# 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 SNcontains aVIP stateroom and are configured for HOSservice. 2. This SN operates exclusively in private or Head of State (HOS) service. 3. This $N is listed on a foreign Registry. 4. This SNwill require extensive engineering changes for a deck plan (LOPA) to be suitable for EASAor UScommercial revenue service under FAR 121 (125 or 135). 5. Responsive engineering resources of the FAAcan be conserved and financial relief can be realized on behalf of the DAH and USGovt; 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, AFSbrackets removed or, if the AFSattach points have been adapted for other purposes; requiring in themselves new ICAs. 7. Operator disclosure and DAH-onboard AFSsurvey of the aircraft is required to submit useful engineering for FAAthat is relevant to SNexisting condition. 8. It isthe 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/EASAair carrier service. In the event this SN istransferred 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 

## IDTI) due FAAunder the Aging Aircraft safety Rule for the AFS(and the attach points) can be completed in accordance with FAR26.47(c) and (e)(2). Sincerely, AS!' 

## '00; 

## i11'-iII'ropri<'<a<y

## (;)1•



# ~ FAAtJN 5;;-84'-'b Nola" Y

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

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### 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 FAASupplemental Type Certificate (STC) holder of SA84NE requests FARcompliance relief and submits this Petition for Exemption (P/E) to FAArule making established under 14 CFRSect. 26.47(c) 

### & (e)(2). LEGpetitions for USGovt. engineering task relief on asingle Configuration of SA84NE for B727-200 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP passenger cabin (LOPA) deck plans. Boeing SNs21460: L This SN contains aVIP stateroom and isconfigured for HOSservice. 2. This SNoperates exclusively In private or Head of State (HOS) service. 3. This SN is listed on foreign Registry. 4. This SNwill require extensive engineering changes for a deck plan (LOPA) to be suitable for EASAor UScommercial revenue service under FAR 121. 5, Responsive engineering resources of the FAAcan be conserved and financial relief can be realized on behalFof the DAH and USGovernment; upon timely approval of this PIE. 6. The Operator nor STCholder are not able to determine if modifications to the AFSloading points on this airframe have been altered, AFS brackets removed or, ifthe AFSattach points have been adapted for other purposes; requiring in themselves new lCAs. 7. Operator disclosure and DAH-onboard AFSsurvey of the aircraft is required to submit useful engineering to FAAthat is relevant to SNexisting condition. 8. It isthe position of the STCholder 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 FAAjEASAair carrier service.

In the event this SN istransferred to athird party and an interior reconfiguration (LOPA) iscompleted, a current airframe survey to include #6 changes can be reviewed and specific airframe load and inspection analysis (OTEj OTI) due FAAunder the Aging Aircraft Safety Rulefor the AFS(and the attach points) can be accomplished in accordance with FAR26.47(c) and (e)(2). Thank you.

Karl Seuring, Managing Director The Leading Edge Group, LLC Kirkland, WA 98033
Corpor~f:e 

### office 3425 em/Ion Po/l)t Kirkhmd Wqshington98033 Mpil (425) 576-4030