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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 

## IDTI) 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 

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### t1JIN TH~DI
Capt. Kar( AirSpeed '" G EjSE GROUP, LLC

g, Managing Director 

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### oflice 3425 C'lnl/onPoint KirklqndW'lshingtoIJ98033 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 publiccomment: The Leading Edge Group, LLC (LEG), as FAASupplemental Type Certificate (STC) holder 

### ofST00466NY 

### requests FARcompliance reliefand submitsthis Petition for Exemption (P/E) to FAArule making established under 14 CFRSect. 26.47(c) & (e)(2). 

### LEGpetitions for USGovt. engineering task reliefon 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 SNscontain aVIP stateroom and are configured 

## for HOSservice. 2. These SNsoperate exclusively in private or Head of State (HOS) service. 3. These SNsare listedon foreign Registries. 4. These SNswill require extensive engineering changes for a deck plan (LOPA) to be suitable for EASAor UScommercial revenue service under FAR 121. 5. Responsiveengineering resourcesofthe FAAcan beconserved and financial reliefcan be realized on behalf ofthe DAH and USGovernment; upon timely approval of this P/E. 

### 6. The Operator nor STCholder are notableto determine if modifications tothe AFSloading points on thisairframe have been altered, AFSbrackets removed or, ifthe AFSattach points have been adapted for other purposes; requiring in themselves new lCAs. 7. Operator disclosureand DAH-onboard AFSsurvey ofthe aircraft isrequired to submit useful engineering to FAAthat isrelevant to SNexisting condition. 8. It isthe position of the STC holder that air safety will not be adversely 

### impacted given these SNshave limited private useand with over 3D-years of airframe age, will likely never return to commercial FAAjEASAair carrier service.
In the event these SNsare transferred to athird party and an interior reconfiguration (LOPA) iscompleted, a current airframe surveyto 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 FAR26.47(c) and (e)(2).

Thank you.


### KarlSeuring, Managing Director The Leading Edge Group, LLC Kirkland, WA 98033 Corporate 

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