• STUART A. GOLDSTEIN, P.A. 

Stuart A. Goldstein, Esq. Board Certified Aviation Law Attorney 

7300 North Kendall Drive, Suite 380 T: (305) 670-1222 

Miami, FL 33156 F: (305) 400-0685 

August 31, 2015 stuartgoldsteinpa@att.net 

Via Federal Express 

U. S. Department of Transportation 

Docket Operations 

West Building, M-30 

Room W12-140 r·· .. :. 

1200 New Jersey Avenue, S. E. 

Washington, D. C., 20590 

Re: The Liberty Foundation, Inc.'s Petition To 

Renew Its Exemption No. 8565, As Amended 

To Whom It May Concern: 

The purpose of this letter is to encourage the Agency to promptly renew The 

Liberty Foundation's Exemption No. 8565, as amended, based upon the facts set out 

in the Foundation's filings. To briefly summarize the recent activity: 

August 22. 2014: The Liberty Foundation filed its Petition For Renewal of its 

Exemption. 

December 10, 2014: The Agency denied the Foundation's Petition for Renewal. 

February 6, 2015: The Foundation filed its Petition for Reconsideration of the 

Denial. 

April 21, 2015: At the Agency's request, the Foundation filed its Aircraft 

Operations Manual. 

June 12, 2015: The Foundation filed its 86 page Supplement to its Petition for 

Reconsideration. 

August 7. 2015: At the Agency's request, the Foundation filed its Safety 

Management Systems Manual. 
U.S. Department of Transportation 

August 31, 2015 

Page Two 

It is unnecessary to recite all of the facts the Foundation has submitted to the 

Agency in support of its Petitions for Renewal and Reconsideration. They are well 

known to the Agency. However, it is appropriate to again point out several 

important factors which support renewal. 

The Foundation has been a leader in the LHFE community since it began 

operations in 2005. It has flown more than 25,000 LHFE passengers without a 

single accident, incident, or injury to a passenger or crew-member.1 

Subsequent to the accident involving The Liberty Belle aircraft (N390TH), 

the Foundation commenced operating the Movie Memphis Belle aircraft (N3703G) 

and did so very safely and successfully until December 2014, when the renewal was 

denied. It is noteworthy that almost a full year after the June 2011 accident the 

Agency renewed the Foundation's Exemption in May 2012 to operate the Movie 

Memphis Belle. 

In seeking the renewal of its Exemption, the Foundation has complied with 

each and every request of the Agency to satisfy it of the Foundation's compliance 

record and attitude. There can be no serious concern as to the Foundation's ability 

and compliance attitude in the past and going forward. The Foundation is ready, 

willing, and able to commence LHFE operations immediately upon the Agency 

renewal of the Exemption as shown in the Foundation's filings listed above. 

When an air carrier has an accident or is found in violation of the Federal 

Aviation Regulations, the Agency typically fines the carrier but does not revoke its 

authority to operate. Certificate revocation occurs only in the most egregious 

circumstances. This is true notwithstanding serious, multiple, violations resulting in 

fines of hundreds of thousands of dollars, injuries and death. There is no plausible 

reason the Foundation should be treated less equally. 

Accordingly, this is to request the Agency promptly renew the Foundation's 

Exemption. The Foundation stands ready to comply with all Agency requirements. 

~espectfully submitted, 

i _ __,.) I) ")!)~. crl\ A-1- ' .. /'tw~~~ &(t ~-tJt;J,tu~ Stuart A. Goldstein 

Counsel for The Liberty Foundation 

1 The June, 2011 accident was not a LHFE flight.