Jamco America Inc.

1018 80 th Street 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 80 u ' Street SW Everett, WA 98203 Tel: 425-347-4735, Ext. 1192 Fax: 425-791-3199 Email: david

— cro4@jameo-ainerica.com

JODA-15-012