safety Rule for the AFS (and the attach points) can be accomplished in

accordance with FAR 26.47(c) and (e)(2).

Thank you.

Karl Seuring, Managing Director

The Leading Edge Group, LLC

Kirkland, WA 98033

Corpor~f:eoffice 3425 em/Ion Po/l)t Kirkhmd Wqshington 98033 Mpil (425) 576-4030