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

R e: Petition of National Air Cargo Group, Inc. for an E xtension 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), a nd 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 o f 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 typ es 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 D epartment of Defense needs, National Airline s would like to petition the extension to the ex e m ption 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 Departmen t ofPetition for Exemption Page 2 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 s ubmit 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. 561 (b)(3) (which is outdated and unsubstantiated b y freighter aircraft

- specific data), and would be in the public interest. It would enable National Airlines to carry tall rigid cargo safely, efficiently, and cost

effectively. It would benefit the public interest by making available to shippers more

comme rcially 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 car go 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 submit s the following in further support of this request : I. Background And Exemption Request National Airlines: National Airlines is a Part 121 certificat ed 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 airPetition for Exemption Page 3 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: The re 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 throughou t 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 carg o. 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 ca rried such cargo safely for decades. However, with the severe decline in "frangible" cargo and ever increasing demand for tall rigid cargo transportation (bothPetition for Exemption Page 4 discussed in Section II below), National Airlines unable to efficiently and effectively carry ta ll 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 B

747. As a result, National Airlines has lost millions of dolla rs 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 t heir 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.Petition for Exemption Page 5 (2) When such positioning i s 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 structu re) **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, ba ggage, 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 t he 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 F light 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 incor porate the 9G requirement or, alternatively, permit the use of "frangible" car go 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 establis hed 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 compa rtment 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 asPetition for Exemption Page 6
a result of its studies. In addition, a review of B

- 747 freighter aircraft accidents revealed that no resulting injury or fatality in su ch 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 B

747 freighter aircr aft 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 f or 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 elimin ate 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 pub lic 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 landi ng 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.Petition for Exemption Page 7 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 th e 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. S econd, 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 requi rements 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

- effe ctive manner.Petition for Exemption Page 8 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 t all, 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 sta ndard 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 Equiv alent 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" t o apply toPetition for Exemption Page 9 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 r estraint 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 th e 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 Repor t"). 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, Aeronautic al 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 forwardPetition for Exemption Page 10 and harming an occupant on a B

- 747 freighter during emergency landing condit ions (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 accid ents, 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 carg o 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 s evere 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 sec ured 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 standar d 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

assu ming 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

-Petition for Exemption Page 11

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. Dep artment 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 landi ng 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 c ost 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 curre nt 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, incl uding 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 B

747 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 ofPetition for Exemption Page 12 tall rigid cargo. Absent this exemption, shippers will have fewer choices of carriers and fewer B

747 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 dela ys 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 competitivene ss 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 res train 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 interes t 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 transpor t 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 re quirement. 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 i s 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 "adPetition for Exemption Page 13 hoc" charters, and therefore frangible freight is most often not available. A s 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 airl ine'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 fore ign 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 Request s Expedited Consideration And Approval. National Airlines urge s the FAA to expeditiously review and approve this P etition. 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 request s a short ened 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 r igid cargo requirements of its humanitarian, commercial, and military customers. At the same time, the delay would adverselyPetition for Exemption Page 14
affect the public interest in that shippers would continue to be denied safe, timely, and cost

competitive service from U.S. all

- ca rgo 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

move d 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 impracticalit y 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 request s 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 appr oximately 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 fra ngible 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.Petition for Exemption Page 15 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

- 2255Petition f or 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

- 201 5

-

____ 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 seek s 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.