Petition for Exemption

Page 1

September 25, 2015

By Electronic Submission

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: Petition of National Air Cargo Group, Inc. for an Extension to Exemption 11125 from 

14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), and 121.141 (Docket 

FAA-2015-____)

Dear Sir or Madam:

National Air Cargo Group, Inc. (“National Airlines”) hereby petitions for a two-year 

extension to the Exemption 11125 (originally submitted in Docket FAA-2014-0980) from 14 

C.F.R. §§91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), and 121.141 to allow National 

Airlines to operate B-747 freighter aircraft while transporting tall rigid cargo (freight that is taller 

than 98 inches and will not break apart during an emergency landing) restrained to withstand a 

3.0g (“3G”) forward load.

Since the granting of the original exemption, National Airlines has operated 78 flights 

under close scrutiny by both the US Department of Defense and the FAA and without incident. 

The US Department of Defense has indicated that they continue to need capacity to make these 

types of flights beyond the current expiration of the exemption in December of this year. For 

completeness, even though the information from the original petition remains largely the same, 

the complete substantiation is included with this petition

Due to US Department of Defense needs, National Airlines would like to petition the 

extension to the exemption of 9G tiedown for freight categorized as tall rigid cargo. The tall rigid 

cargo 9G requirement has caused a major impact in the ability to move US Department of 
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Defense assets back to the United States from various locations around the world. This not only 

has resulted in inability to move assets but has also caused major economic impacts on 

National Airlines and its industry counterparts. National Airlines submit that this narrowly-tailored 

exemption would have no adverse impact on safety, would provide an equivalent level of safety 

to the 9.0g ("9G") forward restraint requirement set forth in 14 C.F.R. § 25.561 (b)(3) (which is 

outdated and unsubstantiated by freighter aircraft-specific data), and would be in the public 

interest. It would enable National Airlines to carry tall rigid cargo safely, efficiently, and costeffectively. It would benefit the public interest by making available to shippers more 

commercially viable shipping options in more markets globally. And, the requested exemption 

would also allow National Airlines to realize the full capabilities of their investments in the B-747 

aircraft and stem the loss of millions of dollars of tall rigid cargo business to foreign operators 

who regularly transport tall rigid cargo without meeting the 9G forward restraint requirement.

National Airlines respectfully request expedited action on this request. The demand for 

transportation of tall rigid cargo is on the rise, and frangible cargo necessary to trigger a 3G 

forward restraint standard is becoming much less available. This is an urgent situation for 

National Airlines and for the public interest, particularly the shipping public. 

National Airlines submits the following in further support of this request:

I. Background And Exemption Request

National Airlines: National Airlines is a Part 121 certificated U.S. air carrier which 

operates a cargo fleet comprised exclusively of B-747 freighter aircraft. National Airlines 

provides charter air service worldwide utilizing a fleet of 2 B-747 freighters. Its customer base 

includes the U.S. Department of Defense, other government agencies, and multiple commercial 

entities needing to move unique cargo to challenging locations around the world, helping to 

keep the U.S. economy on the move. National Airlines and its experienced team of aviation 

professionals deliver high quality services to global customers, meeting and exceeding their air 
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cargo needs. National Airlines also operates a fleet of 2 B-757 passenger aircraft and is Part 

121 certificated to fly domestic and flag passengers operations.

Tall Rigid Cargo: There is substantial demand for transporting tall rigid cargo by air. 

There are two principal categories of tall rigid cargo:

1. Industry-standard 20-foot containers (ISO 1CC) which are 102 inches tall.

• These containers are widely used around the world throughout the global supply 

chain because they have intermodal compatibility, which is important as shipments 

are often transported from door-to-door by multimodal transportation.

• Commodities (such as oil and gas related materials), project cargo, relief goods, and 

hi-tech equipment (such as satellite and communications materials) are often 

shipped in 20-foot sea containers to remote locations where the container is also 

used as a field office or secure storage area. Garments and perishables are often 

shipped in such containers.

• Emerging markets, such as the African market (where U.S. carriers are losing 

substantial business to foreign B-747 operators due to the 9G restriction), are 

particularly reliant on the use of 20-foot containers for project and oil/gas cargo. Tall 

rigid cargo shipments are often carried on part charter flights to offline destinations.

2. Other tall items, such as aircraft engines, generators, and large vehicles, which are taller 

than 98 inches.

• For example, B-747 freighters are needed to carry aircraft engines to support many 

of the world's widebody passenger fleets, which use engines that are classified as 

tall rigid cargo.

The B-747 freighter is particularly well-suited to transport tall rigid cargo efficiently and 

cost-effectively, and has carried such cargo safely for decades. However, with the severe 

decline in "frangible" cargo and ever increasing demand for tall rigid cargo transportation (both 
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discussed in Section II below), National Airlines unable to efficiently and effectively carry tall 

rigid cargo because of the outdated 9G forward restraint requirement which National Airlines is 

not aware has been substantiated by data applicable to any freighter aircraft, much less the B747. As a result, National Airlines has lost millions of dollars of business as shippers have been 

turning to National Airlines' foreign B-747 competitors to transport tall rigid shipments. The 9G 

forward restraint requirement impairs National Airlines ability to realize the full economic and 

efficiency benefits of their substantial investment in the B-747 aircraft and reduces National 

Airlines' global competitive effectiveness. It also results in the availability of fewer service and 

pricing options for tall rigid cargo shippers.

The 9G Requirement: The 9G forward restraint requirement stems from the following 

FAR provisions:

14 C.F.R. § 25.561 and§ 25.787 establish aircraft design requirements and require that 

cargo stowage restraints handle forward inertia forces of 9G for tall rigid cargo:

14 C.F.R. § 25.561:

"(a) The airplane, although it may be damaged in emergency landing conditions on land 

or water, must be designed as prescribed in this section to protect each occupant 

under those conditions.

(b) The structure must be designed to give each occupant every reasonable chance of 

escaping serious injury in a minor crash landing when-

. . .

(3) The occupant experiences the following ultimate inertia forces acting 

separately relative to the surrounding structure:

. . .

(ii) Forward, 9.0g

. . . .

(c) For equipment, cargo in the passenger compartments and any other large masses, 

the following apply:

(1) Except as provided in paragraph (c)(2) of this section, these items must be 

positioned so that if they break loose they will be unlikely to:

(i) Cause direct injury to occupants;

(ii) Penetrate fuel tanks or lines or cause fire or explosion hazard by damage to 

adjacent systems; or

(iii) Nullify any of the escape facilities provided for use after an emergency 

landing.
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(2) When such positioning is not practical (e.g. fuselage mounted engines or 

auxiliary power units) each such item of mass shall be restrained under all 

loads up to those specified in paragraph (b)(3) of this section. . . .

(d) Seats and items of mass (and their supporting structure) must not deform under 

any loads up to those specified in paragraph (b)(3) of this section in any manner 

that would impede subsequent rapid evacuation of occupants." (Emphasis added)

14 C.F.R. § 25.787(a):

"Each compartment for the stowage of cargo, baggage, carry-on articles, and equipment 

(such as life rafts), and any other stowage compartment must be designed for its 

placarded maximum weight of contents and for the critical load distribution at the 

appropriate maximum load factors corresponding to the specified flight and ground load 

conditions, and to the emergency landing conditions of § 25.561(b), except that the 

forces specified in the emergency landing conditions need not be applied to 

compartments located below, or forward, of all occupants in the airplane. . . .” (Emphasis

added)

Although Part 25 establishes design requirements, other provisions incorporate the 

design requirements into air carrier operating requirements. Thus, 14 C.F.R. § 21.5 requires 

Boeing to incorporate the design requirements into the manufacturer's Aircraft Flight Manual 

("AFM"), and 14 C.F.R. §§ 91.9, 91.1025(a), 121.135(a)(4), 121.135(b)(21), and 121.141 

require U.S. air carriers to comply with the AFM. Boeing's and National Airlines' weight & 

balance control and loading manuals for the B-747 freighter incorporate the 9G requirement or, 

alternatively, permit the use of "frangible" cargo to prevent the tall rigid cargo from shifting 

forward. As discussed below, those compliance options are not practical or economically 

feasible.

The 9G requirement was established in the 1950s based on passenger compartment 

seating design analyses. National Airlines is not aware of the 9G passenger-compartment 

requirement having ever been substantiated by any specific cargo transportation analyses. 

Rather, the 9G passenger compartment requirement became an anachronistic regulatory "come 

along" to apply to cargo transportation. 

Moreover, studies conducted by the U.S. Air Force have shown that a 3G forward 

restraint requirement would be appropriate and provide an equivalent level of safety. Indeed, the 

U.S. Air Force has adopted a permanent reduction to a 3G forward restraint for its operations as 
Petition for Exemption

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a result of its studies. In addition, a review of B-747 freighter aircraft accidents revealed that no 

resulting injury or fatality in such accidents was attributable to cargo shifting forward.

This Petition seeks an exemption from 14 C.F.R. §§91.9, 91.1025(a), 121.135(a)(4), 

121.135(b)(21), and 121.141 to allow Part 121 operators of B-747 freighter aircraft to operate B747 freighter aircraft while transporting tall rigid cargo restrained to withstand a 3.0g ("3G") 

forward load. The requested exemption would be used in air cargo operations within, to/from, 

and wholly outside the United States. 14 C.F.R. §11 .83. Tall rigid cargo shipments for various 

shippers often involve itineraries wholly outside the United States, e.g., from Asia to Africa; 

Africa to Europe; Europe to Asia; Oceania to Africa, etc., and thus any limitation on the 

requested exemption as to its geographic scope would eliminate the exemption's real-world 

utility.

The requested exemption would maintain an equivalent level of safety and would not 

adversely affect the safety of upper deck occupants on B-747 freighters during emergency 

landing conditions. It would benefit the public interest by allowing for more effective utilization of 

the B-747 freighter aircraft and more efficient, competitive transportation of tall rigid air cargo to 

meet the needs of governmental, civilian, NGO, humanitarian, and military shippers.

II. The Issue

The bottom of the upper deck floor beams on the B-747 freighter is at a height of 98.1 

inches. In the highly unlikely event of a forward cargo shift, cargo that is 98 inches tall or lower 

will not strike the upper deck structure and occupant areas on the B-747 freighter, and therefore 

the 9G force standard set forth in 14 C.F.R. §25.561(b)(3) is not implicated: the stowage 

compartment must be designed to "the emergency landing conditions of §25.561(b), except that 

the forces specified in the emergency landing conditions need not be applied to compartments 

located below, or forward, of all occupants in the airplane. . . ." 14 C.F.R. §25.787(a). Tall rigid 

cargo, however, is not covered by the exception contained in the last clause because tall rigid 

cargo is located aft of the occupants on the upper deck.
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Boeing's and National Airlines' current weight & balance control and loading manuals for 

the B-747 freighter incorporate the restraint standards of 14 C.F.R. § 25.561(b)(3), and provide 

that tall rigid cargo must be restrained either to (1) a 9G forward load by using a cumbersome 

and complex arrangement of supplementary straps connected to aircraft tie-down points, or (2) 

a 1.5G (B-747-400) forward load combined with a specific volume of frangible cargo placed in 

front of the tall rigid cargo, in either case in order to prevent the tall rigid cargo from shifting 

forward and impacting the upper deck and occupant areas.

These two current methods for transporting tall rigid cargo on the B-747 freighter are 

simply not economically feasible or practical. 

First, restraining tall rigid cargo to a 9G forward load standard requires a cumbersome 

and complex arrangement of straps connected to aircraft tie-down points. There are a limited 

number of tie-down positions on the B-747 freighter, which makes it virtually impossible to 

restrain tall rigid cargo to 9G and carry other cargo. There are often an inadequate number of 

tie-downs on a B-747 to restrain heavy tall rigid cargo to a 9G forward load requirement; and 

even when it is possible to restrain a single item of tall rigid cargo, there are usually an 

insufficient number of tie-downs to restrain additional items of tall rigid or other cargo. As a 

result, the flight is not efficient or cost-competitive for the shipper. 

Second, it is extremely difficult, impractical, and uneconomic to use frangible cargo as a 

buffer. The changing nature of air cargo, customer demands, and aircraft routings today is such 

that there is rarely a sufficient volume of frangible cargo available to place in front of the tall rigid 

cargo. Non-commercial frangible "filler'' cargo is also impractical for logistical, cost, customs, 

and disposal reasons. Military pallets (typically 88 inches wide, not the standard 96 inches) do 

not meet the width requirements for frangible cargo when tall rigid cargo is centerline-loaded on 

the B-747 freighter. As a result, tall rigid cargo, often critical to meet urgent military, commercial, 

and humanitarian requirements, cannot be transported in a timely and cost-effective manner. 
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The inability of National Airlines to carry tall rigid cargo efficiently and competitively is an urgent 

issue, as the global demand for air transportation to carry tall rigid cargo has increased 

significantly. For example, industry-standard 20-foot sea containers are widely used around the 

world throughout the global supply chain to ship oil and gas related materials, project cargo, 

relief goods, hi-tech equipment, garments, and perishables because they have intermodal 

compatibility, offer a built-in secure storage place, and can be used as an "office" in remote 

locations. Large power generators, large vehicles, and widebody aircraft engines regularly 

require long-haul air transportation as well. But the 20-foot sea containers are 102 inches tall, 

and the large aircraft engines, power generators, and large vehicles are also taller than 98 

inches.

III. Granting The Requested Exemption Would Provide An Equivalent Level Of Safety 

And Is In The Public Interest.

As explained below, National Airlines not aware of data substantiating the application of 

the 9G requirement to freighter aircraft. However, more recent studies that were not available 

when the 9G forward restraint requirement was developed in the 1950s demonstrate that a 3G 

forward restraint standard would have no adverse impact on safety, would provide an equivalent 

level of safety, and would be in the public interest.

A. Reports and Data Show that a 3G Forward Restraint Requirement Would Have 

No Adverse Impact on Safety and Would Provide an Equivalent Level of Safety.

The deficiencies with the 9G forward restraint requirement are numerous.

First, the 9G standard was established in the 1950s, well before the B-747 aircraft was 

certificated.

Second, it considered analyses of passenger seats, passenger seat attachments, and 

the geometric relationship of the passenger seat to the interior of the passenger compartment. 

This seat-based requirement appears to have become a regulatory "come along" to apply to 
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cargo transport, without any analysis of the validity or efficacy of applying such a seat-based 

requirement to the cargo compartment.

Third, since the 9G forward restraint standard predated the B-747 by more than a 

decade, it did not account for many of the B-747's exceptional characteristics. It does not 

properly reflect the actual loads and behavior of cargo restrained by the cargo restraint system, 

straps, and nets on a B-747. Nor does it take into account the spatial separation of B-747 upper

deck occupants and the tall rigid cargo, the capability of the crown barrier net to restrain tall rigid 

cargo, or the crashworthiness and energy absorbing capability of the B-747 upper deck 

structure.

Fourth, the 9G standard clearly did not account for the infinitesimal probability that all of 

the events necessary for an occupant on the upper deck of a B-747 freighter to be harmed by 

tall rigid cargo in an emergency landing would occur. U.S. Air Force studies concluded that a 

crash event at higher than 3G with cargo and passengers is "extremely rare", with a probability 

of one occurrence per 4 million hours of operation. Cargo Aircraft and Spacecraft Forward 

Restraint Criteria, Technical Report ASD-TR-76-30, at 21 (December 1977) ("1977 USAF 

Technical Report"). Put another way, combining major and minor accidents for the period 1962 

to July 1976, the probability of a crash at the "3G to N/S Level with Cargo and Passenger" was 

"extremely rare" at 0.00000025 per hours/operation. 1977 USAF Technical Report, at 38, 50. 

And, in November 1981, "CSAF/LET approved permanent reduction to 3G forward restraint 

[c]iting 7 years of operations (6.73M flight hours) with no cargo related accidents." Presentation: 

Cargo Restraint for Fixed Wing Aircraft, 21 May 02, Aeronautical Systems Center, USAF. 

According to the same USAF presentation, "In concert with 2G up and 1.5G aft & laterally, 3G 

forward restraint has proven adequate and cost effective for 30 years of USAF cargo operations 

involving over 29M flight hours."

Fifth, in commercial operations, more than 420 B-747 freighters have flown more than 20 

million flight hours and 4 million flight cycles. There has been no report of cargo shifting forward 
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and harming an occupant on a B-747 freighter during emergency landing conditions (see NTSB 

Accident Aviation Database and 17 hull-loss occurrences on B-747 freighters documented by 

the Aviation Safety Network, www.aviation-safety.net; see also FAA Accident/Incident Data 

System). Based on a review of the B-747 model freighter accidents, it can be concluded that 

any resulting injury or fatality related to the accidents was not attributable to cargo shifting 

forward. In fact, if a cargo shift was involved in any reported accident, it only involved cargo 

shifting aft, with no reported accidents involving a forward shift at all. Since the majority of cargo 

is below the tall-rigid threshold, it can be concluded that tying down to flight loads a 1.5G 

(loading) has been shown to be sufficient in actual incidents and accidents to secure cargo 

against forward-shifting, and this Petition for a 3G tie down therefore is more than sufficient.

This conclusion is supported by the results of the 2008 accident of a Kalitta aircraft in 

Brussels. That accident involved a B-747 freighter which suffered severe damage, breaking into 

three sections after an aborted takeoff due to a bird strike. Although the main deck floor beams 

in the forward cargo section were shattered in the accident, cargo in the other sections which 

was restrained to 1.5G was still secured to the aircraft, and the crew escaped uninjured. See 

Final Report, Ref. AAIU-2008-13 (issued July 2009), Belgium Federal Public Service Mobility 

and Transport, Air Accident and Investigation Unit. 

Sixth, at forward load forces between 3G (the standard requested in this Petition and the 

standard adopted by the USAF) and 9G (the current standard), it is highly likely that the B-747 

would not stay intact. At such high G-force loads, whether the tall rigid cargo was shifting 

forward would be the least of the occupants' and crew's worries because the aircraft would likely 

not remain intact. As a 1977 USAF Technical Report pointed out: "The maximum landing loads 

that the C-130, C-141, and C-5 can generate are 0.94, 1.05, and 1.20G, respectively. This is 

assuming full reverse thrust, full braking, and a loose dirt runway. For any load above these, the 

aircraft is in a crash condition as defined by this report." 1977 USAF Technical Report, at 21. 

And, according to Boeing, during hard braking the forward flight load factors are 1.5G for the B-
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747-400 and 1.2G for the B-747-8. Indeed, loads in the 9G range would not involve an 

"emergency landing condition", but rather a crash. The aircraft and the attachment points would 

fail well before 9G. 

Seventh, the U.S. Department of Defense, which the FAA considers to be a competent 

authority, implemented the reduced 3G forward restraint requirement, and there has been no 

report of an accident where occupants have been harmed by cargo shifting forward during 

emergency landing conditions. The 1977 USAF Technical Report, which was issued after the 

development of the passenger-based 9G forward restraint standard, concluded that reducing 

the requirement to 3G for cargo operations would maintain safety and result in significant cost 

savings and simplification. In pertinent part, the Report summarized:

"The civilian fleet can also use the data in determining what design criteria to

utilize. For example, either a 3G positive locking rail system or a 3G net in

conjunction with current 11⁄2G rail system would provide an adequate system

rather than the 9G system in use today." 1977 USAF Technical Report, at 50-51.”

Accordingly, National Airlines submits that a 3G forward restraint requirement would 

provide an equivalent level of safety to the outdated 9G standard.

B. The Exemption Would Be in the Public Interest.

Granting this exemption would be in the public interest because it would enable U.S. 

operators of B-7 4 7 freighter aircraft to safely and efficiently carry tall rigid cargo, including 

multiple 20-foot sea containers, aircraft engines, large oil/gas equipment, and large vehicles, for 

humanitarian, commercial, and U.S. military shippers around the world. It would also enable B747 operators to more efficiently utilize and to realize the full capabilities of their B-747 aircraft. 

Shippers need access to reasonable, safe, and timely air transportation for their shipments of 
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tall rigid cargo. Absent this exemption, shippers will have fewer choices of carriers and fewer B747 aircraft to handle critical missions, because, as explained above, the 9G forward restraint 

requirement effectively precludes U.S. B-747 freighter operators from competing for tall rigid 

cargo shipments, without any improvement in safety. This, in turn, leads to delays for the 

delivery of critical cargo and/or substantially increases costs for shippers to get their cargo 

delivered. For example, U.S. exporters and importers are detrimentally affected as their costs 

are being driven up, and therefore their competitiveness is reduced. The U.S. military and 

NGOs with urgent humanitarian missions involving tall rigid cargo also encounter delays and 

substantially increased costs in having their vital shipments delivered.

Even in cases where a single item of tall rigid cargo could be carried, other tall rigid 

items could not be transported because the requisite tie-down attachments needed to restrain to 

9G would not be available for additional items. National Airlines estimates that the need to 

provide frangible freight or restrain tall rigid cargo to the 9G standard reduces the cargo-carrying 

capability by a minimum of 30% and, in some cases, up to 50% of the allowable volume and 

weight allowed by the Boeing 747 weight and balance loading and control manual. The public 

interest would be much better served with a 3G restraint requirement because it would allow 

more pieces of tall rigid cargo to be carried on a single flight without any reduction in safety. 

Adherence to the 9G standard results in more flights required to transport the same amount of 

tall rigid cargo, making U.S. operators uncompetitive in the marketplace.

National Airlines is losing substantial business due to their inability to offer competitive 

bids to carry tall rigid loads as a result of the 9G forward load requirement. Many foreign 

competitors routinely carry 20-foot containers and other tall rigid cargo without restraining them 

to withstand a forward 9G force.

National Airlines estimates that it is losing millions of dollars of air cargo business 

because it is unable to effectively compete for tall rigid cargo shipments in light of the 9G 

forward restraint requirement. National Airlines operates many of its flights as unscheduled "ad 
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hoc" charters, and therefore frangible freight is most often not available. As the absence of the 

frangible cargo requires the use of 9G tie downs, National Airlines often loses charters to foreign 

competitors as the tie-down requirements result in the inability to carry all of the cargo required 

for the charter. As such, National Airlines has noted a significant reduction in business and the 

loss of millions of dollars in revenue due to the 9G requirement. National Airlines additionally 

notes that on flights where nonrevenue frangible freight can be used, it has done so at the 

airline's (not the shipper's) expense, resulting in additional cost to the airline for the buildup and 

disposal of this cargo. This has also caused substantial losses due to these additional 

unrecouped costs.

In the context of economic regulation, Congress directed the Secretary to strengthen the 

competitive position of U.S. air carriers to at least ensure equality with foreign air carriers, 

including the attainment of the opportunity for U.S. air carriers to maintain and increase their 

profitability in foreign air transportation. 49 U.S.C. §§40101 (a)(15) and (e)(1). We believe that 

the FAA can act in the public interest and level the playing field without any diminution of safety 

by granting this exemption to provide for a 3G forward restraint requirement.

IV. Petitioner Requests Expedited Consideration And Approval.

National Airlines urges the FAA to expeditiously review and approve this Petition. U.S. 

B-747 operators are being adversely impacted by the application of the 9G requirement, as are

shippers. Application of a 3G requirement would not adversely affect safety and would provide

an equivalent level of safety as supported by cargo-compartment based studies. If the FAA

determines that notice and comment is required, National Airlines requests a shortened 

publication and comment period and a waiver from the requirement that petitions be submitted 

120 days before the proposed effective date of the exemption. Delay would continue to 

adversely affect National Airlines and its ability to fulfill the tall rigid cargo requirements of its

humanitarian, commercial, and military customers. At the same time, the delay would adversely 
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affect the public interest in that shippers would continue to be denied safe, timely, and costcompetitive service from U.S. all-cargo B-747 operators for flying their tall rigid cargo.

V. Conclusion.

The B-747 freighter aircraft has now flown for several million cycles and more than 20

million hours, and National Airlines is not aware of any report showing that tall rigid cargo has

moved forward and either caused frangible freight to compress or caused injury or death to any

crew member on board the aircraft. Given this substantial safety track record, the extremely low

probability of an accident in the 3G to N/S range, the impracticality and economic infeasibility of

securing tall rigid cargo to a 9G forward restraint, and the USAF's conclusion that a 3G forward

restraint requirement would provide an equivalent level of safety and would not adversely affect

safety, National Airlines requests that the FAA grant the exemption requested herein 

expeditiously.

VI. National Airlines’ Responses to the Questions Posed in Ms. Suzanne Masterson’s 

Letter on August 6, 2014 on Similar Docket FAA-2014-0184.

• National Airlines anticipates operating approximately ten flights per month for the 

duration of the US Department of Defense drawdown from Afghanistan (exact timeframe 

unknown).

• National Airlines requests exemption allowing for restraint of cargo for 3.0g (“3G”) and 

no requirement for the use of frangible cargo.

• Granting of this petition would allow National Airlines and its industry counterparts to 

carry cargo under contract of the US Department of Defense to remove cargo from 

Afghanistan to support US National interests. 

• This mission would require the transport of mostly tall rigid cargo.

• Additionally, this exemption would allow for more cargo to be carried on fewer flights, 

providing for use of fewer resources.
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We appreciate your consideration in this matter. If you require additional information,

please do not hesitate to contact me.

Sincerely,

Joseph R. Batten

Director of Operations

Contact Information

National Air Cargo Group, Inc. dba National Airlines

5955 T.G. Lee Blvd., Suite 500

Orlando, FL 32822

Phone: 407-283-6272

Fax: 407-313-2255
Petition for Exemption

ATTACHMENT 1

FEDERAL REGISTER SUMMARY

In accordance with §11.81(f), a summary of this Request for Addition to Petition for 

Exemption for publication in the Federal Register is as follows:

Docket No.: FAA-2015-____

Petitioner: National Air Cargo Group, Inc.

Section of the FAR Affected:

14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), 121.141

Description of Relief Sought: Petitioner seeks to extend current Exemption 11125 for

exemption from the requirements of 14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 

121.135(b)(21), and 121.141 to allow the operation of B-747 freighter aircraft while 

transporting tall rigid cargo restrained to withstand a 3.0g forward load.