f/tr1- WID - O~5L

March 22, 2010

Mr. Glint Jones or Mr. Phil Ford

Federal Aviation Administration

Transport Aircraft Directorate, ANM~100

1601 Lind Avenue, SW

Renton, WA 98057+3356

ST00466NY Configurations 1, 2 & 3

PETITION FOR EXEMPTION

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

ST00466NY 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 tank Configurations 1, 2 and 3 of ST00466NY for

87274100 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in VIP passenger cabin

(LOPA) deck plans.

Boeing SNs 19254 & SN 20327;

1. These SNs contain a VIP stateroom and are configured for HOS service.

2. These SNs operate exclusively in private or Head of State (HOS) service.

3. These SNs are listed on foreign Registries.

4. These 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).

S. Responsive engineering resources of the FAA can be conserved and financial relief

can be realized on behalf of the DAH and U5 Govt; upon timely approval of this PIE.

6, The Operators 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

these SNs have limited private use and, each at over 30-years of airframe age, will likely

never return to commercial FAA/EASA air carrier service.

In the event any of 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 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,

ASE iO'('} L2 - f ~oprietaryt1JI N

TH~DI

Capt. Kar(

AirSpeed '"

G EjSE GROUP, LLC

g, Managing Director

£..,

STOt' L\{;f. N 'f

FAA VI N

Nota<y Y l(fj

M'lil)of lice 3425 C'lnl/on Point Kirklqnd W'lshingtoIJ 98033 M'lin (425) 576-4030
ASE 100323-19 FRPE

PUBUC COMMENT

www.airspeed.us.com

March 23, 2010

Federal Register Petition for Exemption submittal for public comment:

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

of ST00466NY 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 tank Configurations 1, 2 and 3 of

ST00466NY for B727-100 series aircraft, with LEG/pats Auxiliary Fuel System (AFS) in

VIP passenger cabin (LOPA) deck plans.

Boeing SNs 19254 & 20327:

1. These SNs contain a VIP stateroom and are configured for HOS service.

2. These SNs operate exclusively in private or Head of State (HOS) service.

3. These SNs are listed on foreign Registries.

4. These SNs will require extensive engineering changes for a deck plan (LOPA)

to be suitable for EASA or 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 P/E.

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 FAAthat is relevant to SN existing condition.

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

impacted given these SNs have limited private use and with over 3D-years of

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

Thank you.

Karl Seuring, Managing Director

The Leading Edge Group, LLC

Kirkland, WA 98033

Corporate Ofli"ce 3425 emf/on Point Kirk/,me/, Wasbington 98033 M.'j/i} (425) 576-4030