## 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 828-464-874114 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.