FAA Atlanta 30 th 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 re vision 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, t hat persons must return to their seats (requirement 6 in the Exemption). A standard airplane public ad dress (PA) system that is audible throughout the supernumeraries’ seating area also had to be insta lled (requirement 11 in the Exemption). VT MAE is requesting for a revision to the exemption so t hat 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 airc raft 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 allo w the carriage of non-crewmembers or ‘supernumerary’ personnel. It is pertinent to not e that the supernumeraries are situated within the boundaries of the flight deck itself.Page 2 GROUNDS FOR REVISION TO EXEMPTION NUMBER 11060:

i. The flight deck is enlarge d to accommodate the additional supernumeraries, who will be seated directly behind the observers. S ee figure below on flight deck layout.

ii. There is no obstacle or obstruction view betwe en 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 s upernumeraries and observers can easily hear any aural alerts thro ugh 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 inst ructions to the super numeraries to remain seated with their seat belts fastened (see FAA Exemption Letter No. 11060, page 5, Section 25.785(j) Justification (last parag raph)). This will further enhance sa fety level during turbulence, takeoff and landing. vi. There are also concerns that installing a sp eaker in the supernumeraries' seating area may cause feedback to the PA system; hence creatin g 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 boar d 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