National Airlines Citadel II Building 5955 T. G. Lee Boulevard, Ste. 500 Orlando, FL 32822 T 800 451 3174 F 407 313 2255 www.NationalAirlines.com November 19, 2014

By Electronic Submission

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Petition of National Air Cargo Group, Inc. for an Exemption from 14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), and 121.141 (Docket FAA-2014-____)

Dear Sir or Madam: National Air Cargo Group, Inc. (“National Airlines”) hereby pet itions for an exemption from 14 C.F.R. §§91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b) (21), and 121.141 to allow National Airlines to operate B-747 freighter aircraft while tra nsporting tall rigid cargo (freight that is taller than 98 inches and will not break apart during an eme rgency landing) restrained to withstand a 3.0g (“3G”) forward load. Due to US Department of Defense needs, National Airlines would like to petition the exemption of 9G tiedown for freight categorized as tall rigid c argo. The tall rigid cargo 9G requirement has caused a major impact in the ability to move US Department of Defense assets

back to the United States from various locations around the wor ld. This not only has resulted in inability to move assets but has also caused major economic imp acts on National Airlines and its industry counterparts.Petition for Exemption Page 2

National Airlines submit that this narrowly-tailored exemption would have no adverse impact on safety, would provide an equivalent level of safety t o the 9.0g ("9G") forward restraint requirement set forth in 14 C.F.R. § 25

. 561 (b)(3) (which is outdated and unsubstantiated by freighter aircraft-specific data), and would be in the public i nterest. It would enable National Airlines to carry tall rigid cargo safely, efficiently, and cos t-effectively. It would benefit the public interest by making available to shippers more commercially viab le shipping options in more markets globally

. And, the requested exemption would also allow National Airlines to realize the full capabilities of their investments in the B-747 aircraft an d stem the loss of millions of dollars of tall rigid cargo business to foreign operators who regularly transport tall rigid cargo without meeting the 9G forward restraint requirement. National Airlines respectfully request expedited action on this request. The demand for transportation of tall rigid cargo is on the rise, and frangibl e cargo necessary to trigger a 3G forward restraint standard is becoming much less available. Thi s is an urgent situation for National Airlines and for the public interest, particularly the shipping public. National Airlines submits the following in further support of t his request: I. Background And Exemption Request

National Airlines: National Airlines is a Part 121 certificated U.S. air carrier which operates a cargo fleet compris ed exclusively of B-747 freighter aircraft. National Airlines provides charter air service worldwide utilizing a fleet of 2 B -747 freighters. Its customer base includes the U.S. Department of Def ense, other government agenc ies, and multiple commercial entities needing to move unique cargo to challenging locations around the world, helping to keep the U.S. economy on the move. National Airlines and its ex perienced team of aviation professionals deliver high quality services to global customers , meeting and exceeding their air cargo needs. National Airlines also operates a fleet of 2 B-757 passenger aircraft and is Part 121 certificated to fly domestic and flag passengers operations

.Petition for Exemption Page 3

Tall Rigid Cargo: There is substantial demand for transporting tall rigid cargo by air. There are two principal categories of tall rigid cargo: 1. Industry-standard 20-foot containers (ISO 1CC) which are 102 inches tall.

 These containers are widely used around the world throughout t he global supply chain because they have intermodal compatibility, which is impo rtant as shipments are often transported from door-to-door by multimodal transport ation.

 Commodities (such as oil and gas related materials), project c argo, relief goods, and hi-tech equipment (such as satellite and communications materia ls) are often shipped in 20-foot sea containers to remote locations where the container is also used as a field office or secure storage area. Garments and per ishables are often shipped in such containers.

 Emerging markets, such as the African market (where U.S. carri ers are losing substantial business to foreign B-747 operators due to the 9G r estriction), are particularly reliant on the use of 20-foot containers for proje ct and oil/gas cargo. Tall rigid cargo shipments are often carried on part charter flights to offline destinations. 2. Other tall items, such as aircraft engines, generators, and large vehicles, which are taller

than 98 inches.

 For example, B-747 freighters are needed to carry aircraft eng ines to support many of the world's widebody passenger fleets, which use engines tha t are classified as tall rigid cargo. The B-747 freighter is particularly well-suited to transport ta ll rigid cargo efficiently and cost-effectively, and has carried such cargo safely for decades . However, with the severe decline in "frangible" cargo and ever increasing demand for tal l rigid cargo transportation (both discussed in Section II below), National Airlines unable to eff iciently and effectively carry tall rigid cargo because of the outdated 9G forward restraint requir ement which National Airlines isPetition for Exemption Page 4

not aware has been substantiated by data applicable to any frei ghter aircraft, much less the B747. As a result, National Airlines has lost millions of dollar s of business as shippers have been turning to National Airlines' foreign B-747 competitors to tran sport tall rigid shipments. The 9G forward restraint requirement impairs National Airlines ability to realize the full economic and efficiency benefits of their substantial investment in the B-74 7 aircraft and reduces National Airlines' global competitive effectiveness. It also results in the availability of fewer service and pricing options for tall rigid cargo shippers. The 9G Requirement: The 9G forward restraint requirement stems from the following FAR provisions: 14 C.F.R. § 25.561 and§ 25.787 establish aircraft design requir ements and require that cargo stowage restraints handle forward inertia forces of 9G fo r tall rigid cargo:

14 C.F.R. § 25.561: "(a) The airplane, although it may be damaged in emergency lan ding conditions on land or water, must be designed as prescribed in this section to pro tect each occupant under those conditions. (b) The structure must be designed to give each occupant every reasonable chance of escaping serious injury in a minor crash landing when-

. . . (3) The occupant experiences the following ultimate inertia forces acting separately relative to the surrounding structure:

. . . (ii) Forward, 9.0g

. . . . (c) For equipment, cargo in the passenger compartments and any other large masses, the following apply: (1) Except as provided in paragraph (c)(2) of this section, th ese items must be positioned so that if they break loose they will be unlikely to : (i) Cause direct injury to occupants; (ii) Penetrate fuel tanks or lines or cause fire or explosion hazard by damage to adjacent systems; or (iii) Nullify any of the escape facilities provided for use after an emergency landing. (2) When such positioning is not practical (e.g. fuselage moun ted engines or auxiliary power units) each such item of mass shall be restrained under all loads up to those specified in paragraph (b)(3) of this section. . . .Petition for Exemption Page 5

(d) Seats and items of mass (and their supporting structure) must not deform under any loads up to those specified in paragraph (b)(3) of this section in any manner that would impede subsequent rapid evacuation of occupants." (E mphasis added) 14 C.F.R. § 25.787(a): "Each compartment for the stowage of cargo, baggage, carry-on a rticles, and equipment (such as life rafts), and any other stowage compartment must be designed for its placarded maximum weight of contents and for the critical load distribution at the appropriate maximum load factors corresponding to the specified flight and ground load conditions, and to the emergency landing conditions of § 25.561(b) , except that the forces specified in the emergency landing conditions need not b e applied to compartments located below, or forward, of all occupants in the airplane. . . .” (Emphasis added) Although Part 25 establishes design requirements, other provisi ons incorporate the design requirements into air carrier operating requirements. Th us, 14 C.F.R. § 21.5 requires Boeing to incorporate the design requirements into the manufact urer's Aircraft Flight Manual ("AFM"), and 14 C.F.R. §§ 91.9, 91.1025(a), 121.135(a)(4), 121. 135(b)(21), and 121.141 require U.S. air carriers to comply with the AFM. Boeing's and National Airlines' weight & balance control and loading manuals for the B-747 freighter inc orporate the 9G requirement or, alternatively, permit the use of "frangible" cargo3 to prevent the tall rigid cargo from shifting forward. As discussed below, those compliance options are not p ractical or economically

feasible. The 9G requirement was established in the 1950s based on passen ger compartment seating design analyses. National Airlines is not aware of the 9G passenger-compartment requirement having ever been subst antiated by any specific carg o transportation analyses. Rather, the 9G passenger compartment requirement became an anac hronistic regulatory "come along" to apply to cargo transportation. Moreover, studies conducted by the U.S. Air Force have shown th at a 3G forward restraint requirement would be appropriate and provide an equiv alent level of safety. Indeed, the U.S. Air Force has adopted a permanent reduction to a 3G forwar d restraint for its operations as a result of its studies. In addition, a review of B-747 freight er aircraft accidents revealed that no resulting injury or fatality in such accidents was attributable to cargo shifting forward.Petition for Exemption Page 6

This Petition seeks an exemption from 14 C.F.R. §§91.9, 91.1025 (a), 121.135(a)(4), 121.135(b)(21), and 121.141 to allow Part 121 operators of B-74 7 freighter aircraft to operate B747 freighter aircraft while transporting tall rigid cargo rest rained to withstand a 3.0g ("3G") forward load. The requested exemption would be used in air carg o operations within, to/from, and wholly outside the United States. 14 C.F.R. §11 .83. Tall r igid cargo shipments for various shippers often involve itineraries wholly outside the United St ates, e.g., from Asia to Africa; Africa to Europe; Europe to Asia; Oceania to Africa, etc., and thus any limitation on the requested exemption as to its geographic scope would eliminate the exemption's real-world utility. The requested exemption would maintain an equivalent level of s afety and would not adversely affect the safety of upper deck occupants on B-747 fr eighters during emergency landing conditions. It would benefit the public interest by all owing for more effective utilization of the B-747 freighter aircraft and more efficient, competitive tr ansportation of tall rigid air cargo to meet the needs of governmental, civilian, NGO, humanitarian, an d military shippers.

II. The Issue The bottom of the upper deck floor beams on the B-747 freighter is at a height of 98.1 inches. In the highly unlikely event of a forward cargo shift, cargo that is 98 inches tall or lower will not strike the upper deck structure and occupant areas on the B-747 freighter, and therefore the 9G force standard set forth in 14 C.F.R. §25.561(b)(3) is n ot implicated: the stowage compartment must be designed to "the emergency landing conditio ns of §25.561(b), except that the forces specified in the emergency landing conditions need n ot be applied to compartments located below, or forward, of all occupants in the airplane. . . ." 14 C.F.R. §25.787(a). Tall rigid cargo, however, is not cover ed by the exception contained in th e last clause because tall rigid cargo is located aft of the occupants on the upper deck. Boeing's and National Airlines' current weight & balance contro l and loading manuals for the B-747 freighter incorporate the restraint standards of 14 C .F.R. § 25.561(b)(3), and providePetition for Exemption Page 7

that tall rigid cargo must be restrained either to (1) a 9G for ward load by using a cumbersome and complex arrangement of supplementary straps connected to ai rcraft tie-down points, or (2) a 1.5G (B-747-400) forward load combined with a specific volume of frangible cargo placed in front of the tall rigid cargo, in either case in order to preve nt the tall rigid cargo from shifting forward and impacting the upper deck and occupant areas. These two current methods for transporting tall rigid cargo on the B-747 freighter are simply not economically feasible or practical. First, restraining tall rigid cargo to a 9G forward load standa rd requires a cumbersome and complex arrangement of straps connected to aircraft tie-dow n points. There are a limited number of tie-down positions on the B-747 freighter, which make s it virtually impossible to restrain tall rigid cargo to 9G and carry other cargo. There ar e often an inadequate number of tie-downs on a B-747 to restrain heavy tall rigid cargo to a 9G forward load requirement; and even when it is possible to restrain a single item of tall rigi d cargo, there are usually an

insufficient number of tie-downs to restrain additional items o f tall rigid or other cargo. As a result, the flight is not efficient or cost-competitive for the shipper. Second, it is extremely difficult, impractical, and uneconomic to use frangible cargo as a buffer. The changing nature of air cargo, customer demands, and aircraft routings today is such that there is rarely a sufficient volume of frangible cargo ava ilable to place in front of the tall rigid cargo. Non-commercial frangible "filler'' cargo is also impract ical for logistical, cost, customs, and disposal reasons. Military pallets (typically 88 inches wid e, not the standard 96 inches) do not meet the width requirements for frangible cargo when tall r igid cargo is centerline-loaded on the B-747 freighter. As a result, tall rigid cargo, often criti cal to meet urgent military, commercial, and humanitarian requirements, cannot be transported in a timel y and cost-effective manner. The inability of National Airlines to carry tall rigid cargo ef ficiently and competitively is an urgent issue, as the global demand for air transportation to carry tal l rigid cargo has increased significantly. For example, industry-standard 20-foot sea conta iners are widely used around thePetition for Exemption Page 8

world throughout the global supply chain to ship oil and gas re lated materials, project cargo, relief goods, hi-tech equipment, garments, and perishables beca use they have intermodal compatibility, offer a built-in secure storage place, and can b e used as an "office" in remote locations. Large power generators, large vehicles, and widebody aircraft engines regularly require long-haul air transportation as well. But the 20-foot s ea containers are 102 inches tall, and the large aircraft engines, power generators, and large veh icles are also taller than 98

inches. III. Granting The Requested Exemption Would Provide An Equivale nt Level Of Safety And Is In The Public Interest. As explained below, National Airlines not aware of data substan tiating the application of the 9G requirement to freighter aircraft. However, more recent studies that were not available when the 9G forward restraint requirement was developed in the 1950s demonstrate that a 3G forward restraint standard would have no adverse impact on safe ty, would provide an equivalent level of safety, and would be in the public interest.

A. Reports and Data Show that a 3G Forward Restraint Requiremen t Would Have No Adverse Impact on Safety and Would Provide an Equivalent Lev el of Safety. The deficiencies with the 9G forward restraint requirement are numerous. First, the 9G standard was established in the 1950s, well befor e the B-747 aircraft was

certificated. Second, it considered analyses of passenger seats, passenger se at attachments, and the geometric relationship of the passenger seat to the interio r of the passenger compartment. This seat-based requirement appears to have become a regulatory "come along" to apply to cargo transport, without any analy sis of the validity or effica cy of applying such a seat-based requirement to the cargo compartment.Petition for Exemption Page 9

Third, since the 9G forward restraint standard predated the B-7 47 by more than a decade, it did not account for many of the B-747's exceptional characteristics. It does not properly reflect the actual loads and behavior of cargo restrai ned by the cargo restraint system, straps, and nets on a B-747. Nor does it take into account the spatial separation of B-747 upper deck occupants and the tall rigid cargo, the capability of the crown barrier net to restrain tall rigid cargo, or the crashworthiness and energy absorbing capability o f the B-747 upper deck

structure. Fourth, the 9G standard clearly did not account for the infinit esimal probability that all of the events necessary for an occupant on the upper deck of a B-7 47 freighter to be harmed by tall rigid cargo in an emergency landing would occur. U.S. Air Force studies concluded that a crash event at higher than 3G with cargo and passengers is "ext remely rare", with a probability of one occurrence per 4 million hours of operation. Cargo Aircr aft and Spacecraft Forward Restraint Criteria, Technical Report ASD-TR-76-30, at 21 (Decem ber 1977) ("1977 USAF Technical Report"). Put another way, combining major and minor accidents for the period 1962 to July 1976, the probability of a crash at the "3G to N/S Leve l with Cargo and Passenger" was "extremely rare" at 0.00000025 per hours/operation. 1977 USAF T echnical Report, at 38, 50. And, in November 1981, "CSAF/LET approved permanent reduction t o 3G forward restraint [c]iting 7 years of operations (6.73M flight hours) with no car go related accidents." Presentation: Cargo Restraint for Fixed Wing Aircraft, 21 May 02, Aeronautica l Systems Center, USAF. According to the same USAF presentation, "In concert with 2G up and 1.5G aft & laterally, 3G forward restraint has proven adequate and cost effective for 30 years of USAF cargo operations involving over 29M flight hours." Fifth, in commercial operations, more than 420 B-747 freighters have flown more than 20 million flight hours and 4 million flight cycles. There has bee n no report of cargo shifting forward and harming an occupant on a B-747 freighter during emergency l anding conditions (see NTSB

Accident Aviation Database and 17 hull-loss occurrences on B-74 7 freighters documented byPetition for Exemption Page 10

the Aviation Safety Network, www.aviation-safety.net; see also FAA Accident/Incident Data System). Based on a review o f the B-747 model freighter acciden ts, it can be concluded that any resulting injury or fatality related to the accidents was n ot attributable to cargo shifting forward. In fact, if a cargo shift was involved in any reported accident, it only involved cargo shifting aft, with no reported accidents involving a forward sh ift at all. Since the majority of cargo is below the tall-rigid threshold, it can be concluded that tyi ng down to flight loads a 1.5G (loading) has been shown to be sufficient in actual incidents a nd accidents to secure cargo against forward-shifting, and this Petition for a 3G tie down t herefore is more than sufficient. This conclusion is supported by the results of the 2008 acciden t of a Kalitta aircraft in Brussels. That accident involved a B-747 freighter which suffer ed severe damage, breaking into

three sections after an aborted takeoff due to a bird strike. A lthough the main deck floor beams in the forward cargo section were shattered in the accident, ca rgo in the other sections which was restrained to 1.5G was still secured to the aircraft, and t he crew escaped uninjured. See Final Report, Ref. AAIU-2008-13 (issued July 2009), Belgium Fed eral Public Service Mobility and Transport, Air Accident and Investigation Unit. Sixth, at forward load forces between 3G (the standard requeste d in this Petition and the standard adopted by the USAF) and 9G (the current standard), it is highly likely that the B-747 would not stay intact. At such high G-force loads, whether the tall rigid cargo was shifting forward would be the least of the occupants' and crew's worries because the aircraft would likely not remain intact. As a 1977 USAF Technical Report pointed out: "The maximum landing loads that the C-130, C-141, and C-5 can generate are 0.94, 1.05, and 1.20G, respectively. This is assuming full reverse thrust, full braking, and a loose dirt ru nway. For any load above these, the aircraft is in a crash condition as defined by this report." 19 77 USAF Technical Report, at 21. And, according to Boeing, during hard braking the forward fligh t load factors are 1.5G for the B747-400 and 1.2G for the B-747-8. Indeed, loads in the 9G range would not involve anPetition for Exemption Page 11

"emergency landing condition", but rather a crash. The aircraft and the attachment points would

fail well before 9G. Seventh, the U.S. Department of Defense, which the FAA consider s to be a competent authority, implemented the reduced 3G forward restraint require ment, and there has been no report of an accident where occupants have been harmed by cargo shifting forward during emergency landing conditions. The 1977 USAF Technical Report, w hich was issued after the development of the passenger-based 9G forward restraint standar d, concluded that reducing the requirement to 3G for cargo operations would maintain safet y and result in significant cost savings and simplification. In pertinent part, the Report summa rized:

"The civilian fleet can also use the data in determining what design criteria to utilize. For example, either a 3G positive locking rail system or a 3G net in conjunction with current 11⁄2G rail system would provide an adequate system rather than the 9G system in use today. " 1977 USAF Technical Report, at 50-51.”

Accordingly, National Airlines submits that a 3G forward restra int requirement would provide an equivalent level of safety to the outdated 9G standa rd.

B. The Exemption Would Be in the Public Interest. Granting this exemption would be in the public interest because it would enable U.S. operators of B-7 4 7 freighter aircraft to safely and efficient ly carry tall rigid cargo, including multiple 20-foot sea containers, aircraft engines, large oil/ga s equipment, and large vehicles, for humanitarian, commercial, and U.S. military shippers around the world. It would also enable B747 operators to more efficiently utilize and to realize the fu ll capabilities of their B-747 aircraft. Shippers need access to reasonable, safe, and timely air transp ortation for their shipments of tall rigid cargo. Absent this exemption, shippers will have few er choices of carriers and fewer B-Petition for Exemption Page 12

747 aircraft to handle critical missions, because, as explained above, the 9G forward restraint requirement effectively precludes U.S. B-747 freighter operator s from competing for tall rigid cargo shipments, without any improvement in safety. This, in tu rn, leads to delays for the delivery of critical cargo and/or substantially increases costs for shippers to get their cargo delivered. For example, U.S. exporters and importers are detrim entally affected as their costs are being driven up, and therefore their competitiveness is red uced. The U.S. military and NGOs with urgent humanitarian missions involving tall rigid car go also encounter delays and substantially increased costs in having their vital shipments d elivered. Even in cases where a single item of tall rigid cargo could be carried, other tall rigid items could not be transported because the requisite tie-down a ttachments needed to restrain to

9G would not be available for additional items. National Airlin es estimates that the need to provide frangible freight or restrain tall rigid cargo to the 9 G standard reduces the cargo-carrying capability by a minimum of 30% and, in some cases, up to 50% of the allowable volume and weight allowed by the Boeing 747 weight and balance loading and control manual. The public interest would be much better served with a 3G restraint requir ement because it would allow more pieces of tall rigid cargo to be carried on a single fligh t without any reduction in safety. Adherence to the 9G standard results in more flights required t o transport the same amount of tall rigid cargo, making U.S. operators uncompetitive in the ma rketplace. National Airlines is losing substantial business due to their i nability to offer competitive bids to carry tall rigid loads as a result of the 9G forward lo ad requirement. Many foreign competitors routinely carry 20-foot containers and other tall r igid cargo without restraining them

to withstand a forward 9G force. National Airlines estimates that it is losing millions of dolla rs of air cargo business because it is unable to effectively compete for tall rigid carg o shipments in light of the 9G forward restraint requirement. National Airlines operates many of its flights as unscheduled "ad hoc" charters, and therefore frangible freight is most often no t available. As the absence of thePetition for Exemption Page 13

frangible cargo requires the use of 9G tie downs, National Airl ines often loses charters to foreign competitors as the tie-down requirements result in the inabilit y to carry all of the cargo required for the charter. As such, National Airlines has noted a signifi cant reduction in business and the loss of millions of dollars in revenue due to the 9G requiremen t. National Airlines additionally notes that on flights where nonrevenue frangible freight can be used, it has done so at the airline's (not the shipper's) expense, resulting in additional cost to the airline for the buildup and disposal of this cargo. This has also caused substantial losses due to these additional unrecouped costs. In the context of economic regulation, Congress directed the Se cretary to strengthen the competitive position of U.S. air carriers to at least ensure eq uality with foreign air carriers, including the attainment of the opportunity for U.S. air carrie rs to maintain and increase their profitability in foreign air transportation. 49 U.S.C. §§40101 (a)(15) and (e)(1). We believe that the FAA can act in the public interest and level the playing fi eld without any diminution of safety by granting this exemption to provide for a 3G forward restrain t requirement. IV. Petitioner Requests Expedited Consideration And Approval. National Airlines urges the FAA to expeditiously review and app rove this Petition. U.S. B-747 operators are being advers ely impacted by the application of the 9G requirement, as are shippers. Application of a 3G requirement would not adversely a ffect safety and would provide an equivalent level of safety as s upported by cargo-compartment based studies. If the FAA determines that notice and comment is required, National Airlin es requests a shortened publication and comment period and a waiver from the requiremen t that petitions be submitted 120 days before the proposed effective date of the exemption. D elay would continue to adversely affect National Airlines and its ability to fulfill t he tall rigid cargo requirements of its humanitarian, commercial, and military customers. At the same t ime, the delay would adversely affect the public interest in that shippers would continue to b e denied safe, timely, and costcompetitive service from U.S. all-cargo B-747 operators for fly ing their tall rigid cargo.Petition for Exemption Page 14

V. Conclusion. The B-747 freighter aircraft has now flown for several million cycles and more than 20 million hours, and National Airlines is not aware of any report showing that tall rigid cargo has moved forward and either caused frangible freight to compress o r caused injury or death to any

crew member on board the aircraft. Given this substantial safet y track record, the extremely low probability of an accident in the 3G to N/S range, the impracti cality and economic infeasibility of securing tall rigid cargo to a 9G forward restraint, and the US AF's conclusion that a 3G forward restraint requirement would pr ovide an equivalent level of safe ty and would not adversely affect safety, National Airlines requests that the FAA grant the exemp tion requested herein expeditiously. VI. National Airlines’ Responses to the Questions Posed in Ms. Suzanne Masterson’s Letter on August 6, 2014 on Similar Docket FAA-2014-0184.

 National Airlines anticipates operating two flights per day (a pproximately 60 flights per month) for the duration of the US Department of Defense drawdow n from Afghanistan (exact timeframe unknown).

 National Airlines requests exemption allowing for restraint of cargo for 3.0g (“3G”) and no requirement for the use of frangible cargo.

 Granting of this petition would allow National Airlines and it s industry counterparts to carry cargo under contract of the US Department of Defense to r emove cargo from Afghanistan to support US National interests.

 This mission would require the transport of mostly tall rigid cargo.

 Additionally, this exemption would allow for more cargo to be carried on fewer flights, providing for use of fewer resources.Petition for Exemption Page 15

We appreciate your consideration in this matter. If you require additional information, please do not hesitate to contact me.

Sincerely,

Joseph R. Batten Director of Operations

Contact Information National Air Cargo Group, Inc. dba National Airlines 5955 T.G. Lee Blvd., Suite 500 Orlando, FL 32822

Phone: 407-283-6272 Fax: 407-313-2255Petition for Exemption ATTACHMENT 1

FEDERAL REGISTER SUMMARY In accordance with §11.81(f), a summary of this Request for Add ition to Petition for Exemption for publication in the Federal Register is as follows :

Docket No.: FAA-2014-____

Petitioner: National Air Cargo Group, Inc.

Section of the FAR Affected:

14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), 121.141 Description of Relief Sought: Petitioner seek to be added to the exemption from the requirements of 14 C.F.R. §§ 91.9(a), 91.1025(a), 121.135(a)(4), 121.135(b)(21), and 121.141 to allow the operation of B-747 freighter aircraft while trans porting tall rigid cargo restrained to withstand a 3.0g forward load.