U.S. Department 

of Transportation 

Federal Aviation 

Administration 

FEB 1 9 1015 

Mr. Kumaresan Subramaniam 

Engineering Director 

VT Mobile Aerospace Engineering, Inc. 

2100 Aerospace Drive, Brockley Aeroplex 

Mobile, Alabama 36615 

Dear Mr. Subramaniam: 

Transport Airplane Directorate 

1601 Lind Avenue, S.W. 

Renton, Washington 98057-3356 

Exemption No. 11 060A 

Regulatory Docket No. FAA-2014-0351 

This is to inform you that we have amended Exemption No. 11060. This letter explains the 

basis for our decision and describes its effect. 

The Basis for Our Decision 

By letter dated October 24, 2014, and by letter dated October 30, 2014, you petitioned the 

Federal Aviation Administration (FAA), on behalf ofVT Mobile Aerospace Engineering, 

Inc. (formerly known as ST Aerospace Mobile, Inc.), for an amendment to Exemption 

No. 11060. That exemption provided relief from the requirements of§§ 25. 7850), 

25.807(g)(l), 25.807(i)(l), 25.810(a)(l), 25.813(b)(l), 25.813(b)(6), and 25.1447(c)(1) of 

Title 14, Code of Federal Regulations (14 CFR). In addition to requesting the same relief as 

previously requested for Exemption No. 11060, you sought additional relief from the 

requirements of§ 25.857(e) and requested the removal of the turbulence warning 

(Condition 6) and the public address (PA) system (Condition 11) in the supernumerary area. 

Your petition included the same conditions and reasons relative to public interest and safety 

that were the basis for granting the original exemption. In your letter dated 

October 24, 2014, you include justification for an exemption from§ 25.857(e), which 

prohibits passengers on airplanes with Class E cargo compartments. You also included 

justification for exemption from§ 25.810(a)(1), which was previously granted in Exemption 

No. 11060. In your letter dated October 30, 2014, in support of removal of the turbulence 

warning and the P A system in the supernumerary area, you stated that having a standard 

public address system and aural annunciations that are audible by the supernumeraries in the 

flight deck would disturb and confuse the flight crew, which affects safety of flight. 

Federal Register Publication 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register for public comment because the requested amendment to the 
exemption would not set a precedent, and any delay in acting on this petition would be 

detrimental to your company. 

Our Decision 

Section 25.857(e) restricts Class E cargo compartments to all-cargo airplanes (i.e., 

occupancy limited to flight crew [pilots and flight engineer] only). However, VT Mobile 

Aerospace Engineering, Inc.'s (VT MAE) design meets§ 25.857(e)(l) through (e)(5) 

requirements for the Class E cargo compartment itself. 

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As stated by VT MAE, Class E cargo compartments are usually remote from the flight deck 

and the means of controlling fires is to depressurize the airplane to minimize the available 

oxygen. The recommended altitude for flight while depressurized is between 20,000 and 

25,000 feet. The operator is required to ensure that each supernumerary is physically able to 

accomplish this emergency procedure. In addition, the design includes a barrier, which must 

comply with the smoke penetration requirements for the flight deck. VT MAE's design 

includes placards installed on the barrier to indicate that the barrier is to be secured and that 

no personnel are allowed into the Class E cargo compartment during flight. Also, the FAA 

acknowledges that we have approved similar designs and operations where the presence of 

supernumeraries provides a benefit to airplane safety. 

For this configuration, where the supernumerary seats are located in the enlarged flight deck, 

VT MAE has requested that the FAA remove the requirements for an alerting system and a 

P A system. We find that this proposal is acceptable and have removed the requirements for 

a turbulence alert system and P A system in the supernumerary area, since the supernumerary 

seats are in close proximity to the flight crew. We have revised Condition No. 6 accordingly 

and have removed Condition No. 11 of the original exemption. However, the turbulence 

alert must still be recognized in the lavatory and indicate, during turbulence, those persons 

must return to their seats. 

Therefore, under the authority provided by 49 U.S.C. 40113 and 44701, which the FAA 

Administrator has delegated to me, VT MAE is granted a partial exemption from 

§ 25.857(e), allowing supernumeraries on an airplane with a Class E cargo compartment. 

VT MAE is not granted an exemption from§ 25.857(e)(1) through (e)(5), 

Amendment 25-93. 

The Effect of Our Decision 

This amendment adds§ 25.857(e) to the requirements for which the exemption is granted. 

Note that our decision not to grant an exemption from§ 25.812(e), Amendment 25-128, and 

from § 25 .1445( a)(2), Amendment 25-00, remains unchanged from Exemption No. 11060. 

Condition 6 of Exemption No. 11060 is revised as follows: 

Aflightcrew-operated aural or visual annunciation that would be recognized in the lavatory 

must be installed to indicate, during turbulence, that persons must return to their seats. 

Appropriate procedures/limitations must be established to ensure that the flightcrew signals 

the supernumeraries to return to their seats at the onset of turbulence and for taxi, take-off 

and landing. 
Condition 11 ofExemption No. 11060 is deleted. 

All other conditions and limitations of Exemption No. 11060 remain the same. This letter 

must be attached to, and is a part of, Exemption No. 11060. 

Sincerely, 

John P. Piccola, Jr. 

Acting Manager, Transport Airplane Directorate 

Aircraft Certification Service 

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