20 November 2013 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

To Whom It May Concern: 

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 of a provisional certificate, 

and FAR 141.27(b)(3) requires a flight school who has allowed the certificate to expire to wait 

180 days before making a new application. 

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 of the students just 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 under FAR 141.5(e). We did, however, meet the requirements of FAR 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 Nashville Airport (KJWN). 

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 

better experience, but for the cost savings in training. Based on the above statements, we 

believe it is in the best interest of the public to have our request granted. We also believe that 

WINGS can be a benefit to the veterans who receive funds for training from the Gl Bill who are 

based in Clarksville, TN, at Ft. Campbell. WINGS only received VA approval in the past few years 

as the economy was beginning to recover and training opportunities for our veterans was just 

starting to gain traction. 

276 Doug Warpoole Rd., Smyrna, Tennessee 37167 

(615) 355-0033 • Fax (615) 220-2960 

www. wingsmqy.com 
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, and getting the FAR 141 

flight school going again would be accomplished in a safe, expeditious manner. 

Our proposed management team will be as follows: 

• Bill Lardent, Chief Flight Instructor 

• Kyle Willoughby, Assistant Chief Flight Instructor at WINGS Smyrna Primary Base 

• Randy Harmon, Assistant Chief Flight Instructor at WINGS 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 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 to training that operating 

under FAR 141 provides. 

Please feel free to contact me with any questions or concerns at 615-220-1761 or via email at 

allen.howell@flycfm.com. 

Sincerely, 

~~ Allen Howell 

Owner 

Enclosures (2) 

AH/Ikp 

cc: Kyle Willoughby 

Wings of Eagles, LLC 

Kyle.w@wingsMQY.com 

615-355-0033 

615-220-2960 fax 

cc: Mr. Ken Pannell (WINGS POl) 

Federal Aviation Administration 

2 International Plaza 

Suite 700 

Nashville, TN 37217 

276 Doug Warpoole Rd., Smyrna, Tennessee 37167 

(615) 355-0033 • Fax (615) 220-2960 

www.wingsmqy.com 
Summary of Wings of Eagles, LLC Request for Exemption from FAR 141.27 (b)(1) and (b) (3) 

Wings of Eagles LLC (hereinafter referred to as "WINGS") is a flight training company located in 

Middle Tennessee 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 Northern Alabama with a fleet of 14 aircraft. 

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 of a provisional certificate, 

and FAR 141.27(b)(3) requires a flight school who has allowed the certificate to expire to wait 

180 days before making a new application. 

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 of the students just stopped 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 of the requirements of FAR 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 

better experience, but for the cost savings in training. 

We also believe that WINGS can be a benefit to the veterans who receive funds for training from 

the Gl Bill who are based in Clarksville, TN, at Ft. Campbell. WINGS only received VA approval in 

the past few years as the economy was beginning to pick up and training for our veterans under 

the VA approval was just starting to gain traction. 

Based on the above statements, we believe it is in the best interest of the 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 to training that operating under FAR 141 provides. 

276 Doug Warpoole Rd., Smyrna, Tennessee 37167 

(615) 355-0033 • Fax (615) 220-2960 

www. wingsmqy.com 
ADDENDUM 

Wings of Eagles 

141 Management Staff and Qualifications 

Chief Flight Instructor: Bill Lardent 

ATP; CFII; MEI1698770 14,000 Total Time 

Mr. Lardent meets appropriate requirements of FAR 141.35 

Assistant Chief Flight Instructor (John Tune): Randy Harmon 

ATP; CFII; MEl 3192563 5,425 Total Time 

Mr. Harmon meets appropriate requirements of FAR 141.36 

Assistant Chief Flight Instructor (Smyrna): Kyle Willoughby 

Commercial; CFII; MEl 3435986 1,300 Total Time 

Mr. Willoughby meets appropriate requirements of FAR 141.36 

276 Doug Warpoole Rd., Smyrna, Tennessee 37167 

(615) 355-0033 • Fax (615) 220-2960 

www. wingsmqy.com