& . 

Davi d M. McDonald 

Aeronautical Engineers, Inc. vp operations 

February 2, 2012 

U.S. Department of Transportation 

Docket Management System 

400 7'^ Street SW ;;; 

Room PL 401 \ 

Washington, DC 20591-0001 ''^ r^ J • •^~ . ^-y-^'f: 

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Attention Transport Airplane Directorate _ f " 

RE: Request For Exemption From FARs For Freighter Aircraft '-'-' 

To Whom It May Concern, 

Aeronautical Engineers, Inc. (AEI) has been granted an exemption from certain Federal Aviation 

Regulations (FAR) pursuant to 14 CFR Part 11, via Exemption No. 9722, allowing the carriage of 

up to 4 non-crewmembers (commonly referred to as supernumeraries). In addition to the 

exemptions requested and granted in Exemption 9722, AEI also seeks an exemption from the 

requirements of FAR §25.810 This request is substantially similar to the requests granted to other 

freighter conversion STC holders. 

The petitioner requests relief from the following regulations: 

§25.810(a)(1), Amendment 25-114, requires there be a self supporting emergency exit slide for 

passengers. §25.810((a)(2) provides that flight crew may utilize an escape rope for emergency 

egress. 

The petitioner supports its request with the following information: 

AEI holds numerous Supplemental Type Certificates for modification of transport aircraft. With 

regard to this petition, AEI holds STC ST01827LA which allows conversion of Boeing 737-

300/400 aircraft to a freighter with a Class E main deck cargo compartment. Over 200 Boeing 

aircraft have been converted by AEI to freighters. Some operators of AEI freighters need to be able 

to carry supernumeraries to assist with special cargo such a valuable cargo requiring security 

and/or perishable, fragile, or live cargo requiring special attention to ensure its safe delivery. The 

interest of the petitioner is in providing a level of safety for the crew, supernumeraries, cargo and 

aircraft that will allow operators of AEI converted 737 freighters to meet the needs of their 

clientele. 

In this case, the supernumeraries are limited to a maximum of 4 persons. There are far fewer 

supernumeraries on a freighter than passengers on a passenger aircraft. The supernumeraries, 

unlike passengers, will be trained on emergency procedures, including emergency egress. Pursuant 

to Exemption No. 9722, the supernumeraries will be given a preflight briefing on emergency 

7765 Northwest 54 * Street Phone 305-594.5802 www.aeronautical-engineers.com 

Miami, Florida 33166 U.S.A. Fax 305.594.5804 dmm@aeronautical-engineers.com 
& . Aeronautical Engineers, Inc. 

Davi d M . McDonal d 

VP Operations 

procedures during preflight. The supernumeraries are seated immediately adjacent to the 

emergency exits. Based upon the above, AEI submits that the requirement for emergency slides is 

not necessary and that escape ropes will provide an equivalent level of safety to the 

supernumeraries. AEI's emergency rope installation consists of a permanently mounted rope 

above and immediately adjacent to the forward port door (LI). The rope is sufficiently long to 

reach the ground whether dropped out the LI door or the Rl door. 

Request for Waiver of Public Comment 

AEI requests waiver of the normal public comment process since this request is substantially 

similar to those already granted to other freighter STC holders and because the granting of tfiis 

petition will not create new precedent. 

2. Public Interest 

The carriage of an appropriate number of attendants aboard an aircraft to monitor and to attend to 

the special requirements of valuable, fragile, perishable, or live animal cargo, serves the public 

interest in raising the level of safely of the cargo, the airplane, the flight crew, and consequently, 

the public in general. In addition, these exemptions will enhance the utility of the aircraft, thereby 

helping to reduce shipping costs, which will in turn be in the public interest. 

This exemption, therefore serves the public interest for safety reasons and also for increased 

airfreight utility, both domestically and internationally and consistent commercial operations 

among all AEI freighter operators. 

AEI respectfully requests that this petition be granted. 

Sincerely, 

David M. McDonald, 

Vice President 

7765 Northwest 54'*' Street 

Miami, Florida 33166 U.S.A. 

Phone 305.594.5802 

Fax 305.594.5804 

www.aeronautical-engineers.com 

dmm@aeronautical-engineers.com