September 7, 2012

(Revision B)

Structural Integrity Engineering 

9525 Vassar Ave., 

Chatsworth, CA 91311 

U.S. Department of Transportation

Docket Operations

West Building Ground Floor

Room W12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: FAA Project ST14145LA-T 

Under the subject FAA project, Structural Integrity Engineering (SIE) has been appointed as the acting

agent for the applicant, ORBIS International, to obtain a one time STC to reconfigure an MD-10-30F

Freighter to transport Modular Hospitals loaded on Pallets. The Modular Hospitals will be deployed in

support of ORBIS International's efforts to improve eye care throughout the developing world. In

support of this project, SIE is requesting a partial grant of exemption from the requirements of certain

14 CFR Part 25 regulations for this aircraft. 

As part of the STC application process, SIE has identified, and reviewed with the FAA, the Title 14,

Code of Federal Regulations relevant to this effort. These are contained in the Project Specific

Certification Plan (PSCP), SIE report SIE-400-101 (currently at Rev. C). 

The Flying Eye Hospital (FEH) is a teaching hospital that allows people in the forward cabin, the

"classroom", to follow operations with the help of audio-visual equipment. The existing 9G restraint

location will be placed further aft at approximately FS 758 to allow for the classroom to double as a

supernumerary area. The total number of seats installed in the supernumerary area will be forty eight

(48), which includes two (2) flight attendant station in the forward galley area and the remaining forty

six (46) seats will be passenger type seating in the classroom. These crew members will be in addition

to the two (2) flight crew, one (1) flight engineer seat, and two (2) observers located in the cockpit for a

total of fifty-three (53) occupants on board. The supernumeraries will be ORBIS employees including

volunteer faculty and sub contractors to: 1) Accompany the hospital on each mission to perform setup/take-down duties and ensure safe and secure handling of medical equipment and materials in

9525 Vassar Ave., Chatsworth, CA 91311 ♦ Ph. 818-718-2195 ♦ Fax 818-718-2212 ♦ email: integrity@SIEinc.com 
accordance with FAR 125.331; and 2) Support hospital operations including in-country screening and

training. The supernumerary seats and equipment will be equivalent to a passenger interior except that

egress is provided through just one door on each side (L1 and R1). The doors will be equipped with

standard slides/rafts with a capacity of thirty two (32) or thirty seven (37) overload per side and an

additional life raft for sixteen (16) to meet the requirements of 25.1415(b)(1) Amdmt 82 (latest). The

existing Class E main deck cargo compartment will be retained aft of the new location of the 9G barrier

at approximately FS 758. The main deck cargo compartment is not occupied during flight; however, it

is an “accessible Class E cargo compartment” for the purpose of fire fighting. 

This petition is presented for relief to the requirements of the following sections of the 14 CFR Part 25

regulations for the MD-10-30F aircraft being reconfigured for the teaching hospital mission. 

1 - §25.857 amendment 25-93, Sub paragraph (e) and (e)(3). Sub paragraph (e) defines a class E cargo

compartment as one used only for the carriage of cargo. Sub paragraph (e)(3) requires a means to shut

off the ventilating airflow to, or within the compartment. 

2 - §25.807 amendment 114, Sub paragraph (f)(2), (g)(5) Sub paragraph (f) deals with the location of

the exits. Sub paragraph (f)(2) requires that floor-level exits must be in the rearward part of the

passenger compartment unless another location affords a more effective means of passenger

evacuation. Sub paragraph (g) defines the type and number of doors required and (g)(5) requires two

doors per side for cabins with 41 to 110 seats. 

Supporting Information - Section Requirements 

1 - §25.857 Cargo Compartment classification, amendment 25-93, Sub paragraph (e) and (e)(3)

Paragraph (e) defines a Class E cargo compartment as one on airplanes used only for the

carriage of cargo. As stated earlier in the discussion on page one of this petition, the ORBIS teaching

hospital requires forty six (46) supernumeraries for its operation beyond the two flight attendant

stations, two flight crew, one flight engineer seat and two observers.

The DC-10 certification (see TCDS Page 38) includes Exemption Number 2453 issued

September 26, 1977 an exemption from §25.807(c)(1) to “permit evacuation of passengers with one

oversize Type I emergency exit meeting the conditions specified in Exemption No. 1573 on each side

of the fuselage with a passenger seating capacity of 50.”

The FAA has previously granted Exemption 6652, issued June 26, 1997 to Federal Express.

This Exemption allows for the carriage of up to 24 supernumeraries inside a Class E Cargo

Compartment on DC-10 aircraft. In addition, Exemption 6873 is part of the MD-10 certification basis.

This exemption allows the carriage of an additional four (4) supernumeraries in front of the 9G Barrier.

9525 Vassar Ave., Chatsworth, CA 91311 ♦ Ph. 818-718-2195 ♦ Fax 818-718-2212 ♦ email: integrity@SIEinc.com 
The total supernumeraries allowed on the MD-10 aircraft is, therefore 28. In granting the Exemption

6652, the FAA nonetheless expressed a concern about “a trend toward proposals for rather more

ambitious accommodations.” This refers back to a lack of intent towards “large numbers of

supernumeraries” in 121.583. The current proposal does indeed request a “large” number of

supernumeraries. This large number is acceptable, in this case only, because it is limited to: 1) Part 125

Operations instead of Part 121; and 2) Carriage of Mobile Hospitals. The first condition precludes the

commercial use of the exemption and the second condition includes a very specific purpose. This

purpose while obviously different in nature, is just as specific as the previously allowed horse carriage.

Paragraph 25.857(e)(3) requires the air supply to the Class E compartment to be shut off in case of fire.

This feature remains active on the current aircraft. However, the means of fighting a fire per the

Airplane Flight Manual will be changed from decompression procedures to crew fire fighting. We will

request an equivalent level of safety finding for the specific crew firefighting procedure. The crew

firefighting is preferred for this application, because: 1) The modular hospital cargo is, by its nature

accessible (and will be required to be accessible in the operational manuals); and 2) Flare-up of a fire in

descend when the decompression method is no longer available is eliminated as a risk factor.

Furthermore, the crew will not be exposed to prolonged operation at low atmospheric pressure during a

fire event.

2 - §25.807 Emergency exits, amendment 25-114, Sub paragraph (f)(2), (g)(5)

 This regulation defines the number, location, and type of emergency exits required for various

passenger quantities. The aircraft has a single door per side where two would be required for passenger

operation (g)(5). The doors are located at the front of the supernumerary area where (f)(2) expresses a

strong preference for an aft location for passenger operation. 

The existing L1 and R1 doors, which have an opening of 32”X76”, meet the requirements of a

Type B door. Type B doors are qualified for a maximum number of seventy five (75) passenger seats

per pair (left/right). This number is more than 50% larger than the number of supernumeraries. 

FAA has previously addressed egress issues for combi airplanes with only one pair of exits for

passenger egress in Policy Number PS-ANM100-1987-00033, dated 11/02/1987. This Policy identifies

and approves a maximum capacity of fifty passengers for the oversize Type I (a Type B) door available

on the aircraft. The Exemption 2453, part of the Certification Basis of the aircraft is consistent with

this policy. The number allowed exceeds the requested number of supernumeraries.

Information to Support Grant of Exemption: 

Per the provisions of 14 CFR Part 125.331 (Carriage of persons without compliance with the

passenger-carrying requirements of this part), a minimum of two supernumeraries will have

special training in the use of emergency equipment, emergency egress, and flight operations

associated with controlling a fire in an accessible Class E compartment.

9525 Vassar Ave., Chatsworth, CA 91311 ♦ Ph. 818-718-2195 ♦ Fax 818-718-2212 ♦ email: integrity@SIEinc.com 
The supernumerary seating will be provided using seating, emergency egress provisions and

emergency oxygen systems from a decommissioned DC-10 passenger aircraft as part of the STC

project. The supernumerary compartment will have been outfitted with liners, overhead bins and

galleys prior to STC from the same decommissioned DC-10 aircraft. Therefore, this compartment

will meet the flammability requirements per the DC-10 TCDS.

A placard indicating that the door in the 9g rigid barrier is to be closed at all times during flight, except

to gain access in an emergency fire fighting condition, will be located in a conspicuous place on or next

to the smoke barrier. The safety of the crew members entering the cargo hold for the fire-fighting role

is ensured with protective clothing and a breathing apparatus. These crew members have helmet

mounted lights to supplement the ambient lighting provided in the hold.

The historical deployment schedule of the Flying Eye Hospital calls for three-week deployments. The

extended on-ground time for deployment causes the number of flights and flight hours to be much

lower than a normal passenger or freighter operation. The expected number of flights over 20 years of

operations is about equal to the number of flights per year during the aircraft's use as a FEDEX

freighter.

Evaluation of Public Interest: 

The availability of an Airborne Hospital that can be rapidly deployed to any location in the world is in

the public interest. The specific purpose of this particular Airborne Hospital is to cure blindness

worldwide. This is also in the public interest.

Petition for Exemption: 

SIE requests authorization to carry 48 supernumeraries, in accordance with the provisions of 14 CFR

Part 125.331 Carriage of persons without compliance with the passenger-carrying provisions of this

part. In consideration of the foregoing discussion, SIE petitions for exemption from the following 14

CFR Part 25 regulations for the ORBIS reconfigured MD-10-30F aircraft undergoing reconfiguration

by FAA project ST14145LA-T. 

1 - 25.857 amendment 25-93, Sub paragraph (e) and (e)(3), 

• (e) Forty eight (48) supernumeraries in addition to the two flight deck crew members, flight

engineer and two observers may be carried.

• (e)(3) The air supply will be shut off, but the aircraft will not be decompressed for fire

abatement.

2 - 25.807 Emergency exits, amendment 25-114, Sub paragraph (f)(2) and (g)(5)

• (f)(2) The single emergency exit doors 1L and 1R are located at the forward end of the

supernumerary seating compartment.

• (g)(5) A single door per side (Type B Doors 1L and 1R) will be available for emergency egress

9525 Vassar Ave., Chatsworth, CA 91311 ♦ Ph. 818-718-2195 ♦ Fax 818-718-2212 ♦ email: integrity@SIEinc.com 
for no more than fifty (50) supernumeraries. 

The applicant would like the public comment phase to be eliminated from the Exemption process,

because there is no industry-wide effect from a grant of exemption for this unique purpose. 

Structural Integrity Engineering respectfully requests the FAA consideration of the foregoing petition.

Additionally, we ask that the FAA Los Angeles ACO perform coordination necessary to obtain FAA

concurrence and advisement for this petition.

Yours sincerely, 

Willem Kernkamp 

Structural Integrity Engineering 

9525 Vassar Ave., 

Chatsworth, CA 91311 

Tel: 818-718-2195 #106 

E-mail: wkernkamp@sieinc.com 

9525 Vassar Ave., Chatsworth, CA 91311 ♦ Ph. 818-718-2195 ♦ Fax 818-718-2212 ♦ email: integrity@SIEinc.com