# 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 ofrescinding Part 125 Operators . 2. September 2005 : Mr. Ed Bolen Chairman ofthe 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. FAA-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. FAA-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 ofannual 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 ofbusiness! 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. Gulfand 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 offlights . 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 ofbusiness in the near future.