CONQUEST AIR Inc. 

5820 Miami Lakes Drive East 

Miami Lakes, Florida 33014 

Telephone: 305-593-884 7 

U.S. Department of Transportation 

Federal Aviation Administration 

Director, Flight Standards Service 

Mr. John Duncan 

Ref: Letter Dated April 11, 2017 

Dear Mr. Duncan, 

Fax: 305-871-1622 

April 18,2017 

Thank you for the response letter, I did want to clarify the major point which is payload 

increase. In my documents I have requested a payload increase of up to 12,000 lbs. from 

7,500 lbs. which is the current limit. 

In my letter to Secretary Chao I also requested an increase of up to 12,000 lbs. payload. 

I have mentioned that the Department of Transportation has a dividing line of 18,000 lbs. 

payload or less for small operators and above 18,000 lbs. payload as large operators and 

that the FAA had conducted a Study to increase payload for part !35's as well, this may 

have led to the misunderstanding of the requested payload increase. 

We realize there is a difference between 12,000 lbs. payload vs 18,000 lbs. payload and I 

wanted to clarify this point. 

Carlos Gomez 

Cell: 305-218-0619 

Attachment 

March 01 , 2017 letter to Secretary Chao 
CONQUEST AIR Inc. 

5820 Miami Lakes Drive East 

Miami Lakes, Florida 33014 

Telephone: 305-863-3108 

U.S. Department of Transportation 

Secretary of Transportation 

Mrs. Elain Chao 

Fax: 305-871-1622 

March 01 , 2017 

Ref: Removing a 50 + year old FAA restriction that is killing small cargo operators 

Dear Transportation Secretary Chao, 

Conquest Air is a small FAA Part 135 Cargo Air Carrier operating out of Miami into the 

Bahamas daily. In 2016 we conducted 434 flights with our Convair 340 aircraft; these 

aircraft have an artificial payload restriction of 7,500 lbs. when in fact if operating at their 

normal payload would be approximately 12,000 1bs. payload. We are currently operating 

at a 37% inefficiency which has added a substantial cost to our operation as well as an 

increase cost to all of the U.S exporters exporting into the Bahamas due to the 7,500 

current payload restrictions. There are several documents that have been posted 

throughout the FAA websites concerning this same subject. 

We believe the FAA has all the supporting documentation including recommendations 

within their own department which supports increasing the payload on Part 135 Air 

Carriers from 7,500 lbs. to 18,000 lbs. which is the dividing line used by the Department 

of Transportation. 

This payload restriction is out dated and obsolete, the fact that we currently have 3 air 

carriers operating aircraft under 18,000 lbs. payload is a testament to the damage this 

restriction has caused. Once a market out grows the 7,500 lbs. payload, the air carrier will 

be out of business due to the inability to expand or grow into larger aircraft. 

Without the ability for Conquest Air to operate its aircraft at 12,000 lbs. we will be forced 

to seriously consider moving our operation overseas to the Bahamas which would permit 

our aircraft to operate at 12, 000 lbs. payloads. 

We are writing you this letter in the hope that Mr. Trump keeps his campaign promise to 

help small businesses that has been decimated by outdated regulations and policies. 

We have been trying to have this issue resolved for years; the past administrations have 

chosen to do absolutely nothing about this situation. I hereby recommend this be the first 

old regulation that he removes. 
Please take a look at our current FAA docket Number: FAA-2016-4554 which has been 

pending for quite some time now. It has now been over 10 years since the Aviation Rule 

Making Committee recommended to the FAA a payload increase for Part 135 Air 

Carriers. 

I am available to meet with you and your staff to discuss this in detail. 

I am looking forward to your response. 

Sincerely, 

Vice-President 

"For every one new regulation, two old regulations must be eliminated" 

President- Donald Trump 

"To improve is to change; to be perfect is to change often" 

Winston Churchill 
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 

Secretary of Transportation 

Mrs. Blain Chao 

March 01, 2017 

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 

carneage. 

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. 

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 IF AA 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. 
7. There is a huge cost to all the U.S. exports who are shipping goods to the Bahamas, we 

currently have one of the highest transportation rates in the world when you compare cost 

per pound vs distance. 

8. Having the ability to increase our payload would allow us to grow and expand into 

more modem aircraft which would be even more efficient and would help drive down the 

current cost of transportation. This cost is affecting all U.S exporters all the way down to 

the American farmer. Lowering the transportation cost is a huge deal to all exporters and 

U.S. commerce. 

The reason there are only 3 Part 121 Air Carriers in the U.S. is because everyone else has 

been regulated out of business, it's not because the business disappeared. 

One must acknowledge the facts; you have to ask yourself why several operators have 

opted for reducing payloads in order to operate under Part 135. The reason is simple, it is 

impossible for a small operator to operate any small aircraft as defined by the DOT 

(18,000 lbs. payload or 60 seats) in a Part 121 operation. 

One possible solution to this issue is to get into a joint venture with a foreign Part 129 air 

carrier that has open skies with the USA. We have considered this option, however we 

feel this option is not the proper solution. We prefer to do everything possible to remain 

as a US air carrier; we want to remain in the U.S., we want to keep our employees and 

not have to hire foreigner at the cost of American jobs. 

We are at a very critical phase in our operation which requires a solution to the issue 

immediately. 

I am available to meet with you at any time to answer any questions you may have. 

Thank you for your time and consideration in this matter. 

Sincerely, 

Carlos Gomez 

Cell: 305-218-0619