1

HONORING AMERICAN MILITARY AVIATION THROUGH FLIGHT, EXHIBITION &

REMEMBRANCE

PETITION FOR LHFE EXEMPTION September 21, 2016

The Commemorative Air Force (CAF) is requesting an exemption from §§ 91.9, 91.315, 91.319(a), 119.5(g), and 119.21(a) of Title 14, Code of Federal Regulations (14 CFR) to allow CAF to operate certain aircraft for the purpose of carrying passengers for compensation or hire under the Living History Flight Experience (LHFE) program IAW FAA policy p osted on

07/21/2015 ID: FAA

- 20 15

- 0517

- 0001. Operating air c raft under the LHFE program has been accepted by the FAA as in the public interest for nearly 20 years and is reaffirm ed in the July, 2015 policy. This petition for an exemption under the new policy explains how our policies and procedures meet the specific criteria of the new LHFE program, which provides the required Safety Risk Management (SRM) and Equal Level of Safety (ELoS).

David Oliver V.P. of Safety, Operations, & Maintenance

Commemorative Air Force

214

- 330

- 1700 ext.127
Cell: 630

- 853

- 9624 doliver@cafhq.org2



### A. Air craft Requested for the Exemption

We are currently operating under LHFE exemption 6802M which is valid until November 2017. The reason we are submitting this request under the new policy is we want to add

back our T

- 33 N9124Z (which was left off our renewal request [ around 2007 ?] when it

was in static status and TBM N53503 which was removed from our exemption when a pilot raised the gear on the ground resulting in an accident (March, 2014) ; it has returned to service. Additionally, we want to add TBM N40402 which has returned to

service after extensive restoration.

Thi s request does not include thee aircraft currently in our exemption which have standard categor y counterparts: PT

- 17 N1387V, C

- 46 N53594 and C

- 45 N4207. We have

also removed A

- 26 N626SH which is in restoration.

The aircraft in the following table were U.S. operated

, are no longer in military service

and the ir original type designs are more than 50 years old . The number of each model produced/put into service are shown in th e table, a s are the number of aircraft registered in the US. They represent very smal l percentages of the numbers produced

and therefore meet the criteria for fragility. The only one of these aircraft models with examples registered in the standard category is the T

- 28A (see note below the table).

N

Number Model # In

6802M Inspection

Type Category #

Produced # Registered

US %

Remaining

240P A

- 26 x AAIP LIMITED 2,452 29 1%

9682C A

- 26 x AAIP LIMITED 2,452 29 1%

7227C B

- 17 x AAIP LIMITED 12,731 19 <1%

9323Z B

- 17 x AAIP LIMITED 12,731 19 <1%

24927 B

- 24/LB30 x AAIP EXPER 19,256 3 <1%

125AZ B

- 25 x Annual LIMITED 9,816 86 <1%

25YR B

- 25 x AAIP LIMITED 9,816 86 <1%

27493 B

- 25 x AAIP LIMITED 9,816 86 <1%

345TH B

- 25 x AAIP LIMITED 9,816 86 <1%

5865V B

- 25 x Annual LIMITED 9,816 86 <1%

9643C B

- 25 x AAIP LIMITED 9,816 86 <1%

529B B

- 29 x AAIP EXPER 3,970 3 <1%

10601 P

- 51 x Annual LIMITED 15,000 159 1%

44727 P

- 51 x Condition LIMITED 15,000 159 1%

5428V P

- 51 x Condition LIMITED 15,000 159 1%

61429 P

- 51C x Annual LIMITED 15,000 159 1%

92879 SB2C x AAIP EXPER 7,140 1 <1%

82GA SBD x Annual LIMITED 5,936 4 <1%

70743 T

- 28A x Condition EXPER 1,194 79 6.60%

9124Z T

- 33 Condition EXPER 6,557 68 1%

40402 TBM

- 3 Annual LIMITED 9,839 50 <1%3

5264V TBM

- 3 x AAIP LIMITED 9,839 50 <1%

53503 TBM

- 3 AAIP LIMITED 9,839 50 <1%

Sources:

Number Produced: Wikipedia Number US Registered: http://registry.faa.gov/aircraftinquiry/acftref_inquiry.aspx

NOTE on T

- 28A: The policy specifically uses it as an example of aircraft which will not be considered,

because the mode l achieved certification as a standard aircraft. We are requesting re

consideration of the T

- 28A for these reasons: 1. There are only 79 of these in the FAA registration data base; 45 are registered as experimental, 13 are restricted and 16 are

shown as un known. Only 5 are registered as standard category. 2. There were 1,194 “A” models built, so only 7% remain registered in the US and only 6% of those are registered standard category. 3. There is no established path for converting the experimental T

28As to standard category. 4. The aircraft is fragile 5. The aircraft were not standard category converted too experimental (which we agree should not be permitted) 6. Limiting the public’s opportunity to “experience” the T

- 28A in the only 5 aircraft

converted fr om their origina l design seems contrary to the purpose of the program when the original configurations can meet the standards of the new policy.



### B. Responsible Person and Operational Control Structure

The r esponsible person for the CAF is the Vice Presid ent for Safety, Operations and

M aintenance (hereafter referred to as the VP) David Oliver, 214

- 330

- 1700 ext.127 doliver@cafhq.org , who reports directly to the President/CEO. The HQ staff in the
Operations Department in cludes a Direct or of Operations , Director of

Maintenance /Quality Assurance (Vacant) , Designated Employer Representative (for

91.147 D rug and Alcohol progr am)

, Operations Office Manager, Director of Flight Safety (volunteer) and a Director of Industrial and Ground Safety (volunteer). The Organizational structure of the CAF, its subordinate corporations and the responsibilities

of the staff are defined in CAF Regulation 21

- 1.

The Chain of Command in the CAF is similar to the military because we have 165 airp lanes operated by 60 units located in 26 states. Each of our units have elected staff

officers and three of these are the Operations Officers, Maintenance O fficer s and the Safety Officers. These unit officers work directly with their counterparts in the HQ Operations Department. The qualifications and duties for these unit officers (and the additional management positions) are defined in the CAF Unit Manual, Section 2.

Our FSDO for the organization is the North Texas FSDO.4



### C. Safety and Risk Management

Use of SRM Principles: The Commemorative Air Force Safety Program was built upon the pillars of Safety Management Systems (SMS), before SMS became the standard for aviation safety programs. SMS models have matured with significant tools to improve

manageme nt of risk as an ongoing business objective. However, most were created for organizations of significant size with full time employees and require a lot of paperwork which provide little benefit in our organization. We are operating with common

structures and standards of Aviation Safety Management Systems, but have not restructured our programs just to make them look li ke one of the models. Our “Safety Management System Guide # 11 ” is a simple explanation of our safety program history and how our regulatio ns and manuals functions as a safety system. During the annual training required for all of our pilots, mechanic s and helpers it is explained how their specific regulations and manuals tie into the SMS. This enforce s the concept of how all of our policies and procedures tie together for the overarching effect of risk reduction.

Mitigation Process: The identification of risk happens in the field; mitigation and reporting are handled in various ways. The members most frequently work with their Unit Safety Officers, Operations Officers and Unit Leaders and solve things on the spot

. However, w e do have an anonymous process (Safety Reporting System Guide #4) to elevate things directly to the VP if the member feels it is necessary. The fortunate thing about our culture is, members and unit off icers are totally comfortable calling on the phone, sending a quick email to the VP to report issues they can’t handle at their level,

or are of a nature ot her units should be made aware of.
Risk elevated to the HQ are evaluated by the VP , the CAF Staff and Ad Hoc Safety Committees. Mitigations are implemented specifically to the risk, or are incorporated into CAF policies and procedures if the risk is recurr ing, or wide spread.

A ll aircraft accidents and incidents are reported to HQ. The VP, or the Director of Operations will proceed to all major accidents and if there is an NTSB field investigation, they will be Party to the investigation. The lead investig ators have always allowed us to release information to our units for prevention many months before a probable cause is established by the Board. For accidents involving pilot error, the Standardization and Evaluation Committee is part of the process to co nsider sanctions, re

- training of the pilot or if our policies and procedures need to be changed

.5



### D. Manuals System

The Safety, Operations and Maintenance manuals and documents have evolved over many years and have proven to be a ppropriate for our organi zation of volunteer s in the

field ( where the aircraft operations and maintenance occur )

. The individual documents are designed for easy use according to the subject area, but as a whole, constitute the

“Policies and Procedures” as the third element of the Risk Management Pillar s in our

SMS.

Regulations and Manuals :

- CAFR 55

- 7 Procedures for Air show and Event Approvals

- CAFR 60

- 1 Procedures for Flight Operations (General Operations Manual )

- CAFR 60

- 3 Drug and Alcohol policy

- CAFR 66

- 1 Aircraft Maintenance Pol icies and Procedures

- Marshaller’s Training Manual NOTE: Training requirements for crews are in CAFR 60

- 1 and for Maintenance in

CAFR 66

- 1

Guides:

- CAF Safety Management System ( Guide # 11 )

- CAF Anonymous Flight Safety/Ground Hazard Reporting ( Guide # 4 )

- Safety for CAF Pyro Units

- Ground Safety Guide



### E. Other Considerations

We are not requesting additional considerations.