June	27,	2014

Docket	Management	Facility

U.S.	Department	of	Transportation

1200	New	Jersey	Avenue,	SE

West	Building,	Ground	Floor,	Room	W12-140

Washington,	D.C.			20590

Re:		Petition	for	Exemption

Via	Electronic	Filing	and	U.S.P.S.

Dear	Sir	or	Madam:

Pursuant	to	14	CFR	Part	11,	this	is	a	Petition	for	Exemption	from	specific	portions	of	14	

CFR.	

I.		 Name	and	mailing	address:		Richard	J.	Durden,	General	Counsel,	Gulf	& Caribbean

Cargo,	Inc. ,	6860	S.	Service	Drive,	Waterford,	Michigan	48327,	248-666-1961,	direct	line	

(cell)	616-901-6516,	email rdurden@iflgroup.com.	

II. Relief	is	sought from	14	CFR	Part	119.3	to	allow	IFL	Group	to	operate	its	aircraft	

with	a	maximum	payload	capacity	greater	than	7,500	pounds	in	all-cargo	service	under	14	

CFR	Part	135.	

III. Extent	of	relief	sought	and	reasons:		IFL	Group	seeks	an	exemption	to	operate	its	

aircraft	engaged	in	Part	135	all-cargo	service	with	a	maximum	payload	of	more	than	7,500	

pounds	but	not	to	exceed	the	certificated	maximum	takeoff	weight	for	the	aircraft.	

IV. Public	Benefit:		The	FAA	has	certified	aircraft	operated	by	IFL	at	a	maximum	gross	

weight	which	is	the	maximum	weight	at	which	our	company	operates	the	airplanes.		

However,	in	some	of	its	operations,	carrying	fuel	to	safely	conduct	the	flight	with	at	least	

the	reserves	required	by	the	FAA	means	that	7,500	pounds	may	be	loaded	on	the	airplane	

and	the	airplane	is	still	below	the	certificated	maximum	gross	weight.		From	time	to	time	

this	means	that	the	airplane	could	have	carried	all	of	a	load	of	cargo	assigned	to	us	under	
the	certification	regulations,	but	not	under	Part	135—therefore,	either	two	flights	are	

necessary	to	transport	the	cargo	or	a	larger	airplane,	operating	under	Part	121,	must	be	

used.		In	either	case	the	cost	to	the	customer	is	increased	substantially	and	there	is	

unnecessary	environmental	degradation	due	to	fuel	burn	and	carbon	emissions	from	an	

aircraft	that	is	larger	than	necessary	for	the	amount	of	cargo.	

V. Reasons	the	exemption	would	not	adversely	affect	safety,	or	how	the	exemption	

would	provide	a	level	of	safety	at	least	equal	to	the	current	rule:		At	no	time	would	the	

aircraft	be	flown	at	a	weight	in	excess	of	its	certificated	maximum	gross	weight	as	is	done	

when	the	airplane	is	operated	under	Part	91.		Because	of	the	more	rigorous	regulations	of	

Part	135,	operating	the	airplane	at	its	maximum	gross	weight,	whether	that	weight	is	reach	

via	a	cargo	load	of	7,500	pounds	or	less	plus	fuel	or	a	cargo	load	of	more	than	7,500	pounds	

plus	fuel,	the	operation	would	be	safer	than	what	is	done	on	a	day	to	day	basis	under	Part	

91.	

The	FAA	has	already	made	a	determination	that	such	operations	may	be	carried	out	

safely	in	its	Exemption	No.	8480E	for	Ameriflight,	dated April	11,	2012.		IFL	Group	is	

willing	to	operate	under	the	same	conditions	and	limitations	regarding	maintenance	

according	to	Part	145.125(a)(1)	and	flight	following	under	Part	121.125(a)(1)	as	set	forth	

in	the	Ameriflight	Exemption,	as	well	as	install	the	additional	equipment	set	out	in	that	

exemption	and	to	amend	its	training	program	accordingly.	

VI. Summary	for	the	Federal	Register

14	CFR	Part	119.3	

IFL	Group	seeks	an exemption	to	operate	its	aircraft	engaged	in	Part	135	all-cargo	

service	with	a	maximum	payload	of	more	than	7,500	pounds	but	not	to	exceed	the	

certificated	maximum	takeoff	weight	for	the	aircraft.

Very	truly	yours,

Richard	J.	Durden

General	Counsel