TLS-15-003



### Page 1 of 13 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 Exempti on 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-15-0 03 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 a ll Atlas 747-400F airplanes, and once trained and during specific flight opera tions as listed below, be permitted access to the Class E cargo compartment in flight under limitations discu ssed below. The purpose of this letter is to submit a petition for exemption from the followi ng 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 airp lane, 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, supernumer aries, 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 Federa l 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 ex emption petition that action on the petition should not be delayed by the publication an d comment procedures. In determining whether or not such “good cause” is shown, the FAA may consider, among other factors,TLS-15-003

Page 2 of 13 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 exemp tion 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 prop osed effective date of the exemption is

likewise warranted in this case.

Atlas respectfully submits that delay in pr ocessing this Petition would adversely affect Atlas and the shipping public, and that wa iver 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 th is 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 compartm ent. 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 publica tion 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 a nd 8587B and is in large part identical to relevant information quoted from the petiti oner's request in Exemption 8590B and

8587B.

1.3 Atlas Air intends to operate B747-400F produc tion 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 operati ons 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 emergenc y procedures. The designation and purpose of supernumeraries is discussed in 14 CF R 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 a 

### ccess 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.TLS-15-003



### Page 3 of 13 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 orig inally 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 orig inally 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 fr om 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-cr ew (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 th e 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 wordi ng is proposed to be the following:TLS-15-003

Page 4 of 13 

### 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 fu ll facemask will be located inside the right side closet (in front of the supernumerary seats). 3). Two (2) Portable Oxygen Bottles with fu ll 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 compar tment that conditions exist requiring immediate return of the person to their se ats. The alert shall be provided as follows:TLS-15-003



### Page 5 of 13 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 w ith activation of the SEATBELTS Selector

switch where ‘FASTEN SEAT BELTS’ and ‘R ETURN 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] a nd 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 in itiate 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 Exemp tion because no aural or visual cue is required to don the oxygen mask a nd 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 secti ons 3.1.1 and 3.1.2 below. This is an interim modification as we will install a pe rmanent 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 cha nge allows the flight crew to signal to the personnel on the main cargo d eck to return to their seats.

b. The new system has a control unit insta lled 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.TLS-15-003

Page 6 of 13 Atlas Air has installed a relay that a llows 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 25.14 43 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 facem ask will be located as follows as per Figure 2 below: 1) Three Portable Oxygen Bottles with fu ll 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 f acemask will be located inside the right side closet (in front of the supernumerary seats). 3) Two Portable Oxygen Bottles with fu ll 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 inTLS-15-003



### Page 7 of 13 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 adde d before any flights where MD access is required.

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

c. Inspect and verify portable bottles indi cate full capacity (within green band) indicating a full bottle. If less than fu ll, bottle is considered unserviceable and must be replaced or defe rred and restriction applied. 1) Restriction is no MD Access permitte d 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 durin g 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 gui dance 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 th e Master Change Service Bulletin Kit will be FAA approved and manufactured respectiv ely 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.TLS-15-003

Page 8 of 13 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 supe rnumerary take a portable oxygen unit with them when accessing the ma in 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 25.14 77(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 thei r 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 trans port 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 th ey 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/fle xibility 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.TLS-15-003



### Page 9 of 13 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 b ecause 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 cer tifying 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 disadvanta ge. 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 mainTLS-15-003

Page 10 of 13 

### 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 phys ically capable of performing their emergency and normal cargo handling duties, and traine d 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 n eed 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 acces ses 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 orTLS-15-003



### Page 11 of 13 exceeds the Exemption 8590 & 8587 because no aural or visual cue is required to don the oxygen mask and initia te 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 provide d inside the Class E compartment. The alerts will be visible to persons throug hout 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 installa tion 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 ex emptions 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.TLS-15-003

Page 12 of 13 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 immediat ely 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 comp artment 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 isimpractical, 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 ma in deck access during flight, Atlas Air, Inc. requests that the FAA consider the subject requ est 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 car e 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 supe rnumeraries 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 supernumerar ies in the upper deck and access to the main cargo deck during certain phases of flight.TLS-15-003



### Page 13 of 13  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 acces s 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 Mo del 747-8 Airplanes; Stairway Between the Main Deck and Upper Deck.
 NM·09·27, Special Airworthiness Informati on 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