-PARTMENTOF 

Federal Aviation :' H'OPERATIONS 

Administration B DEC - 1 A 11=03 

Memorandum 

Date: November 30, 2010 

To: U.S. Department of Transportation, Docket Operations, West Building, Ground 

Floor, Rm W12-140, 1200 New Jersey Avenue, SE., Washington, DC 20590. 

From: Ross Elmore, Manager, Technical Support - Air Carrier, ACE-240-^"^^ ^^y^*^/ ^ 

Prepared by: Raymon Taylor, ACE-23ID, 816-329-3229 

Subject: Trans States Airlines, Operations Specification D097 Exemption Request 

This memorandum is submitted to request an exemption from 14 CFR 121.1109. Due to the 

maintenance program document submission, review and approval process. Trans States Airlines 

is requesting a 180 day extension to the requirements of 14 CFR 121.1109. 

Please see attached letter from Trans States Airlines. 

If you have any questions, please contact Raymon Taylor at 816-329-3229. 

Attachment 

fi»*f/ 
^53) TRANS STATES 

AIRLMS. 

Aaron H Arcnslrong 

11495 Navaid Rd. 

Bridgeton Mo. 63044 

Tel: (314) 222-4703 

Fa.\: (314)222-4718 

Email: nannslrong@iransslnles.ncl 

November 24, 2010 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

In accordance with 14 CFR 11.63, Trans States Airlines is requesting an exemption to the 

requirements of 14 CFR 121.1109 - Supplemental Inspections deadline of December 20, 2010. 

14 CFR121.1109 requires that operators develop and include in Its maintenance program a list of 

Fatigue Critical Baseline Structure and Fatigue Critical Alteration Structure and a means for 

addressing the adverse effects of repairs, alterations and modification on the structure. We are 

requesting an extension of 180 days to the deadline requirement. 

Trans States Airlines is a 14 CFR Part 119 operator of the Embraer 145LR and EP model 

aircraft. According to the Repair Evaluation Guidelines (REG) developed by the manufacturer of 

the aircraft as required by 14 CFR 26.43, the EMB145 has a Designed Service Goal (DSG) of 

60,000 Flight Cycle (FC) or 67.200 Flight Hours (FH), whichever occurs first. The REG goes on 

to include an implementation schedule that was developed in accordance with guidance 

contained in Advisory Circular (AC) 120-93 that suggests operators begin physical surveys of 

the Fatigue Critical Structure at 45,000 FC. Trans States Airlines' highest time aircraft is 

currently has 25,617 cycles; well short of the suggested 45,000 FC. It is with these facts that 

Trans States Airlines feels that public safety is not jeopardized should the exemption be granted. 

Trans States Airlines developed and provided our proposed program to our Certificate 

Management Office (CMO) on November 16, 2010. However, there is some concern that a 

thorough review by the CMO and any subsequent revisions required by Trans States Airlines to 

die proposed program may cause Trans States Airlines not to meet the December 20, 2010 

deadline. As stated earlier, 14 CFR 121.1109 states that if the operator's Supplemental Inspection 

program is not approved by the Administrator prior to December 20,2010, the certificate holder 

may not operate an airplane under this part. 
— ^ 

Based upon the need to ensure that a safe, effective and compliant Supplemental Inspection 

program is developed, approved and implemented, Trans States is making this request for an 

additional 180 days or a date that the office feels is adequate to review and approve the 

Supplemental Inspection program. 

If you should have any questions and/or concerns with this request, please do not hesitate to 

contact me at (314) 222-4703. 

Regards, 

Aaron H Armstrong 

Director of Quality Assurance