_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

1

PETITION FOR EXEMPTION FROM CERTAIN PROVISIONS 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 contact 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 compliance 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 attempt 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 equipment installations, bringing the 

current fleet of approximately more than 160 airplanes into compliance 

exceeds the capability of Ameriflight’s maintenance department, as well as 

our ability to remove aircraft from service for the required modifications. 

This will require an average of two airplanes per month out of service 

between now and the year 2020. While Ameriflight’s modification program 

is already under way the following factors will limit our ability to comply: 

 heavy demand for aircraft during the Christmas “peak season” 

(which normally requires that all fleet aircraft, including those 

reserved as spares, be fully utilized during November and 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

2

December – and in some cases, requires 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 directives, damaged aircraft, conversion 

and conformity of newly acquired aircraft, etc. 

3. Ameriflight is planning to bring the largest, fastest, and most complex 

aircraft into compliance first, working through the fleet and culminating in 

the smallest aircraft, which spend a greater proportion (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 acquired 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 airplanes in the past two years. 

Newly acquired aircraft will likely be fitted 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 cockpit 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 cockpits are reasonably standardized, and even 

utilizing such time-saving procedures as pre-manufacture of wiring 

harnesses and installation kits, we project full compliance with §91.225 

requirements by 31 December 2022. Because of the likelihood of 

unanticipated delays disrupting that schedule, 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 
_____________ 

AMERIFLIGHT, LLC 

4700 EMPIRE AVENUE 

HANGAR #1 

BURBANK, CA 91505 

(818) 847-0000

3

Ameriflight aircraft currently operate 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 communities throughout the U.S., Canada, Alaska, 

Central and South America, and the Caribbean. This flying touches the lives of 

millions of people, and numerous business and government entities rely upon 

Ameriflight aircraft for timely delivery of urgent 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 currently operate with Mode 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 majority of the fleet 

– including the largest, fastest, and most complex airplanes – to be equipped 

in compliance with §91.225 before 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 FEDERAL REGISTER, stating: 

(1) The rule from which you seek the exemption 

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

(2) A brief description of the nature of the exemption you seek 

Relief from the ADS-B “out” equipment requirement for 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 arguments 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 
_____________ 

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 outside the United States, 

the reason why you need to do 

Ameriflight is contracted to conduct flights 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 within the conterminous U.S. 

Ameriflight is submitting this petition greatly 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 challenges with the deadline for compliance. 

Please let me know if you need any further information or clarification in connection with 

this petition. Thank you for your consideration. 

Sincerely, 

Andrew Lotter 

Vice President, Flight 

Director of Operations