TO: Docket Management Facility US Department ofTransportation 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), forthe operation of certain Pilatus 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 ofthese 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 ofthe Team P3 mission upon the general public, as well as the assurances ofsafety 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 Pilatus P3 aircraft.

### Only 72 Pilatus P3 aircraft were built
. The Pilatus 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 ofthe 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 ofthe 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 wou ld be well served through the continued operation of its historic ai rcraft. Certainly, eitherthe static display or air show fly by operation ofthese aircraft provides a tremendous opportunity for the members ofthe general public to receive a unique educational experience specific to historic military aircraft. Actually rid ing in these historic aircraft will further enhance the educational experience
. Operation ofthe historic military aircraft will have no negative effect whatsoever upon the ai r carriers which operate aircraft certified in the Standard Ai rworthiness Category
.Those who will be aboard these historic aircraft will not be there for the pu rposes 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 ai r carriers, since Team P3

### is not holding itself out for the carriage or transportation of persons or property. Additionally, the type ofeducational 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 ofTeam 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 Pilatus P3. The identical concern for safety, which is fundamental to the Team P3 approach to maintenance, is also an integral part ofTeam 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 ofthe 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 ofTeam P3 to restore, operate, maintain and display the rare and historic Pilatus P3 aircraft is greatly enhanced by the granting ofthis exemption. Theoperations proposed byTeam 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 PresidentExhibit A Aircraft currently on permanent loan to Team P3 as of 01Sep2015 Pilatus P3-05 N836HSI Mfr/Mcll Number of 

### I Code Arrcraft As;signed ,7:)901()8 DELAWARE 

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### Exhibi t 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** WingS<llg'aEngme

PILA ,US P3..03 Fixed**Re~ •P'D~ailng**  w.ng**Si11~le** Engm;o

PILA1US P3-:l5 FO<ed Rec!P rooot.ng lNingStng:eEog,ne

PILA 1US P-3 MK II**t~ ed** **Rec.pro~sting** W.ngSingleE ng;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 oras a commercial operator in violation ofany 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 aircommerce, or as a directair carrier, shall comply with the certification and operations specifications requirements in subpart C ofthis part, and shall conduct its: