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April 20, 2015 

Letter: TLS-15-003 

U.S. Department of Transportation 

Docket Management Facility 

1200 New Jersey Ave., S.E. 

West Building Ground Floor 

Room W12-140 

Washington DC, 20590 

Subject: TLS-15-003 - Petition for Exemption from 25.785(j), 25.857(e), and 

25.1447(c)(1) for Atlas Air B747-400F (Production Freighter) Modification. 

NOTE: This Letter supersedes Letter TLS-15-003 dated 07April2015. Please destroy all 

 copies of Letter TLS-15-003 dated 07April2015. 

1. Introduction: 

Atlas hereby petitions the FAA to permit a maximum of 3 supernumeraries access to the 

Class E cargo compartment during flight on an all Atlas 747-400F airplanes, and once trained 

and during specific flight operations as listed below, be permitted access to the Class E cargo 

compartment in flight under limitations discussed below. The purpose of this letter is to 

submit a petition for exemption from the following 14 CFR part 25 Airworthiness Standards: 

 25.857(e), cargo compartment classification, requires, in pertinent part, that when a class 

‘E’ Cargo Compartment is installed on an airplane, the airplane is used for carriage of 

cargo only. 

 25.1447(c)(1), equipment standards for oxygen dispensing units, requires, in pertinent 

part, that oxygen dispensing unit must be automatically presented to occupants before 

cabin pressure altitude exceeds 15,000 feet. 

 25.785(j), seats, berths, safety belts, and harnesses, requires, in pertinent part, handholds 

to enable passengers to steady themselves while using the aisles in the event of moderate 

turbulence. 

Related sections of the regulations: 

 For the purpose of this petition, supernumeraries, who may have limited access to the 

Class E cargo compartment, are defined per 14 CFR 121.583(a)(1) through (7). 

1.1 Good Cause Exists for Waiving the Federal Register Publication Requirement and the 

 Advance-Filing Deadline. 

Pursuant to 14 C.F.R. §11.87, the publication and comment procedures of Part 11 may be 

waived if “good cause” is shown in the exemption petition that action on the petition 

should not be delayed by the publication and comment procedures. In determining 

whether or not such “good cause” is shown, the FAA may consider, among other factors, 
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whether delay in acting on the petition would adversely affect the petitioner and whether 

the grant of exemption would set a precedent. 14 C.F.R. §11.87(a),(c). No new precedent 

would be set in granting the requested exemption since this request closely mirrors the 

exemptions 8590B and 8587B. In addition, although stated as a general guideline for the 

filing of petitions for exemption (14 C.F.R. §11.63(d)), a waiver of the requirement that 

petitions be submitted 120 days before the proposed effective date of the exemption is 

likewise warranted in this case. 

Atlas respectfully submits that delay in processing this Petition would adversely affect 

Atlas and the shipping public, and that waiver of the Federal Register publication 

requirement and the advance-filing deadline will not set a precedent. This delay would 

be harmful as described in Section 5.0 of this petition for exemption. Clearly, the Federal 

Register publication requirement will cause this timeline to be substantially and 

unnecessarily delayed, to the detriment of the petitioner and of the shipping public, and 

will result in delaying the benefits that will accrue by allowing Atlas to carry 

supernumeraries with access to the cargo compartment. In addition, there is precedent to 

support Atlas’s Petition. Therefore, consistent with the provisions of §11.87, Atlas Air 

respectfully requests that the FAA waive publication of a summary of this request in the 

Federal Register and the 120-day advance-filing deadline. 

1.2 This petition is based on Exemption 8590B and 8587B and is in large part identical to 

relevant information quoted from the petitioner's request in Exemption 8590B and 

8587B. 

1.3 Atlas Air intends to operate B747-400F production freighter aircraft to transport types of 

cargo that require care, or inspection, or both, during flight (e.g., live animals), in 

addition to continuing the original mission of carrying cargo freight. To support this 

usage of the aircraft, Atlas Air proposes to permit a maximum of 3 supernumeraries 

access to the Class E cargo compartment during flight on an all 747-400F airplanes, and 

once trained and during specific flight operations as listed below, be permitted access to 

the Class E cargo compartment in flight under limitations proposed below. Atlas Air will 

implement procedures developed for both the 747-400BCF (Exemption 8590B) and 747-

8F (Exemption 9793C) that determine how each supernumerary is physically able and 

trained to accomplish the necessary emergency procedures. The designation and purpose 

of supernumeraries is discussed in 14 CFR 121.583(a)(1) through (7). These purposes 

and the necessary configuration of the aircraft are not in accordance with 14 CFR Part 25 

regulations; therefore, this petition is submitted to request specific exemptions. 

1.4 Summary of proposed access into the main deck Class E cargo compartment in flight 

for three types of aircraft operations are as follows: 

A. Operations for carriage of live animals, and associated material to support the safe 

transport of the animals, in the main deck cargo compartment requiring 

care/attention during flight; no other cargo on the main deck. 

For these operations the maximum number of supernumeraries permitted access to 

the Class E cargo compartment is 3 during flight. 

B. Operations for carriage of cargo only as originally specified in the TCDS; no live 

animal(s) or other cargo requiring care/attention during flight. 
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For these operations the maximum number of supernumeraries permitted access to 

the Class E cargo compartment is 3 during flight. 

C. Operations for carriage of cargo on the main deck cargo compartment requiring 

care/attention during flight, and other cargo. 

For these operations the maximum number of supernumeraries permitted access to 

the Class E cargo compartment is 3 during flight. 

2. Description of 747-400F Production Freighter Configuration 

2.1 Flightdeck: 

The original flightdeck is certified for maximum occupancy of 2 crewmembers and 2 

observers. Flightdeck layout remains in current delivered configuration. . 

The Boeing Model 747-400F flightdeck is originally fitted and certified with an overhead 

emergency exit hatch for the flightcrew, using inertia descent devices. Flightdeck 

emergency exit is retained unchanged from the original TC configuration. 

2.2 Upper Deck supernumeraries compartment: 

The Boeing Model 747-400F upper deck is originally fitted and certified with one right 

side upper deck crew service door, equipped with one escape slide. This upper deck 

emergency exit is retained unchanged from the original TC configuration. 

The original upper deck of the Boeing Model 747-400F is certified for occupancy of 8. 

The aircraft will retain seating for 4 non-crew (supernumerary) persons only. Total seating 

in the aircraft (including flight compartment) shall be 8 persons. 

 2.3 Main deck cargo compartment: 

The Class E compartment is separated from the upper deck compartment by a smoke 

barrier and ladder enclosure. Access to the Class E cargo compartment is gained through 

a door leading to the folding ladder. The following limitations/instructions shall be 

printed on a placard and placed on the supernumerary seating area side of the access door 

into the compartment. The placard wording is proposed to be the following: 
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Figure 1 – In-Flight Access Limitation Placard 

2.4 Emergency Equipment: 

a. Six (6) Portable ‘walk around’ Oxygen Bottles with a full-face mask will be installed 

on the upper deck as shown per Figure 2. 

1). Three (3) Portable Oxygen Bottles with full facemask will be located on the 

 back side of the cockpit wall just above the frigid area survival kit. 

2). One (1) Portable Oxygen Bottle with full facemask will be located inside the 

 right side closet (in front of the supernumerary seats). 

3). Two (2) Portable Oxygen Bottles with full facemask will be located inside the 

 left side closet (in front of the galley). 

b. Three PBE [portable breathing equipment] units are installed in addition to the 

existing equipment in the flightdeck, one in the flightdeck, two on the upper deck 

and one in the main deck cargo compartment. The equipment shall meet the 

requirements defined in section 25.1439. 

c. One halon fire extinguisher and one water fire extinguisher are installed on the Class 

E cargo compartment, meeting the requirements of section 25.851. 

2.5 Visual Alerting System - Main Deck Signaling System (MDSS): 

One alert means will be provided in order for the flightcrew to communicate to person or 

persons located in the Class E cargo compartment that conditions exist requiring 

immediate return of the person to their seats. The alert shall be provided as follows: 
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Return to seat 

A visual alert signal, flashing of all main deck cargo compartment ceiling lights for 30 

seconds at 0.5 second cycles, concurrent with activation of the SEATBELTS Selector 

switch where ‘FASTEN SEAT BELTS’ and ‘RETURN TO SEAT’ signs will illuminate 

indicating to a person in the main deck cargo compartment to immediately return to their 

seat on the upper deck. The flightcrew will manually activate the signal in case of 

imminent turbulence, cargo compartment smoke/fire warning or decompression. 

Don Oxygen Mask 

The procedures below will be incorporated into the FCOM [Flight Crew Operating 

Manual] and QRH [Quick Reference Handbook] and be included as part of the pre-flight 

briefing: 

1. Any 747-400F equipped with the Main Deck Signaling System (MDSS) will require 

any supernumerary that accesses the Class E cargo compartment to carry an oxygen 

bottle and don a full face oxygen mask and initiate the flow of oxygen at all times 

while in the Class E cargo compartment. 

2. The requirement for the supernumeraries to carry an oxygen bottle and don oxygen 

masks and initiate the flow of oxygen at all times while in the Class E cargo 

compartment, meet or exceeds the Exemption because no aural or visual cue is 

required to don the oxygen mask and initiate the flow of oxygen. 

3. The QRH will include a step to activate the MAIN DECK ALERT which will alert 

the supernumeraries to return to their seat. 

4. The following limitations/instructions shall be printed on a placard and placed on the 

supernumerary seating area side of the access door into the compartment. Reference 

Figure 1. 

3.0 Modification: 

3.1 Interim Modification: 

Atlas Air, Inc. intends to modify its B747-400F aircraft to allow up to 3 supernumeraries 

access to the Class E cargo compartment per sections 3.1.1 and 3.1.2 below. This is an 

interim modification as we will install a permanent modification as per Boeing Master 

Change Service Bulletin as described below in section 3.2. This Master Change and the 

Master Change Service Bulletin Kit will be FAA approved and manufactured 

respectively in approximately 12-18 months. 

3.1.1 Boeing SB 747-33-2290 as per Atlas Air Engineering Order (EO) 4433A042 - 

Main Deck Signaling System (MDSS) Installation: 

a. Boeing SB 747-33-2290 gives instructions for the installation of a Main 

Deck Signaling System (MDSS). This change allows the flight crew to signal 

to the personnel on the main cargo deck to return to their seats. 

b. The new system has a control unit installed on the P5 Overhead Panel in the 

flight compartment. When the switch is operated on the control unit the 

ceiling lights on the main cargo deck flash on and off for thirty seconds at 0.5 

second cycles. This signal tells the personnel on the main cargo deck to 

return to their seats. 

c. Note: SB 747-33-2290 gives instructions to install a relay that allows the 

ceiling lights on the main cargo deck to flash on and off for ten seconds. 
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Atlas Air has installed a relay that allows the ceiling lights on the main cargo 

deck to flash on and off for thirty seconds. 

d. The Atlas Air FCOM and QRH shall include the requirement for flightcrew 

pre-flight briefing of the supernumeraries, including procedures of egress to 

the Class E compartment, and of emergency procedures including the visual 

alert signals. The FCOM shall include the flightcrew procedures related to 

the operation of Class E visual alert signals. 

3.1.2 Atlas Air Engineering Order (EO) 4435A034, Rev. 1 - Portable Oxygen Bottle 

With Full Facemask - Provisional Installation & Activation (See Figure 2): 

1) Part 1 – Installation: 

a. Installs the insert for the O2 bottle mounting brackets. 

2) Part 2 - Activation (after exemption granted): 

a. Installs the mounting brackets, the O2 bottles and facemasks along 

with the applicable identification and instructional placards. 

a. This EO installs 6 portable O2 bottles with full facemask on the upper deck 

of the aircraft for use when accessing the main deck (MD) cargo area during 

flight. 

b. The availability of oxygen bottles with full facemask and a flow indicator 

meet the requirements for CFR 25.1443 and CFR 25.1449 for MD access for 

supernumeraries. 

c. Portable O2 bottle p/n 5600-2D1A-X0K will meet the 30 minute flow time 

requirement at 25k-37k feet, has an O2 qty. gauge and a full face mask, and 

has a flow fitting which confirms O2 is flowing. 

d. The 6 portable O2 bottles with full facemask will be located as follows as per 

Figure 2 below: 

1) Three Portable Oxygen Bottles with full facemask will be located on the 

back side of the cockpit wall just above the frigid area survival kit. 

2) One Portable Oxygen Bottle with full facemask will be located inside the 

right side closet (in front of the supernumerary seats). 

3) Two Portable Oxygen Bottles with full facemask will be located inside 

the left side closet (in front of the galley). 

Figure 2 – Upper Deck Portable O2 Bottle Locations. 

e. The Atlas Air Daily Check and Transit Check taskcards will be revised to 

check (6 ea.) portable O2 bottles oxygen level. If the oxygen level is not in 
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the green band maintenance will be contacted for an MEL to defer and 

replace the bottle at next available opportunity. 

3.1.3 The following pre-flight procedures are to be followed: 

a. Brief supernumeraries on the location of all emergency equipment including 

the portable bottles shown in Figure 2. 

b. Brief supernumeraries on the use of all emergency equipment including the 

portable bottles shown in Figure 2. 

3.1.4 The following procedures are to be followed after each flight operation meeting 

the requirements in section 1.3: 

a. Ensure that serviceable bottles are added before any flights where MD access 

is required. 

b. Replace any used bottles after each flight where MD access was required. 

c. Inspect and verify portable bottles indicate full capacity (within green band) 

indicating a full bottle. If less than full, bottle is considered unserviceable 

and must be replaced or deferred and restriction applied. 

1) Restriction is no MD Access permitted on aircraft where portable bottles 

indicate less than full capacity. 

2) In the event that the unserviceable/used portable device cannot be 

replaced prior to next flight after use, contact MCC to defer and main 

deck access will be restricted during flight until units are replaced. 

3.1.5 The following manuals and pre-flight revisions will be made: 

a. FOM – Outlines requirements to access the main deck and activation of the 

main deck signaling system. 

b. Briefing cards – Will provide guidance for main deck access. 

c. QRH - The 747-400 QRH will be revised to match the 747-8 main deck 

alerting system requirements where applicable. This will also include steps 

for activating the alerting system anytime SUPRNMRY OXY or Passenger 

signs are turned on. 

d. FCOM volume 1 – Addition of preflight of the main deck alerting system. 

e. FCOM volume 2 – Addition of a main deck alerting description. 

f. DDG 33-35-01 - Revise to include main deck alerting system, indicating 

entry is prohibited in-flight with an inoperative main deck alerting system 

and/or where portable bottle(s) indicate less than full capacity. 

3.2 Permanent Modification: 

Atlas Air, Inc. intends to modify its B747-400F aircraft to allow up to 3 supernumeraries 

access to the Class E cargo compartment per Boeing Master Change Service Bulletin as 

described herein. This Master Change and the Master Change Service Bulletin Kit will be 

FAA approved and manufactured respectively in approximately 12-18 months. 

3.2.1 The 747-400F will incorporate system changes to provide: 

a. Automatic aural and visual alerting in the M/D compartment for cabin lossof-pressure and main deck smoke/fire events. 
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b. Visual only alerting for turbulence events. 

c. Portable oxygen bottle with integral full-face mask will be required for each 

person that can be on the MD at the same time. 

d. Procedures will require that each supernumerary take a portable oxygen unit 

with them when accessing the main deck cargo compartment. 

4.0 Exemption(s) Requested: 

4.1 An exemption is requested from CFR 25.857(e) to permit a maximum of 3 

supernumeraries access to the Class E cargo compartment during cruise on an all 747-

400F airplanes. 

4.2 An exemption is requested from CFR 25.1477(c)(1) to permit persons entering the Class 

E compartment the use of a portable oxygen bottle with full face mask and initiate the 

flow of oxygen at all times instead of a self-presenting mask. 

4.3 An exemption is requested from CFR 25.785(j) to obtain relief from the requirement for 

handholds for persons walking in the Class E cargo compartment. 

5.0 Supporting Arguments 

5.1 Presence of Supernumeraries Enhances Safety: 

In order to optimize the usage of the Boeing Model 747-400F as a cargo airplane, 

operators need to be able to accompany their cargo by persons whose function is to take 

care of sensitive cargo and of loading and unloading tasks at any port of arrival. Their 

presence in the aircraft ensures they will be immediately available on arrival to handle the 

cargo. This is most important in case of transport of live animals, perishable goods, items 

of value, etc. 

5.2 Some of the cargo items being transported may include live animals, hazardous 

materials, or valuable or perishable goods that cannot be left unattended, even for the 

duration of the flight, and the presence of personnel trained and qualified in their 

handling is necessary on the aircraft on which they are carried. In-flight inspection of the 

cargo, especially live animals and hazardous materials, enhances safety. 

 5.3 Mixed Cargo Flights are the Norm in the Industry: 

Atlas Air has accepted live animals for carriage on scheduled flights and we routinely 

carry large live animals requiring care/attention during flight in combination with 

other cargo. Depending on the season, the frequency of carrying mixed cargo varies 

from “every flight” to “once every fourteen days.” Clearly, Atlas Air carries mixed 

cargo on a regular basis and such capability/flexibility is needed by the shippers of 

large, live animals. 

 5.4 Not allowing Access for Mixed Cargo on the 747-400F will Create a Hardship: 

Atlas Air has accepted live animals for carriage on scheduled flights. If mixed cargo 

access were not allowed, it would create financial hardship for our operations. It 

would effectively stop large, live animal shipment by air on scheduled flights. The 

cost of shipping horses by air would skyrocket if mixed cargo were not allowed 

because the horse shipper would, in effect, have to pay for the empty pallet positions 

not filled because mixed cargo access would not be allowed. 
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Not allowing access for mixed cargo operations would necessarily drive Atlas Air to 

ship horses (and other large live animals) exclusively on dedicated/chartered flights. 

Such flights would have to be scheduled far in advance and they would likely be 

infrequent due to limited traffic, creating cost and schedule hardship to horse shippers 

due to the relative infrequent flights. Race horses are typically shipped by air and are 

shipped a day or two prior to their races because horses are prone to jet lag and their 

performance suffers as a result. Infrequent dedicated/chartered flights for horse 

carriage would be a hardship to the horse racing industry. 

Not allowing mixed cargo access will very likely create an additional and 

extreme hardship to Atlas Air and the US cargo fleet, one that places us at a 

competitive disadvantage to our foreign counterparts. Airlines not under US 

jurisdiction will most likely pursue certifying mixed cargo access through their own 

regulatory authorities. If they succeed, and most probably will, Atlas Air and other 

US carriers will be at a severe disadvantage. The foreign carriers will be able to 

economically ship smaller quantities of horses on a particular flight while Atlas Air 

and other US carriers will not be able to do likewise. They will have no choice but to 

ship much larger quantities of horses much less frequently in order to fill their main 

deck cargo compartments. 

With minor exception, all large live animals being shipped by air need persons 

(grooms/handlers) on board for their care/attention during flight and to also ensure 

that the animals will not compromise safe flight. 

Large animals may need special attention in flight for their safety and well-being. 

Handlers need to have the ability in flight to calm horses down so they will not try to 

jump and hurt themselves. Whales or other large marine animals need handlers 

capable of keeping them in a wet environment while in flight. Large animals in these 

categories represent a high value. From the shippers' side as well as from the airlines' 

perspective, having grooms/handlers on board and being able to attend to them during 

flight is a must. It is also imperative that a sufficient quantity of grooms be allowed 

inside the compartment at the same time. During flight these grooms assist in 

maintaining a safe environment and help to adequately protect the animal owners' 

investments. 

The quantities of large animals (horses) typically being carried in mixed cargo 

operations varies from one or two stalls holding two to six horses all the way up to 

the main deck being almost completely full with these stalls. If the number of horse 

stalls does not completely fill the main deck compartment, other cargo is routinely 

loaded into the available pallet positions as long as the combination of large animals 

and other cargo is in accordance with IATA [International Air Transport Association] 

guidelines. Atlas Air follows IATA guidelines for live animal carriage, meaning that 

they separate the live animals from certain dangerous goods that may be harmful to 

the large animals (horses) if they were placed too close. 

In order to safely transport large live animals by air, Atlas Air (in combination with 

the shippers) need the flexibility to determine for themselves the proper number of 

grooms/handlers to accompany the large animals without being unduly restricted by 

an AFM limitation that limits main deck access to a few individuals. Although a main 
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deck compartment may not be fully loaded with large animals on a particular flight, it 

may be the decision of the carrier (in combination with the shipper) that the number 

of grooms that should accompany the large animals (horses) is the same as the 

maximum number of supernumeraries allowed to be carried on that model. However, 

Atlas Air requests a maximum of 3 supernumeraries access to the Class E cargo 

compartment during flight on an all 747-400F airplanes. 

5.5 Atlas Air wishes to routinely transport types of cargo that require care and/or 

inspection during flight (e.g., large live animals and/or hazardous materials). The 

effect of the current AFM limitations prohibiting supernumerary access into the main 

deck cargo compartment during flight limits the type of cargo that can be carried, 

creating hardship. If access is not allowed for mixed cargo operations, shipping rates 

would necessarily be higher due to the inefficiency of partially loaded cargo 

compartments. 

 5.6 Evaluation of Public Interest: 

As stated above, cargo operators routinely carry all types of cargo including mixed 

cargo and approving main deck access for such operations of a 747-400F will 

improve cargo carrying efficiency. Additionally, common operating requirements and 

common FAA Exemption allowances for manufacturers will tend to reduce the 

Airlines operating and asset costs through market competition. This will tend to 

reduce overall airfreight rates, as competitive pricing structures among freight 

operators will be promoted; the public interest is served by lower freight rates and 

competitive pricing. 

5.7 Non-crewmember passengers carried on Boeing Model 747-400F airplanes are limited to 

categories listed on section 121.583(a)(1) thru (7). The non-crewmembers, commonly 

referred to as supernumeraries, shall be physically capable of performing their emergency 

and normal cargo handling duties, and trained in the use of emergency equipment. 

5.8 Atlas Air proposes the following safety features and limitations for the entry of 

supernumerary persons into the Class E compartment during flight: 

When supernumeraries are seated in their seats or while in the lavatory on the upper deck, 

self-presenting oxygen masks indicate the need to don an oxygen mask. Since selfpresenting oxygen masks are not available to persons entering the Class E compartment, 

an equivalent level of safety is provided by new procedures added to the Atlas Air FCOM 

and QRH and included as part of the pre-flight briefing: 

1. Smoking shall be prohibited inside the Class E compartment. 

2. The door to the Class E compartment must be closed at all times except for entry 

and exit. The compartment must not be entered in case of smoke/fire being 

detected inside the Class E compartment. 

3. 747-400F equipped with the Main Deck Signaling System (MDSS) will require 

any supernumerary that accesses the Class E to carry an oxygen bottle and don a 

full face oxygen mask and initiate the flow of oxygen at all times. 

4. The requirement for the supernumerary to carry an oxygen bottle and don oxygen 

masks and initiate the flow of oxygen at all times while on the Class E, meet or 
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exceeds the Exemption 8590 & 8587 because no aural or visual cue is required to 

don the oxygen mask and initiate the flow of oxygen. 

5. The QRH will include a step to activate the MAIN DECK ALERT which will 

alert the supernumeraries to return to their seat. 

6. The visual alert system [Main Deck Signaling System (MDSS)] indicates to 

compartment occupants via flashing main deck ceiling lights the need to 

immediately return to their seats. 

7. The visual alert system will be provided inside the Class E compartment. The 

alerts will be visible to persons throughout the length of the compartment. 

8. In the event of air turbulence, loss of cabin pressure or smoke being detected 

inside the Class E compartment, the main deck alerting system will be manually 

activated by a flight deck crewmember. The procedure to be followed for this 

scenario will be the person(s) inside the compartment will immediately return to 

their seat. Such instruction will also be included in the required pre-flight 

briefing to the supernumeraries. 

9. The following limitations/instructions shall be printed on a placard and placed on 

the supernumerary seating area side of the access door into the compartment. 

Reference Figure 1. 

5.9 Handhold provisions in the upper deck per the requirements of CFR 25.785(j) are 

exempted per Exemption 1870E. Since installation of handholds in the main deck cargo 

compartment is impractical, an acceptable level of safety is provided by the crew 

operated alert system [Main Deck Signaling System (MDSS)] ability to indicate, at the 

onset of turbulence, smoke/fire and or decompression to persons in the cargo 

compartment, to immediately return to their seats. 

 5.10 The Atlas Air FCOM shall include the requirement for flightcrew pre-flight briefing of 

the supernumeraries, including procedures of egress to the Class E compartment, and of 

emergency procedures including the visual alert signal. The Atlas Air FCOM shall 

include the flightcrew procedures related to the operation of Class E Main Deck 

Signaling System (MDSS). 

 5.11 The FAA states that the original 747-400F type design includes the installation of a 

placard on the access door to the main deck that reads as follows: “Door to remain 

closed during taxi, takeoff, flight and landing.” Exemption 8590A states that the 

placard ... “has the same effect as an AFM limitation prohibiting access to the main 

deck cargo compartment during flight.” 

 5.12 Atlas Air requests that if this exemption request is granted, that this AFM limitation be 

 removed from the AFM.

6.0 Conclusion 

6.1 The granting of the requested exemptions will not degrade the level of safety provided by 

the regulations. The granting of the requested exemptions will be in the public interest for 

the following reasons: 

6.1.1 The supernumeraries will be trained in the use of emergency equipment and 

will receive a pre-flight briefing from the flightcrew. 
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6.1.2 The FCOM shall instruct the flight crew to brief the supernumeraries before 

each flight about the limitations and procedures in case of entry into the 

Class E compartment during flight. 

6.1.3 An equivalent level of safety for the self-presenting oxygen mask 

requirement will be provided by the requirement that any supernumerary 

accessing the Class E to carry an oxygen bottle and don a full face oxygen 

mask and initiate the flow of oxygen at all times. 

 The visual alert system [Main Deck Signaling System (MDSS)] via 

flashing main deck ceiling lights, which will indicate the onset of 

turbulence, smoke/fire and or decompression to main deck compartment 

occupants the need to immediately return to their seats. 

 Activation of the SEATBELTS Selector switch where ‘FASTEN SEAT 

BELTS’ and ‘RETURN TO SEAT’ signs will illuminate indicating to a 

person in the main deck cargo compartment to immediately return to 

their seat on the upper deck. 

 The following limitations/instructions shall be printed on a placard and 

placed on the supernumerary seating area side of the access door into the 

compartment. Reference Figure 1. 

6.1.4 Since installation of handholds in the main deck cargo compartment is 

impractical, an acceptable level of safety will be provided by the crewoperated visual alert system's [Main Deck Signaling System (MDSS)] via 

flashing main deck ceiling lights, ability to indicate at the onset of 

turbulence, smoke/fire and or decompression to persons in the cargo 

compartment, to return to their seats. 

In consideration of the above and the level of safety that would be provided to all airplane 

occupants on 747-400F airplanes if approved for main deck access during flight, Atlas Air, Inc. 

requests that the FAA consider the subject request for exemption for the 747-400F and revise the 

limitation to allow supernumerary personnel access into the Class E compartment during flight in 

order to fulfill their duties to inspect and/or care for cargo, thereby avoiding any further limitation 

of the aircraft use. 

Appendix - References: 

 Type Certificate Data Sheet A20WE. Boeing 747 

 FAA Exemption 8590B, dated December 1, 2008, pertaining to Boeing 747-400BCF 

Series aircraft: partial exemption from 14 CFR 25.785(j), 25.807(c), 25.857(e), and 

25.1447(c)(1), Allowance of additional supernumeraries in the upper deck and access to 

the main cargo deck during certain phases of flight. 

 FAA Exemption 9793C, dated June 16, 2011, pertaining to Boeing 747-8F Series 

aircraft: partial exemption from 14 CFR 25. 812(g)(1)(ii) and modification of 

Limitation 12, Allowance of additional supernumeraries in the upper deck and access to 

the main cargo deck during certain phases of flight. 
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 FAA Exemption 10703, dated February 13, 2013, pertaining to Boeing 747-400F Series 

aircraft: partial exemption from 14 CFR 25.785(j), 25.807(c)(1), 25.807(c)(5), 

25.809(f)(1). 25.813(b), 25.857(e), and 25.1447(c)(1), Allowance of additional 

supernumeraries in the upper deck and access to the main cargo deck during certain 

phases of flight. 

 FAA Exemption 1870E, dated September 8, 1993, pertaining to Boeing 747-400F Series 

aircraft: exemption from 14 CFR 25.807(c)(1), 25.807(c)(5), 25.809(f)(1), 25.813(b), 

Allowance of non-crew members on the upper deck of 747-200F, 747-200C, certain 747-

100 when in the main deck cargo configuration, and 747-400F Series aircraft. 

 FAA Exemption 6463, dated June 19, 1996, pertaining to Boeing 747-100/200 Series 

cargo aircraft: exemption from 25.857(e) and 25.1447(c)(1), Allowance of 16 

supernumeraries on the main deck of Boeing Model 747-100/-200 cargo aircraft to attend 

to live animal cargo. 

 FAA Exemption 7900, dated October 1,2002, pertaining to B747-100/200 cargo aircraft: 

exemption from 14 CFR 25.855(a), 25.807(d)(1), 25.857(e), and 25.1447(c), Allowance 

of up to 28 supernumeraries on the main deck of Boeing 747-100, -200 Series airplanes 

to attend to live animal cargo. 

 FAA Exemption 8587B, pertaining to Boeing 747·400 Series "combi" aircraft. 

 FAA Exemption 8536A, pertaining to Boeing 747-100, 747-100B, 747-100B SUD, 747-

200B, 747-200C, 747-200F, 747-400, 747-400F Series aircraft. 

 FAA Special Conditions 25·430·SC: Boeing Model 747-8 Airplanes; Stairway Between 

the Main Deck and Upper Deck. 

 NM·09·27, Special Airworthiness Information Bulletin: In·flight access to Class E cargo 

compartments, May 12, 2009. 

 Atlas Air Engineering Order (EO) 4433A042. 

 Atlas Air Engineering Order (EO) 4435A034. 

 Atlas Air 747-400F Flight Crew Operations Manual 

 Atlas Air 747-400F Supernumerary/Jumpseat Briefing Card 

Regards, 

Todd Berkey 

Sr. Director Engineering & Maintenance Programs 

Atlas Air 

2000 Westchester Ave./2nd Flr. 

Purchase, NY 10577-2543 

cc: M. Swearingin – VP Technical Operations, Atlas Air 

 R. Rolland – VP Safety and Regulatory Compliance, Atlas Air 

M. Citrano – Sr. Dir. Maintenance, Atlas Air 

 K. Shadursky – Sr. Dir. Quality Assurance, Atlas Air 

 S. Shataka – NY-FSDO, PMI 

Z. Smoczkiewicz, NY-FSDO, PAI 

A. Taylor, NY-FSDO, POI