AFS-16-14143-E 

December 2, 2016 

 Exemption No. 11125B 

 Regulatory Docket No. FAA-2014-0980 

Mr. Joseph R. Batten 

Director of Operations 

National Air Cargo Group, Inc. 

5955 TG Lee Blvd, Suite 500 

Orlando, FL 32822 

Dear Mr. Batten: 

This letter is to inform you that we have granted your petition to extend Exemption No. 

11125, as amended. It transmits our decision, explains its basis, and gives you the conditions 

and limitations of the exemption, including the date it ends. 

The Basis for Our Decision 

By letter dated September 7, 2016, you petitioned the Federal Aviation Administration (FAA) 

on behalf of National Air Cargo Group, Inc. (National Airlines) for an extension of 

Exemption No. 11125, as amended. That exemption from §§ 91.9(a), 91.1025(a), 

121.135(a)(4),121.135(b)(21), and 121.141 of Title 14, Code of Federal Regulations (14 

CFR) allows National Airlines to not apply the forward emergency-landing load factor of 9G 

specified in § 25.561(b)(3)(ii) for restraint of cargo on the main deck of Boeing 747 series 

airplanes. It applies only to all-cargo flights originating in Afghanistan for transport of cargo 

for the United States (US) Department of Defense (DoD). The FAA’s determination for 

granting Exemption No. 11125 was based on the limited risk exposure of the DoD 

Afghanistan retrograde mission coupled with the importance of the mission as it related to 

U.S. National Security. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 
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The FAA’s Analysis 

The petitioner is seeking an extension to its current exemption in order to continue to provide 

support to the U.S. DoD’s mission. The FAA’s analysis indicates that there has been no 

change in the original conditions and reasons relative to public interest and safety for the 

Boeing 747 cargo airplane when carrying tall rigid cargo. The petitioner has provided no data 

to show that the occupants would be afforded the same level of safety during a crash landing 

if the proposed lower landing loads were employed. The two restraining methods called for 

in the Boeing Weight & Balance (W&B) Manual meet the requirements in §§ 25.561 and 

25.787; however, these may not be the only acceptable methods. The FAA recognizes that 

methods can be developed that are both practical and economically viable and will consider 

proposals for changes to the Boeing 747 W&B Manual for other methods, provided that 

sufficient substantiating data is included with each proposal. As noted by the petitioner, 

granting of this extension to the exemption would allow National Airlines to continue to carry 

cargo under contract of the U.S. DoD to remove cargo from Afghanistan to support U.S. 

National interests. 

Our Decision 

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

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to National Airlines. 

The FAA has determined that the justification for the issuance of Exemption No. 11125, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the 

FAA Administrator has delegated to me, I grant National Air Cargo Group, Inc. (National 

Airlines) an exemption from 14 CFR §§ 91.9(a), 91.1025(a), 121.135(a)(4),121.135(b)(21), 

and 121.141 that allows National Airlines to not apply the forward emergency-landing load 

factor of 9G specified in § 25.561(b)(3)(ii) for restraint of cargo on the main deck of Boeing 

747 series airplanes, subject to the conditions and limitations listed below. 

Conditions and Limitations 

1. This exemption applies only to all-cargo flights originating in Afghanistan for the 

transport of cargo for the United States Department of Defense, including all flight 

segments to reach the intended final destination, provided the cargo or method to 

secure the cargo is not altered or changed prior to reaching the final destination. 

2. All cargo must be secured for all flight loads as required by 14 CFR § 25, subpart C. 

This exemption provides no relief from 14 CFR § 25, subpart C, flight loads. 
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3. The flight crew must carry a copy of this exemption on all flights operated under this 

exemption. 

The Effect of Our Decision 

This exemption terminates on December 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John Barbagallo 

Deputy Director, Flight Standards Service