KA L I T T A C H A R T E R S I I, LLC

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843 Willow Run Airport • Ypsilanti, MI 48198

Toll Free: 800.KALITTA • Office: 734.544.3400 • Facsimile: 734.544.3429

www.kalittacharters.com

12/04/2012

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue

SE West Building

Ground Floor Room W12-140

Washington, DC 20590

To whom it may concern;

“Kalitta Charters II is an airline company specializing in providing nationwide cargo services 

including the transportation of bloodstock – racehorses, show horses, etc. The company 

utilizes 727 aircraft. 

“These animals are very valuable, many worth over one million dollars. The animals cannot be 

properly insured for air transport unless there are a sufficient number of qualified handlers on 

board. 

“The interest of the petitioner is in providing a level of safety for the animals and aircraft that will 

allow an expansion of his service to include international events such as the Olympics and other 

world events which involve a large number of race or show horses. 

“The 727-200 freighters presently have no provisions for a sufficient number of 

supernumerary seats to help in the care of the horses for long haul flights. 

“The petition is for an exemption from 14 CFR 25.857(e) and 25.1447(c)(1). The exemption from 

25.857(e) will allow for the accommodation of up to 16 livestock attendants or grooms on the main 

deck of a 727-200 freighter in a specially designated area; with a maximum occupancy of the 

airplane to be 19 persons, including the flight crew. The exemption from 25.1447(c)(1) will mandate 

an equivalent level of safety for attendants leaving the vicinity of the attendants’ area by requiring 

them to carry portable oxygen units. The 16 walk around oxygen bottles with masks that are stowed 

under the seats plus the 2 walk around oxygen bottles with masks stowed on the wall meet the 

requirements of 25.1447(c)(1), which requires the number of oxygen units to exceed the number of 

seats by at least ten percent. All features of the Class E cargo compartment required by 25.855 and 

25.857 will be retained and all safety requirements of part 25 as defined by the certification basis of 

the airplane in Type Certificate Data sheet (TCDS) 4A25 [sic] will be complied with. 
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“The FAA approved Aircraft Flight Manual (AFM) will contain a supplement with the operating 

limitation restricting the carriage of occupants accommodated by the specially modified section of 

this aircraft to animal handlers who are being trained for such duties. The seats may be similarly 

occupied during operations in which no cargo at all is being transported, but not to be occupied 

during operations in which any cargo whatsoever other than live animals is being transported. 

“In addition, an FAA approved training plan will be initiated to instruct the animal handlers in the 

prohibition against smoking, and procedures in equipment use relating to ditching and emergency 

evacuation. 

“Three exemptions from the federal aviation regulations are being requested – an exemption from 

25.857(e), and 25.855(a) to allow for attendants to be accommodated on the main deck of a 727-200 

freighter and an exemption from 25.1447(c)(1) to provide for an equivalent level of safety in the

dispensing of oxygen in emergency situations. All safety features of part 25 as defined by the 

certification basis of the airplane in Type Certificate Data Sheet (TCDS) 4A25 [sic] will be complied 

with. 

“This request for exemption generally follows those granted to Custom Air Transport and another 

partial grant of exemption to Aeronautical Engineers, Inc. (AEI). 

“Exemptions Being Petitioned 

“Kalitta Charters II is requesting an exemption from 14 CFR 25.857(e) to allow the carriage of up to 

16 livestock handlers on the main deck of a 727-200 freighter, and an exemption from 25.1447(c)(1) 

to allow portable oxygen units to be worn/carried by the animal attendants while they are away from 

the seat installed oxygen. Furthermore, it is requested that 25.1447(c)(1) be allowed for an 

equivalent level of safety that would consider 16 portable oxygen units with masks that can be 

stowed under the seats and 2 portable oxygen units with masks stowed on the wall as meeting the 

requirement that the number of oxygen masks exceed the number of seats by ten percent. 

“By extension, exemption from 14 CFR 25.855(a) is also requested, as this FAR requires any cargo 

compartment to comply with a designated classification of 25.857.” 

Request for Waiver of Public Comment 

“Kalitta Charters II requests waiver of the normal public comment process since this request is 

substantially similar to that already granted to Custom Air Transport and because other similar 

petitions have already been granted to accomplish the same objectives with very similar conditions.
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www.kalittacharters.com

“Justification for Request 

“1. Rationale 

“Horses are usually transported in shipping containers that can carry as many as four horses 

each. The containers are designed to fit into the existing pallet positions of the 727-200 

freighters, and depending on the configuration, could have up to 12 pallets. For this petition, 

the aft two pallets are removed to accommodate the groom seating leaving 10 pallets 

remaining. A typical load could be up to 40 horses on the main deck of a 727-200 and the 

number of qualified grooms is commensurate with the value and safety of the horses on 

board. 

“For safety reasons, the International Air Transport Association (IATA) recommends that for 

up to four pallets, one experienced groom be provided for each pallet of horses. For more 

than four pallets of horses, it is at the discretion of the carrier and the shipper to determine the 

optimum requirement. 

“The safe transport of large numbers of horses by air therefore requires the carriage of a 

commensurate number of qualified handlers on the main deck. 

“The Custom Air Transport exemption already grants the relief sought here. 

“2. Public Interest 

“The carriage of an appropriate number of animal handlers aboard an aircraft to monitor 

and to attend to the special requirements of live animal cargo, especially race horses and 

show horses, serves the public interest in raising the level of safety of livestock, the 

airplane, the flight crew, and consequently, the public in general. 

“Designing the animal handlers’ station to meet the certification basis requirements as well 

as the some of the more recent safety requirements of 14 CFR part 25 raises the safety level 

of the animal handlers to that intended for passengers. 

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

increased airfreight deliveries of these animals internationally.

“3. Safety 

“Safety is the primary concern of the modification. As stated earlier, all safety 

requirements of the original type certification of the aircraft will be complied with as 

defined by the aircraft type certification data sheet (TCDS) A3WE. Any adverse effects 

that the exemption and the equivalent level of safety of the modification will cause are 

discussed below. 
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“4. Adverse Effects 

“The exemption is to allow for the carriage of livestock attendants on the main deck of a 727-

200 freighter. Because of the level of safety provided by 14 CFR part 25, and the restrictions 

placed on the carriage of attendants as specified in the FAA approved AFM supplement, 

there are no apparent adverse effects. 

“5. Equivalent Level of Safety 

“The modification will be designed to incorporate certain features that will ensure the 

animal attendants enjoy a level of safety equivalent to that enjoyed by passengers, as 

provided by the original certifications basis of the aircraft, and some of the updated part 25 

regulations. 

“5.1 Animal Attendant Seats 

“The animal attendant seats will be fully certified to support the weight of the 

attendants, as well as any equipment, such as oxygen bottles, that will be installed 

to the seats, to the maximum load factors of the aircraft at the FS position of the 

seats, and for the emergency landing provisions of the original certification basis for 

the aircraft, CAR 4B and FAR Amendment 25-15. 

“5.2 Emergency Equipment 

“In providing for a compensating level of safety for the main deck occupants, a fire 

extinguisher, CPBE, first aid kit, transmitter (ELT) and any other required equipment 

would be provided. For emergency egress assistance, an axe will be provided to 

assist in the case of a jammed or stuck exit door. 

“5.3 Emergency Egress, 14 CFR 25.810 

“1. Doors 2R and 2L will be reactivated to serve as emergency exits. 

“2. Approved and certified slides will be installed at the doors to provide emergency 

egress from the aircraft.

“3. Flotation for the occupants will be provided by life vests and slide rafts, or rafts. 
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www.kalittacharters.com

“5.4 Supplemental Oxygen, 14 CFR 25.1447 

“Section 25.1447(c)(1) states that oxygen must be automatically presented and 

immediately available to the occupants, and the quantity of masks must exceed the 

number of seats by ten percent. We are seeking an exemption from the requirement 

for the oxygen to be automatically presented. However, we would like it to be 

considered an equivalent level of safety due to required training and familiarization of 

the handlers. 

“5.4.1 Seated Occupants 

“It is the plan of the modification to provide the seated occupants with selfcontained oxygen bottles with protective breathing masks under each seat. 

The attendants will be trained in the use of these oxygen units. 

“5.4.2 Working Grooms 

“Each groom will be able to carry the portable oxygen source with 

protective breathing masks that is stowed under there seat with them 

whenever the groom is not in the vicinity of the seats. 

“Note: It is considered that the portable oxygen units stowed under the seats, 

plus the 2 portable oxygen bottles stowed on the wall will meet the 

requirement of 25.1447(c)(1) that the quantity of masks exceed the number of 

seats by at least ten percent. 

“5.4.3 Decompression Signal 

An automatically activated decompression signal immediately 

recognizable throughout the cabin area will be provided to 

automatically notify supernumeraries when to don oxygen. 

“5.5 Emergency Lighting System, 14 CFR 25.812 

“An emergency lighting system will be provided to meet amendment 25-15 including 

the following items: 

“1. Emergency lighting illumination of the seating area, passageways, door 

signs, instructions, etc. will be provided. 

“2. Exit Identifier Signs

“3. Exterior lighting at the base of the slide
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843 Willow Run Airport • Ypsilanti, MI 48198

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www.kalittacharters.com

“Due to the proximity of the seats to the intended exits and that the occupants have 

a direct view of those exit doors, it is believed that EPL (escape path lighting) 

installation will not add to the safety level and therefore, will not be installed. 

“5.6 Lighted Fasten Seat Belt Signs, 14 CFR 25.791 

“Flight crew activated lighted “Fasten Seat Belt” signs will be provided that are 

visible while seated. 

“5.7 Lighted Return to Seat Signs 

“Flight crew activated ‘Return to Seat’ signs will be provided along the length of the 

aircraft. 

“5.8 Flight Deck Communications, 14 CFR 25.1423 

“A standard aircraft intercom/public address (PA) system will be installed and the PA 

system will be audible from anywhere within the aircraft. The PA system will be 

activated from either the flight deck, or from the supernumerary seating area. 

“5.9 Flight Phone 

“Two-way communication from the supernumerary seating area to the flight deck 

will be provided by means of a flight phone installed within reach of at least one of 

the handlers at their seats. 

“5.10 Placards 

“The following placards will be provided: 

“1. No Smoking Signs 

“2. Door Operating Instructions

“3. Slide Operating Instructions

“4. Raft Operating Instructions

“5. External Door Exit Marking 
KA L I T T A C H A R T E R S I I, LLC

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843 Willow Run Airport • Ypsilanti, MI 48198

Toll Free: 800.KALITTA • Office: 734.544.3400 • Facsimile: 734.544.3429

www.kalittacharters.com

“6. AFM Supplement 

“The FAA approved Aircraft Flight Manual (AFM) will be supplemented to contain 

operating limitations restricting the carriage of occupants to animal handlers under 

specified conditions, as well as the training required for animal handlers. 

“1. The AFM supplement will limit the seats to being occupied by animal handlers 

only. They may be similarly occupied during operations in which cargo is not being 

carried, but not during operations in which cargo, other than live animals, is being 

carried. 

“2. The AFM supplement will have a prorated scale for the number of handlers based 

on less than full utilization of the aircraft to carry livestock. 

“7. FAA Approved Training Plan 

“An FAA Approved Training Plan to instruct handlers in the prohibition against 

smoking, procedures, and equipment use relating to ditching and emergency 

evacuation. 

Sincerely;

Bob Koski

Director of Quality Control

Kalitta Charters II

843 Willow Run Airport

Ypsilanti, MI 48198

734-985-2622