20 November2013 U.S. DepartmentofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590 To Whom It MayConcern: i,..t •.

Wings of Eagles, LLC (hereinafter referred to as "WINGS") hereby requests an exemption to FAR 141.27 (b)(1) and 141.27 (b)(3). WINGS would like to reapply for a provisional pilot school certificate immediately. The prior provisional certificate, W6GS760K, had an expiration date of 30 Sept 2013. That certificate is no longer usable. FAR 141.27 (b)(1) prohibits a renewal ofa provisional certificate, and FAR 141.27(b)(3) requires a flight school who has allowed the certificate to expire to wait 180days before making a newapplication. The request for the immediate renewal is based on the fact that during the previous period (October 1, 2011 through September 30, 2013) when WINGS had a provisional certificate, the economy was in a recession and the number ofstudents enrolled in the FAR 141 flight school fell. Many ofthe studentsjust stopped flying all together. As the economy improved, students were enrolling in our school. We just were not able to attain the 10 student completions required underFAR 141.5(e). We did, however, meetthe requirements ofFAR 141(a-d). WINGS is the only flight school in Middle Tennessee that has VA approval for flight training. Additionally, WINGS is the only non-degreed FAR 141 program in Middle Tennessee, and also has the customer reach into Southern Kentucky and Northern Alabama. We have two locations with the primary base at the Smyrna Airport (KMQY) and a satellite operation at the John C. Tune NashvilleAirport (KJWN). The economy has rebounded, and the numberof beginning students is up 5-fold from one year ago. There are students who want the structure of a FAR 141 flight school, not only for the better experience, but for the cost savings in training. Based on the above statements, we believe it is in the best interest ofthe public to have our request granted. We also believe that WINGS can be a benefit to the veterans who receive funds fortraining from the Gl Bill who are based in Clarksville, TN, at Ft. Campbell. WINGS only received VA approval in the past fewyears as the economy was beginning to recover and training opportunities for ourveterans was just startingtogain traction.

276DougWarpooleRd., Smyrna, Tennessee37167 (615) 355-0033 •Fax (615) 220-2960 www.wingsmqy.comWings of Eagles, LLC is prepared to provide a revised set of Training Course Outlines at the earliest opportunity. The flight school is planning to change personnel, and gettingthe FAR 141 flight school going again would be accomplished in asafe, expeditious manner. Our proposed managementteam will be as follows:

• Bill Lardent, Chief Flight Instructor
• Kyle Willoughby, AssistantChief Flight InstructoratWINGS Smyrna Primary Base
• Randy Harmon, Assistant Chief Flight InstructoratWINGS John C. Tune Satellite Base
You will find the above personnel's qualifications in respect to the FAR 141 requirements in the attached addendum. In no waywould safety be adversely affected bygrantingthis exemption. In fact, we believe that safety can only be enhanced through the more structured approach to training that operating under FAR 141 provides. Please feel free to contact me with any questions or concerns at 615-220-1761 orvia email at allen.howell@flycfm.com. Sincerely,

# ~~ Allen Howell Owner Enclosures (2) AH/Ikp
cc: Kyle Willoughby Wings ofEagles, LLC Kyle.w@wingsMQY.com 615-355-0033 615-220-2960fax
cc: Mr. Ken Pannell (WINGS POl) Federal Aviation Administration 2 International Plaza Suite 700 Nashville, TN 37217

276 DougWarpoole Rd., Smyrna, Tennessee37167 (615)355-0033 •Fax (615)220-2960 www.wingsmqy.comSummaryofWings ofEagles, LLC Requestfor Exemptionfrom FAR 141.27 (b)(1) and (b) (3) Wings of Eagles LLC (hereinafter referred to as "WINGS") is aflighttraining company located in MiddleTennessee at the Smyrna Airport (KMQY- Primary Base) and the John C. Tune Nashville Airport (KJWN - Satellite Operation). The company was founded in 1998 and has operated continuously since then, originally providing training under FAR 61 and, eventually, also under FAR 141. Presently, the company serves students from a geographical region covering Middle Tennessee, Southern Kentucky and NorthernAlabama with afleet of14aircraft. Due to a slowdown in the economy that began in early 2009, WINGS did not have enough student graduations from its training courses to meet the applicable regulations as stated below. The prior provisional certificate, W6GS760K, had an expiration date of 30 Sept 2013. That certificate is no longer usable. FAR 141.27 (b)(1) prohibits a renewal ofa provisional certificate, and FAR 141.27(b)(3) requires aflight school who has allowed the certificate to expire to wait 180days before making a newapplication. The request for the immediate renewal is based on the fact that during the previous period (October 1, 2011 through September 30, 2013) when WINGS had a provisional certificate, the economy was in a recession and the number of students enrolled in the FAR 141 flight school fell. Many ofthe studentsjuststopped flying all together. As the economy improved, student's enrollments were on the rise and we believe we could have met the 10 required graduations within an additional 3 months. We just were not able to attain the 10 student completions required under FAR 141.5(e). We did, however, meet all ofthe requirements ofFAR 141(a-d). WINGS is the only flight school in Middle Tennessee that has VA approval for flight training. Additionally, WINGS is the only non-college degreed FAR 141 program in Middle Tennessee. The economy has rebounded, and the number of beginning students is up 5-fold from one year ago. There are students who want the structure of a FAR 141 flight school, not only for the betterexperience, butforthe cost savings in training. We also believe thatWINGS can be a benefittotheveterans who receive funds fortrainingfrom the Gl Bill who are based in Clarksville, TN, at Ft. Campbell. WINGS only received VA approval in the past fewyears as the economywas beginning to pick up and training forourveterans under the VA approval wasjuststartingtogain traction. Based on the above statements, we believe it is in the best interest ofthe public to have our exemption request granted. Wings of Eagles, LLC is prepared to provide a revised set of Training Course Outlines at the earliest opportunity. The flight school is planning to change personnel (see addendum for qualifications of new management personnel) and getting the FAR 141 authority reinstated would be accomplished in a safe, expeditious manner. In no way would safety be adversely affected by granting this exemption. In fact, we believe that safety can only be enhanced through the more structured approach totrainingthatoperating under FAR 141 provides.

276DougWarpoole Rd., Smyrna, Tennessee 37167 (615) 355-0033 •Fax (615) 220-2960 www.wingsmqy.com

# ADDENDUM Wings of Eagles 141 Management Staffand Qualifications

Chief Flight Instructor: Bill Lardent ATP; CFII; MEI1698770 14,000TotalTime Mr. Lardent meets appropriate requirements of FAR 141.35

Assistant Chief Flight Instructor(JohnTune): Randy Harmon ATP; CFII; MEl 3192563 5,425 TotalTime Mr. Harmon meets appropriate requirements of FAR 141.36

Assistant Chief Flight Instructor(Smyrna): Kyle Willoughby Commercial; CFII; MEl 3435986 1,300TotalTime Mr.Willoughby meets appropriate requirements of FAR 141.36

276DougWarpooleRd., Smyrna,Tennessee37167 (615) 355-0033 •Fax (615) 220-2960 www.wingsmqy.com