Jamco America Inc. 

1018 80thStreet SW tel 425.347.4735 ~~~~0 

Everett, WA 98203, USA fax 425.791.3199 

ALWAYS FLYTOGETHER 

January 20, 2015 

Letter JODA-15-012 

U.S. Department of Transportation 

Docket Management Facility 

1200 New Jersey Ave., S.E. 

West Building Ground Floor 

Room W 12-140 

Washington DC, 20590 

Subject: Petition to Amend Operational Limitations Identifed in Exemption 10899 

The purpose of this letter is to petition to amend the operational limitations identified in Exemption 

10899. Exemption 10899 currently identifies three types of operation and associated limitations as 

follows: 

Type A: Operations for carriage of live animals, and associated material, 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 on the upper deck is 15 and 

the total airplane occupancy is 19. Access to the main deck Class E cargo compartment by 

a maximum of 15 supernumeraries is pennitted during climb, cruise, and approach. 

Type 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. 

For these operations the maximum number of supernumeraries is 6 and the total airplane 

occupancy is 8. No access is allowed into the main deck Class E cargo compartment 

during any airplane operation. 

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

care/attention during flight, and other cargo. 

For these operations the maximmn number of supernumeraries is 6 and the total airplane 

occupancy is 8. Access to the main deck Class E cargo compartment by a maximum of 3 

supernumeraries is pei-initted during climb, cruise, and approach. 

Jainco America proposes that only two types of operation are necessary to provide an acceptable level of 

safety for the flight crew and supernumeraries, as well as to provide consistency with previously issued 

exemptions, including 1870E, which is currently identified on Type Certificate Data Sheet (TCDS) 

A20WE applicable to the Boeing Airplane Mode1747-400F series aircraft. 

The first type of operation is identical to Type A as currently identified in Exemption 10899, including all 

limitations and conditions, except that it be extended to include ferry fligllts for the supernumeraries prior 

to, and after, the carriage of live cargo. All other limitations and conditions identified for Type A 

operation remain unchanged fi°om the current Exemption 10899. 

www.jamco-america.com 
Docket Management Facility 

Page 2 of 2 

January 20, 2015 

Jamc® America Inc. 

This will allow the operator to fly to-and-from locations with the maximum allowed 15 supernumeraries 

for the purpose of picking up, or delivering, live cargo. Without this ability, the operator is unduly 

burdened with flying the freighter aircraft with only 6 maximum supernumeraries and ferrying the 

remaining 9 supernuineraries in a separate additional aircraft. This operational limitation is economically 

and operationally burdensome and not necessaiy, as the aircraft is equally safe for 15 supernumeraries 

witl-i or without live cargo on board, provided all required safety features for Type A operation remain in 

place. 

The second type of operatioii is all other modes of operation for a typical. 747-400F aircraft as currently 

allowed by Exemption 1870E listed in TCDS A20WE. This type of operation would be in effect any time 

the Type A conditions are not met, such as the main deck emergency escape path, required emergency 

equipment, emergency alerting, etc. A maximum 6 supernumeraries can be carried and allowed access to 

the main deck cargo compartment in accordance with the limitations and conditions specifically identified 

in Exemption 1870E. 

Upon acceptance of this proposed amendment to the operational types identified in Exemption 10899, 

Jamco America will revise the following documents for STC ST02114SE to incorporate the changes: 

AFM Supplement, document AFM1494-1 

Supernumerary Training Plan, document TRP-DUB43A1 

If additional infonnation or action is required, please contact the undersigned or Mr. Donald Wren at 

(425)347-4735. 

Sincerely, 

i 

David A. Crotry 

Senior Certification Manager 

Jamco America, Inc. 

1018 80u' Street SW 

Everett, WA 98203 

Tel: 425-347-4735, Ext. 1192 

Fax: 425-791-3199 

Email: david—cro4@jameo-ainerica.com 

JODA-15-012