15 January 2015

To: US Department of Transportation

Federal Aviation Administration

Subject: Petition for exemption – 737-700BDSF - Special Freighter Modification - Provisions for Safety of Supernumeraries

1) Introduction IAI has requested to certify (STC) a major modification of a Model 737-700 Series aircraft from passenger to a Bedek Special Freighter (BD SF) configuration. The program is being certified by the CAAI, then by the FAA via a valida tion process. The project has been assigned the FAA project number ST12406SE-T. IAI is requesting to be granted an exemption from meeting cert ain requirements, pertaining to the following:

• Carriage of two non-crewmembers (supernumeraries), in a dedicat ed supernumerary compartment in addition to the existing flight deck occ upancy of two flight crewmembers, and two observers.

• Access of supernumeraries into the Class E compartment in flig ht for the purpose of attending to the cargo.

• Use of non-presenting oxygen masks in the supernumerary compartment a nd use of portable oxygen bottle by persons entering the Class E cargo compartment in lieu of self-presenting oxygen masks.

• Relief from the requirement for hand holds for persons entering Clas s E cargo

compartment

• Relief from requirement for assist space at floor level exit.

The exemption is requested for B737-700 aircraft modified to special f reighter under an IAI STC. The configuration of the modified airplane as related to t he carriage of supernumeraries and the requested exemptions are identical to the con figuration of the IAI 737-300/-400 special freighters and exemptions which were previousl y granted to it by the FAA (Ref Exemptions 8335 and 8335B for B737-300 and 9792 for B737-400).

a. FAR 25 Affected Sections

Section 25.785(j), at Amendment 25-88 Seats, berths, safety belts, and harnesses

, requires in pertinent part, that that there be a firm handhold, handgr ip, or rail along each aisle to enable persons to steady themselves while using the ais les in moderately rough

air. A I R C R A F T D I V I S I O N

I S R A E L A E R O S P A C E I N D U S T R I E S L T D B e d e k A v i a t i o n G r o u pSection 25.813(b), at Amendment 25-128 Emergency Exit Access , requires, in pertinent

part, that adequate space to allow crewmember(s) to assist i n the evacuation of passengers must be provided.

Section 25.857(e), at Amendment 25-93 Cargo Compartment classification , requires, in pertinent part, that when a Class E cargo compartment is instal led on the airplane, the airplane be used for carriage of cargo only.

Section 25.1447(c)(1), at Amendment 25-116 Equipment Standards for Oxygen Dispensing Units , requires, in pertinent part, that oxygen-dispensing units must be automatically presented to the occupants before the cabin altitude ex ceeds 15000 feet. The total number of dispensing units and outlets must exceed the number of seats by at least 10 percent. The extra units must be uniformly distributed throug hout the cabin as practicable, and there must be two oxygen masks in each lavatory.

b. Related Sections of the FAR

Section 121.583(a) Carriage of persons without compliance with the passenger-carrying requirements of this part contains, in pertinent part, a listing of categories of the people who may be carried aboard an airplane in part 121 services without c omplying with the requirements of part 121 to carriage of passengers.

2) Description of the converted airplane configuration

General The Boeing B737-700 is a transport category airplane. The converted 737-700BDSF will have an all-cargo main deck configuration. A new 9g rigid cargo/smoke barrier located aft of doors 1L and 1R, separates the Class E main deck cargo compartment from the supernumerary compartment (See Fig.1). The existing flight dec k accommodation for pilot, co-pilot and two observer seats are retained from the type ce rtified aircraft providing for a flight deck maximum occupancy of four persons. Two (2) a dditional noncrewmembers (supernumeraries) are seated in the supernumerary compartment on the original existing aft facing flight attendant seats, which ar e mounted on the aft wall of the forward lavatory near door 1L.

Supernumerary seats The type certified aft facing cabin attendant seats and their r estraint harness are retained unchanged from the type certified aircraft. Life vest and their stowage provisions are also retained unchanged for the use of the supernumeraries.Figure 1 737-700BDSF Layout LIFE VESTS

FLSAHLIGHT

PORTABLE OXYGEN

FULL FACE MASK

LIFE RAFTS STOWAGE

(PROVISIONS) PORTABLE

ELT FIRE EXTINGUISHER

PBEEmergency exits arrangement and emergency evacuation

The existing original aircraft emergency egress means doors 1 L and 1R are not affected by the modification to freighter and are retained with their sli des, markings, accessibility and illumination. These doors provide the emergency exits for the supernume raries in compliance with the regulations, except for the lack of assist spac e aft of door 1L due to the installation of the rigid barrier closely aft of the door. Flight deck exits and evacuation are not affected by the conversion to freighter. Following an emergency landing, an evacuation alert signal will be given to the supernumeraries through an existing attendant evacuation signaling system.

PA system and Intercom The existing Public Address (PA) system is retained in the supernumerary a rea. The existing forward attendant station intercom is retained.

Oxygen equipment The conversion to freighter requires the capability to depressurize the airplane in order to extinguish a fire in the class E compartment and to cruise at an altitude of 25000 feet until a landing is possible. In order to provide oxygen for the airplane occupants for the require d duration the following equipment is provided: For the two occupants in the supernumerary area, two oxygen bottles w ith two masks that are permanently connected to the bottles are installed within re ach of the seated supernumeraries. The oxygen bottles are sized for the maximum requi red flight duration. An illuminated "Use Oxygen" sign is installed in direct view of the seated supernumeraries. Illumination of the sign, combined with an audible warni ng signal over the PA, will be operated automatically in case of loss of cabi n pressure or manually by the flight crew at cabin altitude above 15000 feet, to alert the supernumeraries. Due to the close proximity of the galley area to the supernumerar y seat PSU, there is no need for an additional oxygen source at the galley. A lighted “ Return to Seat” sign shall be installed at the galley area, activated automatically and manually simultaneously with the “Use Oxygen” signal. Lavatory compartment self-presenting oxygen masks dispenser is re tained in the type certified configuration. Oxygen supply to any person entering Class E cargo compartment i s provided by an 11 cubic feet portable oxygen bottle with full face mask, which must be carried by the person entering the compartment at all times. Persons in the car go compartment will be warned to use oxygen and return to seat through a cargo compartment alert system

. Smoking is not permitted in the compartment. Appropriate instruction plac ards are installed on the cargo compartment and lavatory entry doors. The flight deck oxygen system, as certified in the original airc raft for the four flight deck occupants, is sufficient for the required flight duration and is not aff ected by the conversion to freighter.Cargo compartment alert system

A flight deck operated switch shall activate a visual alert system flashing alternate compartment lights for the duration of 20 seconds to indicate to any person within the compartment that immediate return to seat is required. The syst em shall be activated by the flight crew to warn persons in the cargo compartment of a nee d to return to seat due

to a smoke alert or an imminent turbulence. An aural and visual alert system consisting of horns and flashing of alternate compartment lights will be automatically activated in case of loss of cabin pressure at cabin altitude above 15000 feet, and in case of activation of the decompr ession mode or manually by the flight crew, to alert any person in the class E compartme nt to don oxygen

mask and return to seat. Appropriate instruction placards are installed at the cargo compartment e ntry door.

Lavatory Compartment The forward lavatory compartment is retained unchanged from the type certified aircraft including the self-presenting oxygen mask and "Return to Seat" sign.

Crew Galley G1 galley unit is retained from the type certified aircraft. An illuminated "Return to Seat" sign is installed on the face of the galley. The galley is located in close proximity to the oxygen bottle and the supernumerary s eats. A fire extinguisher and a PBE are installed on the rigid barrier adjacent to the gal ley.

Cargo Compartment Access Door An entry slide door in the 9g barrier provides access to the main dec k Class E cargo compartment from the supernumerary compartment. The door and barrier shall be designed to prevent smoke penetration into occupied areas. The door must be closed a t all times except for entry and exit. Entry into the compartment is prohibited during taxi, takeoff and landing or in case of fire within the compartment. A placard on the door provides the operating instructions and limitations accordingly.

Flight Manual Limitations The Airplane Fight Manual Supplement shall include all the limitations and instr uctions related to the carriage of supernumeraries and their entry into the class E co mpartment in flight including instructions for their pre-flight briefing by the crew.3) Requested exemption

Exemption from the abovementioned Sections is sought to the following ex tent:

Section 25.785(j): An exemption is requested from the requirement for a firm hand hold, hand grip or hand rail for persons entering the cargo compartment in fl ight. As the compartment is a large open space it is impractical to provide ha nd hold for a person entering the compartment. Instead, an equivalent safety is provided by the alert system that is available for the flight deck crew to warn persons in the cargo compartment of imminent turbulence and of the need to return to their seats and by their physical capability and training.

Section 25.813(b): An exemption is requested from requirement for assis t space adjacent to exit door. Assist space is not needed since supernumerary persons are capable of performing autonomous evacuation of the aircraft and there is no cabin crew on board to provide assistance.

Section 25.857(e): Relief is sought to permit carriage of four (4) non-c rew persons (Two observers and two supernumeraries) in addition to the two flight crewm embers, on an allfreighter airplane, which has a class E cargo compartment.

Section 25.1447(c)(1): An exemption is requested to allow usage of non sel f presenting oxygen dispensing units in the supernumerary compartment. The self-pres enting masks alert passengers to use the oxygen and put the masks within easy re ach. An equivalent safety is provided by having oxygen bottles with connected masks inst alled within reach of the seated occupant of the supernumerary compartment and by an aut omatic and manual alert system illuminating an ordinance sign with an audio alert signal to instruct the person to don the oxygen mask in case of drop of cabin pressure.

An exemption is requested to allow usage of non self presenting ox ygen dispensing units in the class E compartment. An equivalent level of safety is provi ded by having a portable oxygen bottle with a full face mask carried by each pers on entering the Class E cargo compartment at all times and by an automatic and manual audio and visual alert system alerting the person to don the oxygen mask.

4) Supporting Arguments

Exemption from cargo only provisions of Section 25.857(e) has been previousl y granted to IAI for cargo conversions of B767-200SF, B747-200/-300SF , B737-300SF/RB/QC

and B737-400SF aircraft.

1. The cargo operators need for their missions a number of support personne l, necessary for the safe handling of the cargo in the process of lo ading/offloading and for in-flight attendance of the cargo. Such personnel are obviously nee ded both at departure and destination of a cargo flight. It is important that t he cargo handlers arepresent upon airplane arrival, particularly if perishable goods or live animals are

carried. The most efficient way to assure their attendance at destination airport is to transport them aboard the cargo flight. 2. Among their various missions, the cargo operator may have to carry particular kinds of goods, such as live animals, hazardous materials, valuable or perisha ble cargo. Such types of cargo cannot be left unattended, even for the duration of a flight, and the presence of personnel qualified in their handling is necessary on the airplane on which they are carried. Safety and efficiency of the operati on will therefore be

enhanced. 3. Cargo operators also need to have qualified personnel necessary f or operation and maintenance purposes at various locations. They will optimize their missions if they are permitted to carry their personnel aboard their cargo flights, thus sa ving travel by regular passenger flights. 4. The categories of the supernumerary persons for which this exem ption is requested are as defined on FAR Section 121.583(a), they are trained as to the autonomous use oxygen masks, emergency equipment and emergency exit operation. It will also be required that the operator allows access to the supernumerary seats only to persons trained in the necessary emergency procedures. These persons must be physically capable of using the rope descent means and will not ne ed assistance by a crewmember. The non-crewmembers shall be briefed preflight about the emergency procedures by the flight crew. The necessary inst ructions shall be incorporated in the Airplane Flight Manual.

5) Supporting arguments for the additional sections affected

The airplane reconfiguration for carriage of cargo does not enable pr oviding assist space adjacent to the exits as required by Section 25.813(b). The use of assi st space adjacent to the emergency exits is not necessary, however, as the conside red categories of personnel will be trained for operation of main exit doors and for autonomous

evacuation.

The exemption from Section 25.785(j) requirement to provide a handhold is justi fied by providing means that enable flight deck crew to warn persons in the m ain deck of imminent turbulence, signaling them of the need to return to their sea ts and fasten seat belts. Appropriate instruction placards will be installed at the e ntrance to the main deck cargo compartment and the requirement for pre-flight briefing of the supernumeraries in this respect will be added to the AFM Supplement.

The requirements of Section 25.1447(c)(1) to have automatic presentation of oxygen dispensing units before the cabin pressure altitude exceeds 15000 feet are compensated by the fact that the supernumeraries will have knowledge of equipme nt location and use and by their seating in direct view of the "Use Oxygen" instruc tion sign. This signal, combined with the training and briefing provided to the supernumeraries is considered equivalent to the dropping masks of a passenger airplane.Masks shall be accessible to seated occupants of 5'2" to 6'3" st ature. The quantity of

oxygen is sufficient for the maximum duration of the flight incl uding an intended decompression for suppression of cargo fire.

A portable oxygen bottle with full face mask must be carried by e ach person entering the Class E cargo compartment at all times. An automatic and manual aural and visual alert system is provided to instruct the person to don the oxygen mask in cas e of drop of cabin

pressure.

Public Interest

Granting the requested exemption will be in the public interest, as by allowing the carriage of the supernumerary persons aboard the cargo flights the operat ors will be able to optimize the safety conditions of the cargo operation and to make t he operation more

efficient. Improving the utility of the airplanes reduces the total number of a irplanes and affects the environment and the airports congestion.

David Gat Acting Director, Certification

Aircraft Division Bedek Group Israel Aerospace Industry