243-A Burgess Road, Greensboro NC 27409

Office (336) 665-7149 www.skyleasecargo.com

6 April 2015

VIA ELECTRONIC SUBMISSION

U.S. Department of Transportation

Docket Management System

1200 New Jersey

Avenue, SE 

Washington, DC

20590

Re: Petition of Sky Lease Cargo 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

Dear Sir or Madam:

Sky Lease Cargo (“Sky Lease I, Inc.”) hereby petitions 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 Sky 

Lease I, Inc. to operate B-747 freighter aircraft while transporting tall rigid cargo (freight

that is taller than 98 inches and will not break apart during an emergency landing)

restrained to withstand a 3.0g (“3G”) forward load.

Due to US Department of Defense needs, Sky Lease I, Inc. requests an 

exemption of 9G tiedown requirement for freight categorized as tall rigid cargo. The tall

rigid cargo 9G requirements 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 world. This not only has resulted in inability to move assets but has also caused

major economic impact on Sky Lease I, Inc.
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Sky Lease I, Inc. submits that this narrowly-tailored exemption would have no

adverse impact on safety, would provide an equivalent level of safety to 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forward restraint requirement set forth in 14 C.F.R. § 25.561 (b)(3) (which is outdated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

interest. It would enable Sky Lease I, Inc. to carry tall rigid cargo safely, efficiently, and

cost-effectively. It would benefit the public interest by making available to shippers more

commercially viable shipping options in more markets globally. And, the requested

exemption would also allow Sky Lease I, Inc. to realize the full capabilities of their

investments in the B-747 aircraft and 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.

Sky Lease I, Inc. respectfully request expedited action on this request. The

demand for transportation of tall rigid cargo is on the rise, and frangible cargo

necessary to trigger a 3G forward restraint standard is becoming much less available.

This is an urgent situation for Sky Lease I, Inc. and for the public interest, particularly

the shipping public.

Sky Lease I, Inc. submits the following in further support of this request:

I. Background And Exemption Request

Sky Lease I, Inc. is an FAR Part 121 Supplemental Air Carrier which

operates a cargo fleet comprised of B-747 and MD-11 freighter aircraft providing charter

air service worldwide. Its customer base includes the U.S. Department of Defense, other

government agencies, 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. Sky Lease I, Inc. and its experienced team of aviation professionals deliver high
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quality services to global customers, meeting and exceeding their air cargo needs.

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 the global 

supply chain because they have intermodal compatibility, which is important as 

shipments are often transported from door-to-door by multimodal transportation.

• Commodities (such as oil and gas related materials), project cargo, relief 

goods, and hi-tech equipment (such as satellite and communications materials) 

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 

perishables are often shipped in such containers.

• Emerging markets, such as the African market (where U.S. carriers are 

losing substantial business to foreign B-747 operators due to the 9G restriction), 

are particularly reliant on the use of 20-foot containers for project 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 engines to 

support many of the world's widebody passenger fleets, which use engines that 

are classified as tall rigid cargo.
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The B-747 freighter is particularly well-suited to transport tall 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 tall rigid cargo 

transportation (both discussed in Section II below), Sky Lease I, Inc. is unable to

efficiently and effectively carry tall rigid cargo because of the outdated 9G forward 

restraint requirement which Sky Lease I, Inc. is not aware has been substantiated by data 

applicable to any freighter aircraft, much less the B-747. As a result, Sky Lease I, Inc. has 

lost millions of dollars of business as shippers have been turning to Sky Lease I, Inc.' 

foreign B-747 competitors to transport tall rigid shipments. The 9G forward restraint 

requirement impairs Sky Lease I, Inc. ability to realize the full economic and efficiency 

benefits of their substantial investment in the B-747 aircraft and reduces Sky Lease I, Inc.' 

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 requirements and 

require that cargo stowage restraints handle forward inertia forces of 9G for tall 

rigid cargo:

14 C.F.R. § 25.561:

"(a) The airplane, although it may be damaged in emergency landing conditions on 

land or water, must be designed as prescribed in this section to protect each 

occupant under those conditions.
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(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, these 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 mounted 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...

(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." (Emphasis added)
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14 C.F.R. § 25.787(a):

"Each compartment for the stowage of cargo, baggage, carry-on articles, 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 be applied to compartments located below, or

forward, of all occupants in the airplane. . . .” (Emphasis added)

Although Part 25 establishes design requirements, other provisions incorporate

the design requirements into air carrier operating requirements. Thus, 14 C.F.R. § 21.5

requires Boeing to incorporate the design requirements into the manufacturer'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 Sky Lease I, Inc.' weight & balance control and loading manuals for the B-747

freighter incorporate the 9G requirement or, alternatively, permit the use of "frangible"

cargo to prevent the tall rigid cargo from shifting forward. As discussed below, those

compliance options are not practical or economically feasible.

The 9G requirement was established in the 1950s based on passenger

compartment seating design analyses. Sky Lease I, Inc. is not aware of the 9G

passenger-compartment requirement having ever been substantiated by any specific

cargo transportation analyses. Rather, the 9G passenger compartment requirement

became an anachronistic regulatory "come along" to apply to cargo transportation.
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Moreover, studies conducted by the U.S. Air Force have shown that a 3G forward 

restraint requirement would be appropriate and provide an equivalent level of safety.

Indeed, the U.S. Air Force has adopted a permanent reduction to a 3G forward restraint

for its operations as a result of its studies. In addition, a review of B-747 freighter aircraft

accidents revealed that no resulting injury or fatality in such accidents was attributable to

cargo shifting forward.

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 Sky Lease, Inc. to operate B-747

freighter aircraft while transporting tall rigid cargo restrained to withstand a 3.0g ("3G") 

forward load. The requested exemption would be used in air cargo operations within,

to/from, and wholly outside the United States. 14 CFR §11.83. Tall rigid cargo shipments

for various shippers often involve itineraries wholly outside the United States, 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 safety and would

not adversely affect the safety of upper deck occupants on B-747 freighters during

emergency landing conditions. It would benefit the public interest by allowing for more

effective utilization of the B-747 freighter aircraft and more efficient, competitive

transportation of tall rigid air cargo to meet the needs of governmental, civilian, NGO,

humanitarian, and military shippers.
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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 CFR §25.561(b)(3) is not

implicated: the stowage compartment must be designed to "the emergency landing

conditions of §25.561(b), except that the forces specified in the emergency landing

conditions need not be applied to compartments located below, or forward, of all

occupants in the airplane. . . ." 14 CFR §25.787(a). Tall rigid cargo, however, is not

covered by the exception contained in the last clause because tall rigid cargo is located

aft of the occupants on the upper deck.

Boeing's and Sky Lease I, Inc.' current weight & balance control and loading

manuals for the B-747 freighter incorporate the restraint standards of 14 CFR §

25.561(b)(3), and provide that tall rigid cargo must be restrained either to (1) a 9G

forward load by using a cumbersome and complex arrangement of supplementary

straps connected to aircraft 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 prevent 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 standard requires a

cumbersome and complex arrangement of straps connected to aircraft tie-down
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points. There are a limited number of tie-down positions on the B-747 freighter, which

makes it virtually impossible to restrain tall rigid cargo to 9G and carry other cargo.

There are 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 rigid cargo, there are usually an insufficient number of tie-downs to

restrain additional items of 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 available

to place in front of the tall rigid cargo. Non-commercial frangible "filler'' cargo is also

impractical for logistical, cost, customs, and disposal reasons. Military pallets (typically

88 inches wide, not the standard 96 inches) do not meet the width requirements for

frangible cargo when tall rigid cargo is centerline-loaded on the B-747 freighter. As a

result, tall rigid cargo, often critical to meet urgent military, commercial, and humanitarian

requirements, cannot be transported in a timely and cost-effective manner. The inability

of Sky Lease I, Inc. to carry tall rigid cargo efficiently and competitively is an urgent 

issue, as the global demand for air transportation to carry tall rigid cargo has increased 

significantly. For example, industry-standard 20-foot sea containers are widely used

around the world throughout the global supply chain to ship oil and gas related materials,

project cargo, relief goods, hi-tech equipment, garments, and perishables because they

have intermodal compatibility, offer a built-in secure storage place, and can be used as

an "office" in remote locations. Large power generators, large vehicles, and widebody
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aircraft engines regularly require long-haul air transportation as well. But the 20-foot sea

containers are 102 inches tall, and the large aircraft engines, power generators, and

large vehicles are also taller than 98 inches.

III. Granting The Requested Exemption Would Provide An Equivalent Level Of

Safety And Is In The Public Interest.

As explained below, Sky Lease I, Inc. is not aware of data substantiating 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 safety, would provide an equivalent level of safety, and would be in the public

interest.

A. Reports and Data Show that a 3G Forward Restraint Requirement Would

Have No Adverse Impact on Safety and Would Provide an Equivalent Level

of Safety.

The deficiencies with the 9G forward restraint requirement are numerous. 

First, the 9G standard was established in the 1950s, well before the B-747 aircraft

was certificated.

Second, it considered analyses of passenger seats, passenger seat

attachments, and the geometric relationship of the passenger seat to the interior of the

passenger compartment. This seat-based requirement appears to have become a 

regulatory "come along" to apply to cargo transport, without any analysis of the validity

or efficacy of applying such a seat-based requirement to the cargo compartment.

Third, since the 9G forward restraint standard predated the B-747 by more than a 

decade, it did not account for many of the B-747's exceptional characteristics. It does not 
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properly reflect the actual loads and behavior of cargo restrained 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 of

the B-747 upper deck structure.

Fourth, the 9G standard clearly did not account for the infinitesimal probability

that all of the events necessary for an occupant on the upper deck of a B-747 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

"extremely rare", with a probability of one occurrence per 4 million hours of operation.

(Cargo Aircraft and Spacecraft Forward Restraint Criteria, Technical Report ASD-TR-76-

30, at 21 (December 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 Level with Cargo and Passenger" was "extremely rare" at

0.00000025 per hours/operation. 1977 USAF Technical Report, at 38,50. And, in

November 1981, "CSAF/LET approved permanent reduction to 3G forward restraint 

[c]iting 7 years of operations (6.73M flight hours) with no cargo related accidents."

Presentation: Cargo Restraint for Fixed Wing Aircraft, 21 May 02, Aeronautical 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 400 B-747 freighters have flown

more than 20 million flight hours and 4 million flight cycles. There has been no report
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of cargo shifting forward and harming an occupant on a B-747 freighter during

emergency landing conditions (see NTSB Accident Aviation Database and 17 hullloss occurrences on B-747 freighters documented by the Aviation Safety Network,

www.aviation-safety.net; see also FAA Accident/Incident Data System). Based on a

review of the B-747 model freighter accidents, it can be concluded that any resulting

injury or fatality related to the accidents was not 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 shift at all. Since the majority

of cargo is below the tall-rigid threshold, it can be concluded that tying down to flight

loads a 1.5G (loading) has been shown to be sufficient in actual incidents and accidents

to secure cargo against forward-shifting, and this Petition for a 3G tie down therefore is

more than sufficient.

This conclusion is supported by the results of the 2008 accident of a Kalitta

aircraft in Brussels. That accident involved a B-747 freighter which suffered severe

damage, breaking into three sections after an aborted takeoff due to a bird strike.

Although the main deck floor beams in the forward cargo section were shattered in the

accident, cargo in the other sections which was restrained to 1.5G was still secured to

the aircraft, and the crew escaped uninjured. See Final Report, Ref. AAIU-2008-13

(issued July 2009), Belgium Federal Public Service Mobility and Transport, Air Accident

and Investigation Unit.

Sixth, at forward load forces between 3G (the standard requested 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
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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 runway. For any load above these, the aircraft is in a crash condition as

defined by this report." 1977 USAF Technical Report, at 21. And, according to Boeing,

during hard braking the forward flight load factors are 1.5G for the B-747-400 and 1.2G

for the B-747-8. Indeed, loads in the 9G range would not involve an "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 considers to be a

competent authority, implemented the reduced 3G forward restraint requirement, 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, which was issued after the development of the passenger-based 9G forward

restraint standard, concluded that reducing the requirement to 3G for cargo operations

would maintain safety and result in significant cost savings and simplification. In

pertinent part, the Report summarized:

"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.”
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Accordingly, Sky Lease I, Inc. submits that a 3G forward restraint requirement

would provide an equivalent level of safety to the outdated 9G standard.

B. The Exemption Would Be in the Public Interest.

Granting this exemption would be in the public interest because it would enable Sky 

Lease I, Inc. B-747 freighter aircraft to safely and efficiently carry tall rigid cargo,

including multiple 20-foot sea containers, aircraft engines, large oil/gas equipment,

and large vehicles, for humanitarian, commercial, and U.S. military shippers around

the world. It would also enable Sky Lease I, Inc. to more efficiently utilize and to realize

the full capabilities of our B-747 aircraft. Shippers need access to reasonable, safe,

and timely air transportation for their shipments of tall rigid cargo. Absent this

exemption, shippers will have fewer choices of carriers and fewer B-747 aircraft to

handle critical missions, because, as explained above, the 9G forward restraint 

requirement effectively precludes Sky Lease I, Inc. from competing for tall rigid cargo

shipments, without any improvement in safety. This, in turn, 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 detrimentally affected

as their costs are being driven up, and therefore their competitiveness is reduced. The

U.S. military and NGOs with urgent humanitarian missions involving tall rigid cargo

also encounter delays and substantially increased costs in having their vital shipments

delivered.

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 attachments
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needed to restrain to 9G would not be available for additional items. Sky Lease I, 

Inc. estimates that the need to provide frangible freight or restrain tall rigid cargo to

the 9G 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 requirement because it would allow more

pieces of tall rigid cargo to be carried on a single flight without any reduction in

safety. Adherence to the 9G standard results in more flights required to transport

the same amount of tall rigid cargo, making U.S. operators uncompetitive in the

marketplace.

Sky Lease I, Inc. is losing substantial business due to their inability to offer

competitive bids to carry tall rigid loads as a result of the 9G forward load requirement.

Many foreign competitors routinely carry 20-foot containers and other tall rigid cargo

without restraining them to withstand a forward 9G force.

Sky Lease I, Inc. estimates that it is losing millions of dollars of air cargo business 

because it is unable to effectively compete for tall rigid cargo shipments in light of the 9G 

forward restraint requirement. Sky Lease I, Inc. operates many of its flights as

unscheduled "ad hoc" charters, and therefore frangible freight is most often not available.

As the absence of the frangible cargo requires the use of 9G tie downs, Sky Lease I, Inc.

often loses charters to foreign competitors as the tie-down requirements result in the

inability to carry all of the cargo required for the charter. As such, Sky Lease I, Inc. has

noted a significant reduction in business and the loss of millions of dollars in revenue due

to the 9G requirement. Sky Lease I, Inc. additionally notes that on flights where

nonrevenue frangible freight can be used, it has done so at the airline's (not the
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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 Secretary to

strengthen the competitive position of U.S. air carriers to at least ensure equality with

foreign air carriers, including the attainment of the opportunity for U.S. air carriers 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 field without any diminution of safety by granting this exemption to provide for a

3G forward restraint requirement.

IV. Petitioner Requests Expedited Consideration And Approval.

Sky Lease I, Inc. is aware that the FAA has granted exemptions to other air carriers for 

similar relief sought by this request. Therefore, since granting this exemption is not 

precedent setting, Sky Lease I requests that publication of this petition in the Federal 

Register be waived in accordance with Section 11.87(b).

V. Conclusion.

The B-747 freighter aircraft has now flown for several million cycles and more

than 20 million hours, and Sky Lease I, Inc. is not aware of any report showing that tall

rigid cargo has moved forward and either caused frangible freight to compress or

caused injury or death to any crew member on board the aircraft. Given this substantial

safety track record, the extremely low probability of an accident in the 3G to N/S range,

the impracticality and economic infeasibility of securing tall rigid cargo to a 9G forward

restraint, and the USAF's conclusion that a 3G forward restraint requirement would
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provide an equivalent level of safety and would not adversely affect safety, Sky Lease I, 

Inc. requests that the FAA grant the exemption requested herein expeditiously.

SUMMARY

Sky Lease I, Inc. Petition for Exemption from 14 CFR §§ 91.9(a), 91.1025(a),

121.135(a)(4), 121.135(b)(21), 121.141

Sky Lease I, Inc. petitions then Administrator for an 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 transporting tall rigid cargo

restrained to withstand a 3.0g forward load.

Should you have any questions or need additional information, please contact me at 

336-668-7505.

Sincerely,

Herman F. Gillis, III

Director of Operations

hgillis@skylease.aero