TO: U.S. Department of Transportation

 Docket Management System

 400 7th Street SW

 Room PL-400

 Washington, DC 20591-0001

May 01, 2012

PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATION

14 CFR 91.315 TO PERMIT FLIGHT TRAINING FOR COMPENSATION OR HIRE 

IN A LIMITED CATEGORY B-25 AIRCRAFT

PETITION SUMMARY

AERO TRADER, a California Corporation, requests an exemption from Federal Aviation 

Regulation 14 CFR 91.315, for the purpose of flight training in North American B-25 aircraft. The aircraft 

is certificated in the LIMITED category and 14 CFR 91.315 states “No person may operate a limited 

category civil aircraft carrying persons or property for compensation or hire.” AERO TRADER would like 

to provide initial and recurrent flight training, for compensation or hire, in this aircraft to qualified 

applicants. 

REASON FOR PETITION

AERO TRADER is petitioning for an exemption from 14 CFR 91.315 in order to be able to offer 

initial and recurrent flight training in B-25 aircraft, and charge reasonable compensation for this service. 

North American B-25 aircraft are certificated in the Limited category and the Pilot In Command (PIC) is 

required to be type rated (NB-25) in the aircraft in accordance with 14 CFR 61.31 (a)(1). An applicant for 

a type rating must receive flight instruction and an endorsement from an authorized instructor in 

accordance with 14 CFR 61.63 (d)(2), prior to application and then must accomplish a practical test in the 

aircraft. In addition, all pilots type-rated in a “two pilot” large aircraft must accomplish a 14 CFR 61.58 

recurrency practical flight test at least every 24 months for the type rating to remain in effect. The B-25 is 

both a “Large” aircraft and requires two pilots in accordance with the TCDS AL-2 Rev 2. 
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 Initial and recurrent training is the backbone of safe flying in large aircraft. In addition, expertise in 

training in vintage warbird and radial engine powered aircraft is not commonly available. AERO TRADER 

is able to provide this flight training service. An exemption from 14 CFR 91.315 is necessary to recover 

the expense of flight training operations. Training flights will be conducted utilizing North American B-25 

N9856C (S/N 43-28204). AERO TRADER has been operating this aircraft since 1981. This aircraft carries 

a LIMITED airworthiness certificate and is maintained under an FAA Approved Aircraft Inspection 

Program by AERO TRADER personnel. AERO TRADER is an experienced warbird and B-25 

maintenance and restoration facility and the parent company, S&R Aviation Services, Inc., holds the 

Limited type certificate for the B-25 aircraft (AL-2). All flight training will be accomplished by AERO 

TRADER personnel, holding appropriate Category, Class and Type ratings and Flight Instructor 

certificates.

The flight training operations contemplated under the proposed exemption are important for the 

continued safe operation of B-25 aircraft in the United States and also worldwide. Foreign operators of

B-25 aircraft from Holland, Austria and France have made requests, in the past, for initial and recurrent

B-25 aircraft flight training.

Safe operation of North American B-25 aircraft is paramount for the continued preservation of 

these historic flying aircraft and the safety of persons on board and on the ground. Initial and recurrent 

training is essential to this safe operation and thus it is in the public interest to grant this Petition for 

Exemption. Flight training operations in B-25 aircraft do not pose competition to local flight schools 

providing primary or advanced flight training in Standard category aircraft. Pilots who request B-25 

training are usually well advanced in pilot ratings and arrive with Commercial or ATP certificates. Local 

flight schools cannot offer B-25 training. 

 During its discovery research, AERO TRADER has determined that this petition for exemption would 

not set a precedent as several other very similar exemptions – No. 8593; No. 10057; and No. 10191 -

currently exist.
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DESCRIPTION OF THE RELIEF SOUGHT

AERO TRADER has illustrated the public interest that supports the grant of this Petition for 

exemption from 14 CFR 91.315. Quality flight training will only enhance the safety of B-25 flight 

operations. The proposed operations will not present an element of competition to local flight schools.

Based upon the foregoing, AERO TRADER requests that FAA issue an exemption from 14 CFR 

91.315, to permit flight training for compensation or hire, in a Limited Category B-25 aircraft.

AERO TRADER 

Dated: May 01, 2012 By:________________________________________________

Carl W. Scholl, President

AERO TRADER

7000 Merrill Avenue Box 19

Hangar A-497 Chino Airport

Chino, California 91710