In the matter of 

) ) 

Ainvorthiness Directive: The 

Boeing Company Airplanes 

) Docket F AA-20 14-0780 ) Directorate ID 2014-NM-168-AD 

) 

Notice of Proposed Rulemaking ) 

MOTION OF KALITTA L.L.C. 

FOR EXTENSION OF COMMENT PERIOD 

Communications with respect to this document should be addressed to: 

January 6, 2015 

Mark W. Atwood 

Cozen O'Connor 

The Army & Navy Club Bldg. 

1627 I St., N.W. 

Washington, D.C. 20006 

(202) 463-2513 

mat wood :lilcozcn.com 

Counsel fur 

Kalitta Air, L.L.C. 
Ainvorthincss l>ircctivc: The 

Boeing Compnny Airphmcs 

Notice of Proposed Rulemaking 

) Docket F AA-20 14-0780 

) Directorate ID 2014-NM-168-AD 

) 

) 

MOTION OF KALITTA AIR, L.L.C. 

FOR EXTENSION OF COMMENT PERIOD 

Pursuant to 14 CFR § 11.47, Ka1itta Air. L.L.C. ("'Kalina") hereby requests that the 

Administrator grant an additional 30 days for Jiling of public comments on the above-referenced 

proposed Airworthiness Directive. In support of this request, Kalitta states as follows: 

I. On December 1, 2014. the FAA published (79 Fed. Reg. 71 037, el seq.) a Notice of 

Proposed Rulemaking proposing to adopt an Airworthiness Directive pertaining to Boeing 747 

cargo aircraft equipped with main deck side cargo doors. This proposed AD would require 

operators to amend their airplane flight manuals to incorporate limitations for carrying certain 

payloads, and would formalize restrictions that have been inlormally imposed by the FAA on 

747 cargo operators since last year. 

2. Kalitta operates a lleet composed entirely of Boeing 747 cargo aircraft - 22 of them. 

It is one of the world's major transporters of large and heavy cargo by air, and perlorms vital 

services for various U.S. Government agencies. such as the Air Mobility Command. It thus will 

be signilicantly impacted by the rule that has been proposed. 

3. Kalitta has been working closely lor over a year with other operators of Boeing 74 7 

cargo aircraft, such as Atlas Air Cargo, Southern Air. UPS. and Western Global to address the 
expressed great concern about the precedent that would be set by language in the preamble to the 

proposal. and these concerns need to be developed and articulated. This work is still ongoing, 

and the 45 days allowed for comment on such a complex matter will not be suflicient to enable 

the carrier to adequately prepare and present its positions on this proposal. An additional period 

of at least 30 days will be necessary if Kalitta is to provide the kind of meaningful input that will 

help the agency make the best decision in this matter. 

4. There arc a number of statements contained in the proposed AD that Kalitta believes 

to be factually inaccurate, and will. ifleft unchallenged, lead to an incorrect result. Moreover, 

Kalitta believes the FAA has failed to comply with its legal obligation to accurately assess the 

economic cost of compliance with the proposed AD. The NPRM's economic impact analysis 

considers only the cost of doing the paperwork for an amendment of the Airplane Flight Manual 

- a mere $85 per aircraft. On the contrary. the restrictions represented by the AD and the policy 

position taken by the FAA over the past year have already cost the industry millions of dollars in 

lost revenues, and will cost many millions more. 

5. It is incumbent upon the FAA in undertaking what is. in li.tct, a very significant change 

in the way U.S. cargo carriers do business. to allow the most aiTected stakeholders adequate time 

2 
Dated: January 6. 2015 

3 

Mark W. Atwood 

Cozen O'Connor 

The Army & Navy Club Bldg. 

1627 I St., N.W. 

Washington, D.C. 20006 

(202) 463-2513 

ma\woodid coLcn.com 

Counsel for K~tlittu Air, L.L.C.