TO: U.S. Department of Transportation Docket Management System 400 7th Street SW Room PL -400 Wa shington, DC 20591 - 0001 May 01, 2012 **PETITION FOR EXEMPTION FROM FEDERA L A**  **VIA TION REGULA** 

**TION 14 CFR 91.315 TO PERMIT F**  **LIGHT TRA INING FOR COMPENSA**  **TI ON OR HIRE**  **IN A LIMITED CA** 

**TEGORY B -** **25 AIR** **CRA FT** 

**PETITION SUMMA RY**  AERO TRADER, a California Corporation, requests an exemption from Federal Aviation Regulation 14 CFR 91.315, for the purpose of flight training in North Am e rican B -25 aircraft. The aircraft is certificated in the LIMITED category and 14 CFR 91.315 states “ No person may o perate a lim ited category civil aircraft carrying **persons** or property for **compensation** or **hire** .” AERO TRADER would like to provide initial an d recurrent flight training, for com pensation or hire, in this aircraft to qualified applicants. **REA SON 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 Am erican 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 mu st 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 pil ots type - rated in a “two pilot” large aircraft mu st accomplish a 14 CFR 61.58 recurrency practical flight test at least every 24 mo nths 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 2.2 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 Am erican B -25 N9856C (S/N 43 -28204). AERO TRADER has been operating th is aircraft since 1981. This aircraft carries a LIMITED airworthiness certificate and is ma intained under an FAA Approved Aircraft Inspection Program by

A ERO TRADER personnel. AERO TRADER is an experienced warbird and B -25 ma intenance and restoration facil ity and the parent com pany, S&R Aviation Services, Inc., holds the Lim ited type certificate for the B -25 aircraft (AL-2). All flight training will be accomplished by A ERO 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, Austri a 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 o n 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 sc hools providing primary

o r 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.3

**DESCRIPTION OF THE RELIEF SOUGHT** A ERO 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 com petition 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 TRA DER**  Dated: May 01, 2012 By :

________________________________________________ Carl W . Scholl, President

**AERO TRA DER**  **7000 Merrill A**

**venue Box 19 Hangar A** **- 497 Chino A** **irport Chino, California 91710**