### ~ .lET11/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 ofMondoil 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 seeksthe grant ofan exemption from theprohibition ofthe SFARpursuantto SectionII C ofthe SpecialRegulation.

SFAR 77 provides that no person may conduct flight operations over or within the territory ofIraq except as otherwiseprovided in the SFAR. One such proviso, and the
one applicable to the facts ofthis request, is contained in Section II C ofthe SFAR. This section ofthe SFAR 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 describedherein by exemption. In support ofthis requestMondoil 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 usingN877A, 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. Itis expected that operations will be conducted to and from Iraq on the average ofonce monthly, although the frequency ofoperations could differ. '

Jet Aviation Flight Services, Inc. 

### IAircraft Management 

### ICharter Services 

### IFlight Support 112 Charles A. Lindbergh Drive 

### ITeterboro Airport 

### ITeterboro, NJ 07608 

### IUSA Tel. +1 201 462 4433 

### IFax +1201 625 6335 

### Iwwwjetaviation.com

### ~ .lETRIVIRTIOJIII

A <liEII\IE!RAL DYNAMICS C:CMPANV

Jet Aviation Flight Services, Inc. is provided security servicesby ONO International's security operationspriorto, and duringflight 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 ofErbil. Security teams provided by ONO International will move with both passengers and crew, ensuring that the flight crew and any ground staffare 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 ofany exterior markings exceptthe 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 ofIraq 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 ofErbil will be from ORERvia SID or OCT SEVKU UM860 KABAN, which is the ORBB FIR exitpoint, into Turkey. Exemption to SFAR 77 has been granted to other operators seeking similar supportto the oilproduction withinthe KurdistanRegion. Approval ofMondoil operations to and from Iraqwould be inthepublic interest. The Government ofthe United States has a longterm national interest in the development ofthe economy ofIraq. Oil is the primary source offoreign exchange earnings for Iraq. The Government ofIraq 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 ofthe Government ofIraq, and the entire Middle Eastregion, the national and security interests ofthe United States will be furthered by approval ofthese flight operations.

# ;:z.~~ William Thomas Director ofOperations Jet AviationFlight Services, Inc.