TO: 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE West 

Building Ground Floor Room W12-140 

Washington, DC 20590 

PETITION FOR EXEMPTION FROM FEDERAL AVIATION REGULATIONS SECTIONS 

91.315, 91.319, 119.5(g) AND 119.21(a) FOR THE OPERATION OF TEAM P3 

HISTORIC MILITARY AIRCRAFT 

PETITIONERS: 

Team P3 

5115 N Dysart Rd 

STE 202-172 

Litchfield Park, AZ 85340 
Petition Summary 

Team P3 requests an exemption from the Federal Aviation Regulations 91.315, 91.319, 

119.5(g) 119.21(a), for the operation of certain Pi latus P3 aircraft (see Exhibit A) which 

are located at Glendale Municipal Airport in Glendale, Arizona. Team P3 would like to 

provide flight experiences to enthusiast of these historic aircraft. The aircraft is certified 

in the Experimental Exhibition category. 

Reason for Petition 

Team P3 is petitioning for an exemption from Federal Aviation Regulations 91.315, 

91.319(a)(2), 119.S(g), 119.21(a) in order to more fully involve the public at aviation 

events which Team P3 participates in every year. Team P3 sponsors and participates in 

significant aviation events throughout the year. Team P3 feels that an exemption from 

Federal Aviation Regulations 91.315, 91.319, 119.5(g), 119.21{a) is necessary. This 

exemption will allow Team P3 to continue its mission relative to the education of the 

general public concerning the rare and historic Pilatus P3 aircraft and inspire aviation 

interest. Considering the positive effect of the Team P3 mission upon the general public, 

as well as the assurances of safety which Team P3 maintains, the scope of Federal 

Aviation Regulations 91.315, 91.319, 119.5(g), 119.21(a) relative to the operation of 

these Experimental Exhibition aircraft does not present a concern to the FAA. 

Background 

Team P3 is a qualified nonprofit 501{c)(3) educational organization devoted to inspiring 

aviation interest and perpetuating aviation heritage; Team P3 fulfills its mission by 

restoring, operating, maintaining and displaying the rare and historic Pi latus P3 aircraft. 
Only 72 Pi latus P3 aircraft were built. The Pi latus P3 was designed and utilized as an 

advanced military trainer used mostly by the Switzerland Air force. Only 28 Pilatus P3 

aircraft are registered with the FAA (see Exhibit B). The granting of the petition will 

allow for Team P3 to effectively utilize its historic and rare military aircraft as well as 

fulfill by enhancing its educational goals to the community. 

Interests of the Petitioner 

As an Arizona Nonprofit Corporation, with IRS 501{c)(3) status, Team P3 is devoted to 

promoting and inspiring aviation interest by using the Pilatus P3-05 aircraft. Team P3 

fulfills its mission by restoring, operating, maintaining and displaying the rare and 

historic Pilatus P3 aircraft. 

Public Interest 

Team P3 believes that the public interest would be well served through the continued 

operation of its historic aircraft. Certainly, either the static display or air show fly by 

operation of these aircraft provides a tremendous opportunity for the members of the 

general public to receive a unique educational experience specific to historic military 

aircraft. Actually riding in these historic aircraft will further enhance the educational 

experience. Operation of the historic military aircraft will have no negative effect 

whatsoever upon the air carriers which operate aircraft certified in the Standard 

Airworthiness Category. Those who will be aboard these historic aircraft will not be 

there for the purposes of air transportation. The only purpose in being aboard the 

aircraft is to experience flight in these historic aircraft, as well as participating in an 

educational event. All operations will depart from, and return to the same airport. Team 

P3 operations will not present any type of competition to the air carriers, since Team P3 
is not holding itself out for the carriage or transportation of persons or property. 

Additionally, the type of educational mission conducted by Team P3 is of no interest to 

the air carriers. Team P3 aircraft will be utilized solely for the purpose of providing 

educational and historical experiences to its clients. 

Safety Issues 

The professional members of Team P3's maintenance department are all FAA certified 

Airframe and Powerplant mechanics. They perform the maintenance in collaboration 

with FAA certified repair stations required by the Federal Aviation Regulations. All 

inspection programs meet or exceed relevant Federal Aviation Regulations. All aircraft 

are maintained in accordance with Federal Aviation Regulation Part 91 and inspections 

meet the requirements of Federal Aviation Regulation 91.409. Inspections are 

performed with appropriate technical orders and manuals specific to the Pi latus P3. 

The identical concern for safety, which is fundamental to the Team P3 approach to 

maintenance, is also an integral part of Team P3 flight operations. All pilots, who will be 

involved in flight operations under the proposed exemption, will possess, at a minimum, 

a Commercial Airman Certificate and Second Class Medical Certificate. Specific pilot 

qualifications and FAA check out procedures are enforced at all times prior to the pilot 

being approved under the proposed exemption. 

Description of the Relief Sought 

Team P3 has illustrated that there is an overriding public interest in the granting of its 

request for an exemption from Federal Aviation Regulations 91.315, 91.319, 119.S(g}, 

119.21(a). The mission of Team P3 to restore, operate, maintain and display the rare 

and historic Pi latus P3 aircraft is greatly enhanced by the granting of this exemption. The 
operations proposed by Team P3 will not present any competition to air carriers. Team 

P3 has the intention to provide flight experiences to clients on local educational flights. 

Team P3 has unequivocally demonstrated that the requisite equivalent of safety will be 

provided to those who participate in a flight experience in a Team P3 aircraft. Team P3 

maintenance and operations policies and procedures will ensure that safety is not 

compromised. Accordingly, Team P3 requests that the FAA issue an exemption from 

Federal Aviation Regulations 91.315, 91.319, 119.5(g), 119.21(a). for the continued 

operation of its historic aircraft. 

Travis R. Allen 

Team P3 

5115 N Dysart Rd 

STE 202-172 

Litchfield Park, AZ 85340 

Team P3 

Travis R. Allen 

President 
Exhibit A 

Aircraft currently on permanent loan to Team P3 as of 01Sep2015 

Pilatus P3-05 N836HS 
I Mfr/Mcll Number of 

I Code Arrcraft 

As; signed 

,7:)901()8 DELAWARE 

I :.1 

GEORGIA1 

NORTH 

CAROLINA1 

SOUTH 

CAROLINA· 

g 

TEXAS - 1 

WISCONSIN 

:..1 

Total = 7 

7393107 C.t;LIFORHIA 

:..1 

ILLINOIS- 1 

SGIJTH 

C.ARCLINA1 

lnta' = 3 

7J90131 ARIZ:JI~-2 

CALIFORNIA 

:._£ 

DELAWARE 

_ .. -

FLORIDA -2 

GEORGIA -

1 

MINNESOTA 

:.1 

NEBRASKA1 

NEW 

!/tEXICO- 1 

NORTH 

CAROLINA1 

SCL'TH 

DAKOTA - 1 

TENNESSEE 

:..1 

Total = 17 

7093216 NEW 

MEXIC0·- 1 

Iota;= 1 

Exhibit B 

FAA REGISTRY 

Make ; Model Inquiry Results 

Manufacturer Name Entered: PILATUS 

Mod£>1 Name Entered: P3 

Manufacturer Mode! Name Type Type Engine 

Name Aircraft 

PIL'uUS P3 F•Ked Re~tprocattllg 

Wing 

S<llg'aEngme 

PILA ,US P3..03 Fixed Re~•P'D~ailng 

w.ng 

Si11~leEngm;o 

PILA1US P3-:l5 FO<ed Rec!P rooot.ng 

lNing 

Stng:eEog,ne 

PILA 1US P-3 MK II t~ed Rec.pro~sting 

W.ng 

SingleEng;ne 

Aircraft Amateurrrc #of Aircraft Kit 

Category Engines Wei(fht CodE> 

#of 

Seats 

Land Amateur 01 Up t:> 

002 12.499 

Land A.mat~ur 01 vote 

\J:J1 12.4BB 

Land Amateur 01 Up to 

on 12,499 

Land Amateur \J1 Up to 

on 12.499 
§91 .315 Limited category civil aircraft: Operating limitations. 

No person may operate a limited category civil aircraft carrying persons or property for compensation or 

hire. 

§91.319 Aircraft having experimental certificates: Operating limitations. 

(a) No person may operate an aircraft that has an experimental certificate-

( 1) For other than the purpose for which the certificate was issued; or 

(2) Carrying persons or property for compensation or hire. 

§119.5 Certifications, authorizations, and prohibitions. 

(g) No person may operate as a direct air carrier or as a commercial operator without, or in violation of, an 

appropriate certificate and appropriate operations specifications. No person may operate as a direct air 

carrier or as a commercial operator in violation of any deviation or exemption authority, if issued to that 

person or that person's representative. 

§119.21 Commercial operators engaged in intrastate common carriage and direct air carriers. 

(a) Each person who conducts airplane operations as a commercial operator engaged in intrastate 

common carriage of persons or property for compensation or hire in air commerce, or as a direct air 

carrier, shall comply with the certification and operations specifications requirements in subpart C of this 

part, and shall conduct its: