CONQUEST AIR Inc. 

5820 Miami Lakes Drive East 

Miami Lakes, Florida 33014 

Telephone: 305-863-3108 

Cell: 305-218-0619 

U.S. Department of Transportation 

Federal Aviation Administration 

February 17, 2017 

Docket Management System,Room PL 401 

Ref: Regulatory Docket No. FAA-2016-4554 

Fax: 305-871-1622 

Additional Supporting Documents for Exemption No. FAA-2016-4554 

Maximum Payload Provision of CFR Part 110.2 

Events relating to payload increase and common carriage. 

1. August 2003 : FAA forms the 125/135 Aviation Rule Making Committee (125/135 

ARC) for the purpose of rescinding Part 125 Operators. 

2. September 2005 : Mr. Ed Bolen Chairman of the 125/135 ARC sent the ARC report to 

the FAA supporting the increase in payload for Part 135 Air Carriers, this in addition 

would provide a home for some Part 125 Operators wishing to move across to common 

carr1eage. 

3. March 2005: Ameriflight International was granted payload increase exemption. 

F AA-2005-20109 for their Embraer 120 aircraft. 

4. May 2007: Florida Air Transports exemption was denied. 

FAA-2007-26801. FAA stated that the ARC did not recommend piston powered aircraft 

for payload increase under Part 135 (This is not correct). 

5. July 2008: FAA published a Study titled "Safety Effects of Raising the Maximum 

Payload for Turboprop Aircraft in Part 135 Cargo Operations" . FAA stated that they were 

unaware that any piston powered aircraft operators would want to move to Part 135 (This 

is not correct). 
6. August 2009: Skywagon Inc. increase payload exemption was denied. 

F AA-2009-0233 Same reason as stated under Florida Air Transports denial. 

7. May 2015 : IFL Group's exemption was denied. 

FAA-2014-0442 

8. May 2016: Conquest Air exemption was denied. 

FAA-2016-4554 

9. June 7 2016: Conquest Air filed for reconsideration 

FAA-2016-4554 

Current Facts: 

1. In 2005 there were 19 Part 125 all cargo operators. 

2. In 2017 there are only 4 Part 125 all cargo operators with piston powered aircraft. 

3. Most Part 125 cargo operators closed down their business after the aviation rule 

making committees recommendation. During these ARC meetings, the DOT had a 

representative present. The information gathered during these meeting was used to 

inforce additional restriction on all Part 125 Operators such as limited number of annual 

contracts (No more than 3) and limited number of annual flight hours. 

4. These cargo operators were forced to close down their businesses because they could 

no longer be competitive due to these DOT/FAA restrictions. These operators were 

simply regulated out of business! 

5. There are only 3 Part 121 cargo Air Carriers in the entire USA that have aircraft with 

payloads below 18,000 lbs. 

a. Mountain Air Cargo (Fed Ex, ATR-42 I ATR-72) 

b. Everts Air Cargo (Tatonduk,Alaska- C-46 aircraft) 

c. Gulf and Caribbean (IFL Group, CV580&CV5800) 

6. Our company is operating aircraft at capacity that is to say that the only way to grow is 

to increase the number of flights. Once another air carrier shows up with a larger aircraft 

into the market you will be out of business. What you have done is built a business for 

someone else to take over. Throughout the history of aviation, air carriers have always 

looked for the most efficient aircraft available for various reasons including keeping the 

transportation cost down. 

The reason you don't see any Douglas DC-7 flying across to Europe is because they will 

not compete against B-767, B787, B747 or A-380. The markets will always drive the 

competition. 

This market will always drive the future aircraft that will be used to transport the goods. 

Without the ability to grow or expand, we will be out of business in the near future.