AFS-14-353-E

May 7, 2015

 Exemption No. 11496

 Regulatory Docket No. FAA-2014-0442

Mr. Richard J. Durden

General Counsel

IFL Group, Inc.

6860 South Service Drive

Waterford, MI 48327

Dear Mr. Durden:

This letter is to inform you that we have denied your petition for exemption. It transmits our 

decision and explains its basis.

The Basis for Our Decision

By letter dated June 27, 2014, you petitioned the Federal Aviation Administration (FAA) on

behalf of IFL Group, Inc. (IFLG) for an exemption from § 119.3 of Title 14, Code of Federal 

Regulations (14 CFR) to the extent necessary to allow IFLG to operate aircraft with a 

maximum payload capacity greater than 7,500 pounds in all-cargo service under part 135.

Although you requested relief from § 119.3, that section has been redesignated to § 110.2. 

The redesignation was included in the “Operations Specifications” final rule published in the 

Federal Register on February 10, 2011 (76 FR 7482).

In your petition for exemption, you reference Exemption No. 8480, wherein such an 

exemption was granted. The FAA finds, however, that the circumstances are not sufficiently 

similar. In the case of Exemption No. 8480, the relief sought by the petitioner was relatively 

minor compared to your request. In that case, the exemption was limited to operation of the 

Embraer EMB-120 aircraft, and the operator sought to raise the gross weight of an aircraft by 

633 pounds or 8.4 percent. However, based on the types of aircraft in your operation, you are 

seeking a far greater percent increase over the current limit of 7,500 pounds. Specifically, the 
2

IFL request for the use of the Convair 5800, which can carry a max payload of nearly 

22,000#’s. This is 300% over the regulation-limited amount (7500’s) and nearly 15 times the 

excedence we have allowed under Exemption No. 8480.

Furthermore, the FAA issued a denial of exemption in circumstances similar in all material 

respects to those presented in your petition. In Denial of Exemption No. 7864 (copy 

enclosed), the FAA found that if the petitioner wanted to conduct all-cargo operations with an 

airplane that had a payload capacity greater than 7,500 pounds, it must do so as supplemental 

operations under part 121. The FAA highlighted that part 121 and part 135 each include a 

unique set of requirements that, when taken together, establish the minimum requirements that 

must be met to ensure safe operations under each part. The FAA found that allowing the 

petitioner to selectively comply with isolated sections of part 135 and part 121 rather than 

complying with all of the applicable requirements of each part would not provide an 

equivalent level of safety. Further, the FAA found that the petitioner had not articulated how 

a grant of relief would be appropriate in its particular circumstances as compared to other 

operators who might wish to operate airplanes with payload capacities greater than 7,500 

pounds under part 135. 

Having reviewed your reasons for requesting an exemption, I find that —

• they do not differ materially from those presented by the petitioner in the enclosed 

Denials of Exemption Nos. 8480 and 7684; 

• the reasons stated by the FAA for denying the enclosed Denials of Exemption 

Nos. 8480 and 7684 also apply to the situation you present; and 

• a grant of exemption would not be in the public interest.

Our Decision

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, the petition of IFL Group, Inc. for an exemption from 

14 CFR § 110.2 is hereby denied.

Sincerely,

/s/

Michael J. Zenkovich

Deputy Director, Flight Standards Service