MOUNTAIN AIR CARGO, INC. 

May 18, 2015 

U.S Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Subject: Mountain Air Cargo, Inc. Request a Grant of Exemption to Title 14 CFR 91.203 

To Whom it May Concern: 

1. Introduction 

Mountain Air Cargo, Inc. (MTNA) is requesting an exemption from the provisions of 14 CFR 91.203. 

The exemption will permit MTNA to operate aircraft listed in revenue service, and any aircraft 

subsequently added to the Air Carrier's D085 Aircraft Listing of the Operation Specifications, using 

illegible or missing Certificates of Airworthiness and Registration. The required data and mitigating 

circumstances are as detailed hereafter. 

2. Explanation of the Relevant Operating Rule 

14 CFR 91.203(a) (1) states, in pertinent part, that no person may operate a civil aircraft unless it has 

an appropriate and current U.S. Certificate of Airworthiness. 

14 CFR 91.203(a) (2) states, in pertinent part, that no person may operate a civil aircraft unless it has 

an appropriate and current U.S. registration certificate. 

14CFR 91.203(b) states, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate is displayed at the cabin or cockpit entrance so that is legible to passengers 

and crew. 

P.O. BOX 488 - DENVER, NORTH CAROLINA 28037 - TELEPHONE 828-464-8741 
14 CFR 47.49 permits the holder of a certificate of aircraft registration to apply, and pay the fee, for 

a duplicate certificate of registration and obtain a temporary certificate by collect telegram if the 

holder needs to operate his aircraft before he receives the duplicate certificate. 

3. Technical Reasons for Non-Compliance 

During normal operations the Certificate of Airworthiness and Registrations may become, illegible, 

mutilated, disappear or occasionally become lost. The Federal Aviation Administration (FAA) Aircraft 

Registry in Oklahoma City, OK, only provides service from 8:00 am to 4:30 pm Central Time, Monday 

through Friday. Registration certificates requiring replacement discovered after business hours will 

cause cancellations, unnecessary delays, and loss of revenue. 

MTNA contends that even during normal working hours it can be disruptive or unnecessarily 

expensive to obtain a telegraphic registration or airworthiness certificate. Under the current rule, 

the FAA must have the application and fee in hand before a temporary certificate can be sent. 

MTNA maintains that such loss of these certificates does not reflect change of ownership, 

registration number, or state of airworthiness. Moreover, the certificates are not suspended, 

revoked or surrendered and the aircraft remain listed in the Operation Specifications and will be 

maintained under the approved continuous airworthiness maintenance program or approved 

aircraft inspection program. 

MTNA is requesting to operate the affected aircraft with a copy of the Certificate of Airworthiness or 

Registration for five (5) workii-ig days (excludii-ig weekends and Holidays) which aiiows sufficient 

time to acquire the duplicate and install in the aircraft. 

MTNA, upon approval of this Exemption, will submit a program specifically stating policies, 

procedures and responsibilities to execute this exemption, to the Certificate Management Unit, 

Principal Maintenance Inspector for approval and integration into the MTNA manual system. 

4. Aircraft Affected by the Exemption 

Those aircraft currently listed and subsequently added to the D085 Aircraft Listing of the Operation 

Specifications. 

5. The Pu bl ic I nterest 

Granting this exemption would: 

Enable MTNA to avoid flight delays and cancellations, thereby avoiding missed flights and 

flight connections for shippers and to all who depend on timely schedules and reliable air 

service. The loss of public service from a missing, illegible or mutilated certificate is 

significant. 
6. No Adverse Affect on Safety 

Granting this exemption would: 

Not affect the continued airworthiness of those aircraft in non-compliance since the 

absence of the Certificate of Airworthiness or Registration has no effect on any part of the 

aircraft necessary for safe operation. 

Not diminish safety since MTNA would continue to maintain the aircraft in accordance with 

the approved continuous airworthiness maintenance program or approved aircraft 

inspection program and would not execute the privileges of this exemption if granted, until 

the Certificate Holding District Office approves the program. 

• Not be applicable to operations beyond the 48 contiguous states. 

In conclusion of the foregoing explanations, MTNA requests that the for grant of exemption be worded 

to allow for currently listed and subsequent additions to the Air Carriers' D085 aircraft listing of the 

Operation Specifications. 

If you have any questions or comments on this matter, please feel free to contact me. 

la r d s, 

_ 

David Bain 

Chief Inspector 

Mountain Air Cargo, Inc. 

Office (828) 466-6718 

Cell (704) 807-1942 

dbain@mtaircargo.com 

CC: Michael Bandalan, VP/Director of Maintenance — Mountain Air Cargo, Inc. 

Robert Peterson, Assistant Director of Maintenance — Mountain Air Cargo, Inc.