~ .lET 11/V.IRTION A GENERAL DYNAMICS CCMF'ANY 

Mondoil Enterprises International, LLC petition for an exemption from Special 

Federal Aviation Regulation No.77 §91.1605 of Title 14, Code of Federal 

Regulations 

Dear Sirs: 

The undersigned, on behalf of Mondoil Enterprises International, LLC ("Mondoil") 

hereby seeks FAA approval to conduct flight operations to and from Iraq as further 

described herein. Special Federal Aviation Regulation No. 77 prohibits flight 

operations conducted with U.S. registered aircraft except as may be approved by the 

FAA. Mondoil hereby seeks authority to conduct Part 91 flight operations with 

aircraft owned or leased by Mondoil, and flown by airman employed by Jet Aviation 

Flight Services, Inc., holding certificates issued by the Federal Aviation 

Administration. Mondoil hereby seeks the grant of an exemption from the prohibition 

of the SF AR pursuant to Section II C of the Special Regulation. 

SF AR 77 provides that no person may conduct flight operations over or within the 

territory of Iraq except as otherwise provided in the SF AR. One such proviso, and the 

one applicable to the facts of this request, is contained in Section II C of the SF AR. 

This section of the SF AR states that the special regulation does not prohibit persons 

otherwise precluded from conducting operations over or within the territory of Iraq 

when such operations are either; (i) authorized by another U.S. Government agency 

with the approval of the FAA, or; (ii) authorized by an exemption granted by the 

Administrator. Mondoil hereby seeks the approval of the FAA for the operations 

described herein by exemption. In support of this request Mondoil states as follows: 

Mondoil proposes to conduct operations between points outside of 

Iraq and Erbil, Iraq through ORER (ICAO designator). These flight 

operations will be conducted under Part 91 authority using N877A, a 

long range, turbojet aircraft, owned and operated by Mondoil. The 

aircraft flight crews will all possess airman certificates issued by the 

FAA. The aircraft will transport key executives and others in 

furtherance of the business interests of Mondoil, who is exploring 

and developing oil fields located in the Kurdistan region ofiraq. It is 

expected that operations will be conducted to and from Iraq on the 

average of once monthly, although the frequency of operations could 

differ. ' 

Jet Aviation Flight Services, Inc. I Aircraft Management I Charter Services I Flight Support 

112 Charles A. Lindbergh Drive I Teterboro Airport I Teterboro, NJ 07608 I USA 

Tel. +1 201 462 4433 I Fax +1201 625 6335 I wwwjetaviation.com 
~ .lET RIVIRTIOJIII A <liEII\IE!RAL DYNAMICS C:CMPANV 

Jet Aviation Flight Services, Inc. is provided security services by ONO International's 

security operations prior to, and during flight operations. ONO International maintains 

a presence in Erbil and will maintain close communication with the company and the 

aircraft flight crew during operations into and out of Erbil. Security teams provided 

by ONO International will move with both passengers and crew, ensuring that the 

flight crew and any ground staff are adequately protected while in Iraq. Jet Aviation 

Flight Services, Inc. has on staff flight control and international trip plam1ers who 

work closely with ONO International security and a dedicated team at Universal 

Weather and Aviation, to manage flight logistics. The aircraft is free of any exterior 

markings except the FAA aircraft registration number. 

Flights will operate the aircraft to and from Iraq in accordance with threat 

assessment and all local operating rules/procedures so to exit the SFAR area 

expeditiously and thereby minimize hazards to the aircrew and aircraft. Routing 

into and out of Iraq will be through Turkey (L TAA) FIR. Routing into Erbil the 

flight will exit from Turkey LTAA FIR, into the Iraq ORBB FIR at position 

NINVA UM688 ROXOP, then OCT or via STAR to ORER. Routing out of Erbil 

will be from ORER via SID or OCT SEVKU UM860 KABAN, which is the ORBB 

FIR exit point, into Turkey. 

Exemption to SF AR 77 has been granted to other operators seeking similar 

support to the oil production within the Kurdistan Region. 

Approval ofMondoil operations to and from Iraq would be in the public interest. The 

Government of the United States has a long term national interest in the development 

of the economy of Iraq. Oil is the primary source of foreign exchange earnings for 

Iraq. The Government of Iraq has embarked on a program to increase oil production 

and to export oil to support its growing revenue needs. Mondoil is assisting those in 

Iraq that are pursuing oil exploration and development. To the extent increasing oil 

related revenues will allow for greater stability of the Government of Iraq, and the 

entire Middle East region, the national and security interests of the United States will 

be furthered by approval of these flight operations. 

;:z.~~ William Thomas 

Director of Operations 

Jet Aviation Flight Services, Inc.