P.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG October 4 , 2010

DOT Docket Management System 400 7th Street, SW, Room PL 401 Washington, DC 20591

Dear Sirs:

Reference: Small “N” Numbers, FAA

- 2000

- 8177 , Exemption No. 5019

EAA (Experimental Aircraft Association) is the world leader in recreational aviation. With an international membership of 170,000 people in more than 112 nations, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to th e continued growth of aviation, the preservation of its history and a commitment to aviation’s future. EAA programs, activities and events are known throughout the world for Preserving the heritage of aviation, Promoting access to flight, Protecting the r ight to fly, Preparing the future of aviation, and of our

Passion for aviation safety and education.

This petition for exemption request is being submitted for two reasons:

1. To renew the current exemption , No. 5019, for another three

- year term. The condi tions and reasons regarding public interest and safety, presented in the original petition dated October 28, 1988, and the most recent renewal request dated August 16, 2000, November 22, 2002, October 29, 2004 and August 15, 2006 remain unchanged. EAA und erstands this renewal request is being submitted one year early and if granted, the new three

- year termination date would be February 28, 2014.

2. EAA s eek s to add §45.22(b)(2) to this exemption.



### Several vintage military aircraft use a numbering system on the vertical tail of the aircraft to identify either the aircraft designation and/or the unit identification number. Examples , as shown in the below pictures, include the Navy N3N

- 3

, the Navy N2S

- 5 , the Navy N3N

, and several other aircraft.

a. The existing exemption, No. 5019, allows operators/owners to restore these vintage aircraft to their original authentic marking configurations by which each aircraft was know during their military days.

b. This effort to restore aircraft to their original marking configurations is being hampered by §45.22(b)(2) “It displays no other mark that begins with the letter “N” anywhere on the aircraft .”

c. EAA is seeking to have Exemption No. 5019 modified to include an exemption to §45.22(b)(2) . This addition would allow aircraft to be restored to their original military marking configuration, including the “N” aircraft designation or unit

identification number on the vertical tail surfaces.

d. This request to modify th e existing Exemption is in the same public interest and safety as presented by this association in the original petition dated October 28,P.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG 1988 through the most recent renewal request dated August 16, 2006, and in paragraph 1, above.

e. Navy N3N

- 3. Examp le of a “N” type of authentic marking configuration.

f. Navy N2S

- 5. Example of an “N” type of authentic marking configuration.P.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG g. Navy N3N. Example of an “N” type of authentic marking configuration.

h. The other primary concern is that for several years the U.S. Navy has only been
marking their aircraft with the word “Navy.” This is a singular word that begins
with the letter “N” that is marked on the fuselage of the aircraft.

i. UH

- 1N Huey Helicopte r. Example of an “N” type of authentic marking
configuration.P.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG ii. T H

- 47 Helicopter. Example of an “N” type of authentic marking
configuration.

iii. T

- 28 airplane . Example of an “N” type of authentic marking
configuration.P.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG iv. 

### T

- 45 airplane. Example of an “N” type of authentic marking configuration

v. T

- 44 King Air airplane. 

### Example of an “N” type of authentic marking configurationP.O. BOX 3086 OSHKOS H, WI 54903

- 3086 • T el 920.426. 6522 • F ax 920.426.6560 • WWW.EAA.ORG As shown above there are several examples that clearly show authentic aircraft markings that begin with the letter “N”. Therefore, EAA requests the following two actions be taken involving FAA Exemption No. 5019, DOT Docket No. FAA

- 2000

- 8177:

1. This exempt ion be changed to allow the use of unique aircraft markings that begin with the letter “N” if it is applicable to that particular aircrafts’ military heritage (Exemption from §45.22(b)(2)).

2. This exemption be renewed for an additional three years, with a n ew expiration date of February 28, 2014.

This exemption continues to be in the public interest and safety.

For questions concerning this renewal request, contact Bill Fischer, EAA Executive Director

Warbirds of America 920

- 426

- 4874, bfischer@eaa.org o r the undersigned at 920

- 426

- 6522, rhansen@eaa.org

Sincerely,

Randy Hansen

EAA Government Relations Director