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AMERIFLIGHT, LLC

4700 EMPIRE AVENUE HANGAR #1 BURBANK, CA 91505 (818) 847-0000 1

PETITION FOR EXEMPTION FROM CERTAIN PR OVISIONS OF 14CFR PART 91.225 FOR AMERIFLIGHT, LLC

This petition follows the requirements for inclusion in such
documents set forth in the order presented in 14CFR Part 11.81.

Your name and mailing address and, if you wish, other cont act information such as a fax number, telephone number, or e-mail address

Mr. Andrew Lotter Vice President – Flight, Director of Operations Ameriflight, LLC 4700 Empire Ave., Hangar 1 Burbank, CA 91505 Telephone – 818 847 0000 ext. 181
Email – alotter@ameriflight.com

The specific section or sections of 14 CFR from which you seek an exemption

14CFR91.225(a), (b), and (d)

The extent of relief you seek, and the reason you seek the relief

Ameriflight, LLC requests a delay in comp liance with the regulations cited above
because

1. Ameriflight, LLC anticipates supply problems for some components required for the ADS-B installations in Ameriflight aircraft due to high demand upon manufacturers and vendors, which may be exacerbated by a last-minute rush as operators attemp t to achieve compliance before the current January 1, 2020 deadline

2. Based upon current projections, and even assuming use of some outside vendors to accomplish required equipm ent installations, bringing the current fleet of approxim ately more than 160 airplanes into compliance exceeds the capability of Ameriflight’s maintenance department, as well as our ability to remove aircraft from se rvice for the required modifications. This will require an average of two ai rplanes per month out of service between now and the year 2020. While Am eriflight’s modification program is already under way the following fact ors will limit our ability to comply:

 heavy demand for aircraft during the Christmas “peak season” (which normally requires that a ll fleet aircraft, including those reserved as spares, be fully utilized during November and

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AMERIFLIGHT, LLC

4700 EMPIRE AVENUE HANGAR #1 BURBANK, CA 91505 (818) 847-0000 2 December – and in some cases, requir es that we charter aircraft to meet UPS, FedEx, and other customers’ requirements)

 other unanticipated demands upon the Maintenance Department such Airworthiness Directives with limited compliance times, mandatory fleet campaign directiv es, damaged aircraft, conversion and conformity of newly acquired aircraft, etc.
3. Ameriflight is planni ng to bring the largest, fastest, and most complex aircraft into compliance first, working through the fleet and culminating in the smallest aircraft, wh ich spend a greater proporti on (if not all) of their time below Class A airspace and away from high-traffic airports. The proposed order of operations is:

 Embraer EMB-120ER (8 aircraft)

 Beech UB and UC 1900 (24 aircraft)

 Fairchild SA-227 (46 aircraft)

 Beech 99 (57 aircraft)

 Piper PA-31 (30 aircraft) This list does not consider newly ac quired aircraft, a number of which are likely to join the fleet between now and 2020. For example, Ameriflight added a total of five SA-227 and BE-1900 airp lanes in the past two years. Newly acquired aircraft will likely be fi tted with ADS-B equipment in the course of standardization and conformity before being placed in service at Ameriflight.

4. Each aircraft type in the fleet presents unique challenges, including complete revision of the instrument panel in some cases to provide room
for ADS-B units with reasonable co ckpit standardization and ergonomics, and variations in wiring and layout in aircraft that were acquired from a variety of operators.

5. Based upon these projections and no unanticipated delays, without regard for the fact that our fleet’s cockpit s are reasonably stand ardized, and even utilizing such time-saving procedur es as pre-manufacture of wiring harnesses and installation kits, we pr oject full complian ce with §91.225 requirements by 31 December 2022. Because of the likelihood of unanticipated delays disrupting that sc hedule, we believe that a final compliance date of 31 December 2024 is realistic.

Therefore, Ameriflight respectfully requests an exemption to extend the current final compliance date for ADS-B “out” installations in Ameriflight
fleet aircraft to 31 December 2024.

The reasons why granting your request would be in the public interest; that is, how it would benefit the public as a whole

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AMERIFLIGHT, LLC

4700 EMPIRE AVENUE HANGAR #1 BURBANK, CA 91505 (818) 847-0000 3 Ameriflight aircraft currently operat e more than 1900 flights per week, transporting express packages for UPS, FedEx, and DHL, medical laboratory samples, radioactive isotopes used in medical treatment and diagnosis, and other high-priority cargo to communiti es throughout the U.S., Canada, Alaska, Central and South America, and the Caribbean. This flying touches the lives of millions of people, and numerous busine ss and government entities rely upon Ameriflight aircraft for timely delivery of urge nt cargo.

The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek the exemption

 All Ameriflight aircraft current ly operate with M ode A/C transponders

 These aircraft are engaged in all-cargo operation

 In most cases Ameriflight’s flights operate during off-peak air traffic hours and away from the busiest airspace.

 Ameriflight’s current aircraft modification plan calls for the ma jority of the fleet – including the largest, fa stest, and most complex airplanes – to be equipped in compliance with §91.225 befor e the year 2020 deadline.

 In accordance with the modification plan, the number of Ameriflight aircraft operating on this exemption will steadily taper from a small number of our smallest, slowest airplanes down to zero during the period this exemption is in
effect. For these reasons, we believe there will be no adverse effect upon safety, and public
interest considerations favor a grant of this petition.

A summary we can publish in the F EDERAL R EGISTER , stating: (1) The rule from which you seek the exemption

14CFR91.225(a), (b), and (d)

(2) A brief description of the nat ure of the exemption you seek

Relief from the ADS-B “ out” equipment requirement fo r some Ameriflight fleet cargo aircraft until 31 December 2024, for those airplanes whose modifications cannot be completed prior to the year 2020 deadline

(g) Any additional information, views or ar guments available to support your request;
and

We anticipate that a significant number of other operators will be faced with the same challenges as Ameriflight which is a combination of component availability

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AMERIFLIGHT, LLC

4700 EMPIRE AVENUE HANGAR #1 BURBANK, CA 91505 (818) 847-0000 4 issues and aircraft downtime availability that will make compliance with the year
2020 deadline unfeasible (h) If you want to exercise the privileges of your exemption out side the United States, the reason why you need to do

Ameriflight is contracted to conduct f lights six days per week for several customers, including UPS and FedEx, to destinations outside the U.S. from two
bases in Puerto Rico and others wit hin the conterminous U.S.

Ameriflight is submitting this petition gr eatly in advance of the year 2020 deadline for §91.225 in compliance with the dual purposes of providing the FAA with apt notice of our impending need for relief, and alerting the agency to the likelihood of other operators facing the same issues and challe nges with the deadline for compliance.

Please let me know if you need any further in formation or clarificat ion in connection with this petition. Thank you for your consideration.

Sincerely,

Andrew Lot ter Vice President, Flight Director of Operations