Law	Offices 

# Yodice Associates

411	Aviation	Way,	Suite	245 Frederick,	MD	21701 Office:		(301)	695

- 2300 FAX:		(301)	695

- 2151 www.yodice.com JOHN S. YODICE * KATHLEEN A. YODICE * MICHAEL A. YODICE PARALEGAL RAYMOND C. SPECIALE LEONARD CERUZZI ‡ ELIZA BETH M. CANDELARIO ** OF COUNSEL

* MD & DC; ‡ CT ONLY;

** PA & DC THROUGH U.S. DEPARTMENT OF TRANSPORTATION DOCKET MANAGEMENT SYSTEM
-- WWW.REGULATIONS.GOV

June 18, 2015

Federal Aviation Administration c/o U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Fl, Rm W12

- 140 Washington, DC 20590
Re: Petition for Renewal of Exemption No. 8593D Regulatory Docket No. FAA
- 2002
- 12993
Enclosed is our petition to renew Exemption No. 8593D issued to the Stallion 51 Corporation, which exempts the operation of their North American TF

- 51 Mustang aircraft from 14 C.F.R. § 91.315. The Stallion 51 Corporation has held this exemption and a similar exemption since 1998 and has throughout those years oper ated their aircraft at a more than equivalent level of safety without incident and without any compromise to aviation safety. There has not been any change in the conditions and reasons relative to the public interest and safety that were the basis for granting the original exemption, nor is there any need to change the conditions and limitations contained in the originalgrant of exemption. Therefore, we respectfully request that the Exemption No. 8593D be renewed in its current form and that its effec tiveness be extended until at least July 31, 2017, or longer given the more than 15 years of safe operations under the FAA’s exemption authority. If there are any questions or need for additional information, please contact our office at 301

- 695
- 2300 and we will promptly respond. Sincerely,

Kathleen A. Yodice Counsel to Stallion 51 Corporation
EnclosureTO: U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12
- 140 Washington DC 2059 0

PETITION FOR RENEWAL OF EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION 91.315 FOR THE OPERATION OF THE STALLION 51 CORPORATION'S NORTH AMERICAN TF
- 51 MUSTANGS

Petitioner: Stallion 51 Corporation 3951 Merlin Drive K issimmee, FL 34741

Dated: June 18 , 20152 RELIEF SOUGHT The Stallion 51 Corporation seeks a re newal of FAA Exemption No. 8593D (Regulatory Docket No. FAA
- 2002
- 12993). Specifically, Stallion 51 seeks the renewal of its exemption from Federal Aviation R egulation (FAR) Section 91.315 for the operation of its North American TF

- 51 Mustangs. Stallion 51's Mustangs are currently certificated in the limited category. Stallion 51 seeks continued relief from the application of FAR
91.315 to provid e various typ es of training in these aircraft and will continue to do so with a level of safety that exceeds what is required by the regulations.
REASONS FOR PETITION Since April of 1987, Stallion 51 has operated TF

- 51 aircraft. The original TF

- 51, when purchased, po ssessed a standard airworthiness certificate. However, after approximately three years of operation, the FAA determined that it made an error in issuing the certificate, and a limited category special airworthiness certificate was issued. Although FAR §9 1.315 generally prohibits the carriage of persons or property for compensation or hire in any aircraft other than one certificated in the standard category, Stallion 51 was assured by the FAA that flight training in this limited category aircraft would be permissible. Stallion 51 was advised by the3 FAA that since the TF

- 51 has dual cockpits and fully functional dual controls, and the trainee is a crewmember and not a passenger, the regulation would not apply. In the late 1990's, the increased use of aircr aft that did not possess a standard airworthiness certificate, such as those imported from foreign countries, and the increased use of

non - standard airworthiness certificated aircraft for air show "press rides" prompted a review by the FAA. Stallion 51 di scussed with the FAA the issue of the applicability of FAR 91.315 to their operation. The Corporation requested and was granted an exemption from FAR 91.315. Stallion 51 continues to conduct operations according to the strictest procedures and standards , setting them apart from others in the industry. As exemplified by their flawless safety record, Stallion 51 sets the standard through practices such as monthly safety stand
- downs and quarterly safety briefs, constant review of operations and instruction s, a maintenance program conducted in accordance with the FARs, and a highly trained staff of Certified Flight Instructors, including an exceptionally qualified Chief Pilot and full time Flight Surgeon, who conduct training in a manner that meets or exceed s the requirements of the FARs. Stallion 51’s incomparable operations warrant exceptional treatment, justifying the4 continued exemption from FAR 91.315 without additional conditions or limitations.
BACKGROUND Stallion 51 operates thr ee dual
- cockpit, dua l
- control P
51s, known as the TF
- 51 Mustang. These aircraft were specifically designed for fighter training and high performance fighter aircraft transition training. The aircraft are utilized in a number of training situations, including military
contra cts, initial/recurrent training, unusual attitude training, types specific formation and aerobatic training, and orientation flights. In 1998, Stallion 51 petitioned the FAA for a grant of exemption from FAR §91.315 in order to be able to provide
tr aining in the aircraft as further described in this petition . Stallion 51 d id not seek to provide air transportation for compensation or hire in these aircraft. Recognizing that the services provided by Stallion 51 are in the public interest, the FAA gran ted Stallion 51's request on September 17, 1998 and issued Exemption No. 6811. On June 22, 2000, Stallion 51 petitioned the FAA for a renewal of Exemption No. 6811. The FAA determined that the justifications for issuing the original exemption remained va lid and granted a renewal of the exemption, by letter dated September 8, 2000, and issued Exemption No.5 6811A. On July 22, 2002, Stallion 51 again petitioned the FAA for a renewal of Exemption No. 6811A, which the FAA granted on September 4, 2002, and iss ued Exemption No. 6811B. Exemption No. 6811B was set to expire on September 30, 2004. A Petition for Renewal of Exemption No. 6811B was filed on May 12, 2005, and the FAA determined that because Exemption No. 6811B had expired, the FAA would treat the Pe tition as a new request for exemption. The FAA granted the request for exemption and issued Exemption No. 8593 in a letter dated August 1, 2005. Stallion 51 filed a Petition for Renewal of Exemption On June 7, 2007. The FAA granted the petition and issu ed Exemption No. 8593A in a letter dated July 23, 2007. O n May 21, 2009, Stallion petitioned for another Renewal of Exemption, which the FAA granted and issued Exemption No. 8593B o n July 20 , 2009 . O n
June 10 , 2011, Stallion again petition for and was gr anted a Renewal of Exemption by the FAA with the issuance of Exemption
No. 8593C on July 14 , 2011 . This exemption was most recently
renewed wh en Stallion filed a petition o n June 28 , 2013 and th e FAA issued Exemption No. 8593D o n July 29 , 2013 . This curr ent exemption is set to expire on July 31, 2015.
INTERESTS OF THE PETITIONER Stallion 51 operates three of only sixteen known TF

- 51 Mustangs in existence in the world. Stallion 51 operates these6 trainers at a level that meets, and generally exceeds, mili tary operating procedures. A select and highly experienced team conducts all training operations. In the interest of safety, all flight operations are conducted under day, VFR conditions. An integral part of Stallion 51's training curriculum consists of initial/recurrent training. A complete dual training syllabus is utilized in initial/recurrent training.
See Exhibit A. 1 The training covers such issues as aircraft systems, normal and abnormal procedures, basic flight maneuvers, slow and high performa nce maneuvering, stalls and departures , with heavy emphasis on take

- offs and landings. Successful participants in the program will demonstrate knowledge and proficiency in the aircraft at a level required for a type rating under FAR Part 61. R ecurrent tr aining is offered for those who successfully complete initial training, as well as for pilots of other high performance aircraft. D epending upon the pilot's skill level, recurrent training can vary from one to three flights. The program provides an inten sive review of aircraft systems, procedures , and various flight maneuvers, as

1 Cites to "lettered" exhibits are to those exhibits that were attached to the original Petition for Exemption and are not attached he reto. They can be provided upon request if necessary. Cites to "numbered" exhibits are to those exhibits that were attached to the June 2000 Petition for Renewal of Exemption. They can also be provided upon request if necessary. 2 Under the FARs, a stu dent pilot with complex, tail wheel, and high performance aircraft endorsements can act as Pilot in Command of a limited category P
- 51 Mustang. Additionally, a private pilot would be allowed to fly7 well as introducing the latest safety materials available relative to the operation of the aircraft. Another essential element of the Stallion 51 training program consists of or ientation training flights. These flights are conducted under the same safety standards as initial/recurrent training; however, completion of the dual training syllabus is not envisioned, nor is it expected that the student will perform at a level consist ent with the standards for a type rating. Orientation flights are offered to individuals who are considering the purchase of a high performance warbird aircraft, others who would simply like to sharpen their existing pilot skills, corporate flight operato rs, airline pilots seeking unusual attitude recovery training, and even individuals who are currently student pilots, or may become student pilots in the future. All training is performed by the same staff who provide initial/recurrent training. Further, all instruction is logged as dual, pursuant to the applicable FARs. An important aspect of Stallion 51's training operation is the service it has provided through military contracts. For the maj ority of the past 28 years, except for a few years during which lack of funding has led to a lack of contracts, flight operations have been conducted for the United States Navy Test Pilots School at Patuxent River Test Center. This training8 provided test pilot students and staff with military quali tative evaluations. Utiliz ation of the TF

- 51 Mustang is key to the success of this training. In addition to training for the Navy, Stallion 51 has conducted similar programs for the United States Air Force Test Pilot School and the International Test Pil ot School, a school that provides flight test services and training to civil and military customers from around the world. When Stallion 51 first petitioned the FAA for its exemption, approximately five hundred (500) training flights had been
conducted fo r the military. That number now stands at approximately seven hundred ( 700 ). Between the time of the original Petition for Exemption and the time of the 2000 Petition for Renewal of Exemption, Stallion 51 formally added "Unusual Attitude and Upset Train ing" to the curriculum. See Exhibit #1. Stallion 51 has successfully continued operation of this addition, which has proven to be an important and valuable subset of Stallion 51's overall training program. All individuals seeking a pilot certificate are required to receive training in returning an aircraft to level flight from what is termed an "unusual attitude." This training is normally taught in the context of flying partially or solely with reference to instruments and is normally done during a pil ot's initial pilot training. One shortcoming of this9 training is that it is normally done in a small, low performance aircraft with power and bank

- angle (roll) limitations. Although this initial pilot training may address recovery from an "unexpected att itude," it generally does not address extreme pitch and roll excursions and thus does not adequately prepare flight crews for flying in today's environment. The advent of automated flight control systems and the mixing of many types and sizes of airplanes in the traffic pattern of many airports has increased the potential for the aircraft to be "upset" from level flight. Unless the pilot is properly trained and prepared to respond to these types of upsets, the pilot may lose control of the aircraft.
The National Transportation Safety Board (NTSB) has long
noted that: Many accidents and incidents have involved airplanes that achieved attitude and flight path angles that were outside the normal flight envelope. However, this flight path was still within no rmal flight regime, before it achieved more severe attitude and flight path angles. The NTSB recommended that air carrier and commercial operators provide their flight crews with training in the recognition of and recovery from unusual attitudes and upset maneuvers, including upsets that occur while the aircraft is being controlled by automatic flight control systems, and unusual attitudes that result from flight control malfunctions and10 uncommanded flight control surface movements. See NTSB Recommendatio ns A - 96
- 66 and A
- 96
- 120. This is the basis for Stallion 51's Unusual Attitude and Upset Training. The TF

- 51 has control pressures much like many corporate and commercial aircraft and can be flown without pitch, bank, or airspeed restrictions to safely rep licate any possible flight condition. Because an equivalent level of unusual attitude and upset recovery training is not readily available in standard category certificated aircraft, Stallion 51 provides a service that may otherwise be unavailable to a pi lot. Based upon the foregoing, it is clear that Stallion 51 offers a complete program of high performance training in the
TF - 51 Mustang that is conducted and accomplished safely and successfully and meets a safety training need that is not otherwise easil y or efficiently accessible in the industry . Stallion 51 seeks to continue these training activities in full compliance with the FARs, as it has done s o for the past 28 years. Accordingly, Stallion 51 requests a renewal of the Grant of Exemption No. 8593 B from FAR 91.315.
PUBLIC INTEREST Granting a renewal of the exemption from FAR 91.315 to Stallion 51 is in the public interest. At the time of its11 original Petition for Exemption, and again at the time of its previous Petitions for Renewal of Exemption, Stallion 51 contended that, other than its operations, aircraft capable of adequately training individuals to operate high performance propeller driven fighter aircraft are not available. This remains true today. Clearly, instruction is available in two

place lower performance former military trainers, but these do not offer the same performance characteristics and, thus, the transfer of skill the TF

- 51 offers. More importantly, aircraft certificated in the Standard Airworthiness Category are not capabl e of performing this training. The TF

- 51 Mustang is particularly ideal for providing this training mission. Many of the civilian flown warbird fighter aircraft are P

51 Mustangs. Commonly, insurance companies require training in
the TF
- 51 Mustang prior to offering insurance to new P

- 51 Mustang pilots. Without this training, many pilots would be unable to obtain adequate insurance. Without doubt, it is in the public interest for Stallion 51 to be able to provide this required training, which qualifies c ivilian warbird pilots for adequate insurance coverage. Of greater importance is the fact that through the Stallion 51 training program, pilots receive
tr aining that enables them to operate their aircraft safely whether in solo flight or with a passenger. The need for this12 training has been illustrated in a study conducted on civil pilot accidents in high performance military surplus aircraft.
See Exhibit B. There is a unique potential inherent to utilization of the
TF - 51 Mustang for various training o perations, including the Unusual Attitude and Upset Recovery training, which are forms of training not equivalently available in standard category certificated aircraft. T he TF
- 51 thus serves as an excellent training aircraft for pilots who fly the Spitfir e, Corsair, Bearcat, P
- 47, and other fighter aircraft. Considering the minimal pilot qualifications which are required to fly the Mustang or other fighters under the FARs 2 , participation in Stallion 51's training program, which is often a condition preced ent to obtaining liability and hull insurance, provides an essential service to the aviation community and promotes safety in air commerce.
T hrough May 2015, Stallion 51 has provided training and aircraft familiarization to over 9,000 individuals in variou s fields including: (1) Initial Checkouts; (2) Recurrent Training; (3) Unusual Attitude and upset training; (4) Orientation

2 Under the FARs, a stu dent pilot with complex, tail wheel, and high performance aircraft endorsements can act as Pilot in Command of a limited category P
- 51 Mustang. Additionally, a private pilot would be allowed to fly passengers in a P

- 51 Mustang with no more training than i s required to obtain the private pilot certificate. Other than requirements set by the insurance companies, no specific training program or letter of authorization is required to act as pilot in command of a limited category P

- 51 Mustang.13 Flights; (5) Military Test Pilot Training; and (6) Types specific Formation & Aerobatic Training. The fact that so many individuals have reached out and participated in the training demonstrates the need and the public’s interest in its availability. Finally, in addition to the enhancement of the public interest through Stallion 51's training activities, there is an indirect benefit to the general public through Stallion 51's participation in airshows around the country. The FAA has previously recognized the public interest in the operation of historic military aircraft. Utilizing the TF

- 51, Stallion 51 has attended numerous airshow s over the years. In the past 10
years , Stallion 51 has attended and participated in over one hundred ( 100) air shows, approximately seven of which occurred in the past two years since the last Petition for Renewal Of Exemption. Most recently, Stallion 5 1 attended airshows in: Lakeland, FL

– April 2014 Jacksonville, FL

– October 2014 Stuart, FL
– October/November 2014 Melbourne, FL

– March 2015 Tuscaloose, AL

– March 2015 Tyndall AFB, FL

– April 2015 Lakeland, FL

– April 2015 At these airshows, Stallion 51 performs various maneuvers in the TF

- 51 including low level flight maneuvers such as vertical rolls, barrel rolls, point rolls, inverted passes,14 Cuban 8 loop, and a break to landing. Considering the significance of the P

- 51 Mustang in World War II, th e public's interest in seeing this aircraft perform is obvious. On April 7

- 10, 1999, Stallion 51 hosted and sponsored the "Gathering of Mustangs and Legends" at its Kissimmee, FL facilities. Sixty

- five Mustangs were flown to the event representing about forty percent of the known flyable Mustangs in the world. The Gathering of Mustangs and Legends brought together not only many of the great Mustang Pilots such as Chuck Yeager, Bud Anderson, Bob Hoover, Robin Olds, Lee Archer, Frank Borman, and Bill Ander s, but also assembled individuals with considerable knowledge concerning aircraft performance, maintenance, aerodynamics, and flying safety. The primary goal of this event was education. Subjects covered included formation flying, spin/loss of control flight, airframe and maintenance panel discussions, flight physiology, engine

- out glide performance, see Exhibit #2, engine maintenance panel discussions, and an operational safety overview. The seminars were well attended by the FAA, NTSB, and numerous i nsurance companies. On September 27

- 30, 2007, Stallion 51 hosted and sponsored a second the Gathering of Mustangs and Legends in Columbus, Ohio. Even more mustangs were flown to this event, with 80 in attendance and another 20 blocked by15 either weather o r mechanical and schedule difficulties. Many of the same great pilots also returned, along with a variety of
others. Stallion 51 has also hosted other historical and educational events similar to the "Gathering of Mustangs and Legends." In March 2002 , Stallion 51 hosted the 352nd Fighter Group Reunion. This event was taped for broadcast by the Public Broadcasting Service (PBS). In October 2010, Stallion 51 again hosted the 352nd Fighter Group Reunion. Additionally, Stallion
51 has participated in v arious television shows about the history of the P

- 51 airplanes. Stallion 51 intends to continue participating in and hosting similar events for public benefit in the future. In addition to and as part of airshows, Stallion 51 participates in the USAF H eritage Flight Program. In 1997, USAF Heritage single

- ship aerial demonstration teams began flying formation flights with civilian warbirds as part of its celebration of fifty years as a separate service. The USAF Heritage Flight Program features histori c aircraft such as the
P - 47 and P
- 51, flying with A

- 10, F
- 15, F
- 16, F
- 22 and F4 demonstration jets at air shows across the country. The response at public events was overwhelming and a formal program soon followed. USAF holds an annual Heritage Flight16 Training and Safety Conference. The second year, the conference was held in conjunction with the "Gathering of Mustangs" in Kissimmee. The Air Force considers the USAF Heritage Flight Program an important part of its recruiting and retention
efforts. At the time of the initial Petition for Renewal of Exemption, Stallion 51 had been a major participant in the USAF Heritage Flight Program and had flown twenty formation demonstrations with Air Combat Command Jet fighters. Stallion 51 has continued its part icipation in this important educational
program and as of May 2015, has flown in over 255 formation demonstrations. Stallion 51 also participates in the International Test Pilot School (ITPS) training for students and instructors, providing flight test tr aining and qualitative evaluation to civil and military customers alike. In the past four years

s ince beginning involvement with ITPS, Stallion has participated in approximately 15 sorties , further demonstrating Stallion 51’s contribution to the public ’s interest in renewing the exemption . LEVEL OF SAFETY A Petition for Exemption can say much concerning a plan to provide an equivalent level of safety, but Stallion 51's recor d represents the ul timate proof: after 2 8 years of extensive fligh t operations and over 16 ,000 hours of operating the TF

- 5117 Mustang, Stallion 51 has a flawless safety recor d. This record is possible because all training is conducted in a manner that is equivalent to, and generally exceeds, the requirements of the
FARs.
B etween the time of the initial grant of exemption (September 30, 1998) and the 2002 Petition for Renewal of Exemption (July 30, 2002), Stallion 51 flew nearly 2 , 000 hours without incident. Between the 2002 Petition for Renewal of Exemption and the 2005 Pe tition for Renewal of Exemption, Stallion 51 flew about 1 , 500 hours without incident; another approximately 1,000 hours without incident between the 2005 and the 2007 Petitions for Renewal of Exemption; 1,000 between the 2007 and 2009 Petitions; 1,000 betw een May 2009 and the 2011 Petition ; and approximately 2,500 between the May 2011 and the 2013 petition . Stallion 51 has continued to demonstrate its commitment to safety by improving its excellent safety record with 1,000 addition al flying hours since May , 2013 , all incident free. These hours are comprised of various forms of training, demonstration, and ferrying including: (1) orientation flights; (2) recurrent training; (3) initial checkouts; (4) air shows; (5) military test pilot training; (6) maintena nce and ferry flights; and (7) unusual attitude and upset training.18 There are a number of safety practices that have contributed to Stallion 51's impeccable safety record. Each month a safety stand
- down is scheduled. On this day, mandatory safety meetin gs are held and pilots discuss safety issues relating to ground and flight operations. Reviewed at the meeting are any recent incidents or mishap s in the warbird community, changes to local operations, and a discussion concerning a designated "emergency o f the month." Minutes are taken and entered in the "Operations Read File," which is made available to all personnel as a review and reference source. This manual contains additional information such as changes to taxi routes, closed runways, and other in formation critical to the safe operation of Stallion 51's aircraft. Stallion 51 also
holds Safety Briefs with the Tower Chief and ATC Safety Personnel, at which relevant operation and safety procedures are covered and reviewed. These briefs are held appr oximately 4 times each year and attended by Stallion 51’s Chief Instructor and other pilots. Stallion 51 does not believe that safety is enhanced only through the accumulation of numerous flight hours. The Stallion 51 philosophy is that safety is enhanced by constantly reviewing the standardization of operations and instruction. An in

- flight video is recorded during all training operations. This video19 runs from engine start to stop, and is utilized as a training aid not only for the student, but also for each of the instructor pilots. These videos are periodically reviewed by the Chief Instructor to ensure standardization and compliance with Stallion 51 procedures. At the advice of its safety consultant, Stallion 51 implemented an additional safety preca ution. Stallion 51 also videotapes selected air shows in which it participates. These videos are then reviewed and referenced to ensure operating practices are adhered to, as well as to provide a method of post
- performance air show critiques. The traini ng provided by Stallion 51 has unquestionably made a very large impact upon the reduction of P

- 51 accidents and incidents. The petitioner has been honored with recognition such as the Warbirds Worldwide Editor's Award for "outstanding contributions toward s flight safety and warbird operations worldwide." In 2013, Chief Instructor Lee Lauderback was inducted into the Experimental Aircraft Association (EAA ) Warbird Hall of Fame. As an FAA

- recognized industry leader in

ae robatic competency in warbird aircraf t, EAA Warbirds of America’s recognition of Mr. Lauderback’s training and safety is speaks particularly highly of the safety standards utilized by
Mr. Lauderba ck in Stallion 51’s operations. Additionally,20 Stallion 51 is recognized by virtually every major aircraft insurance company and is known in the insurance industry as the "Flight Safety of High Performance Fighter Aircraft." Stallion 51’s excellent safety record is enhanced by a
well
- organized maintenanc e program. Stallion 51 employ s a Director of M aintenance who oversees the program, working one on one with the people and companies performing the maintenance.
The TF
- 51 Mustangs are maintained in accordanc e with Subpart E
of FAR Part 91 as it applies to aircraft which are operated for hire. All airc ra ft receive an annual inspection and one hundred hour inspections pursuant to United States Air Force Technical
Order 1F
- 51A
- 6. See Exhibit C. All maintenance procedures are conducted in accordance with United States Air Force Technical
Order 1F
- 51D
- 2. S ee Exhibit D. Additional maintenance guidance is obtained through utilization of the Cavalier Mustang F

- 51D maintenance instructions manual. See Exhibit E. The United States Air Force Flight Operating Instructions Handbook, AN 01
- 60JE
- 1, is utilized for aircraft operations.
See Exhibit H. Prior to training, Stallion 51 instructors request each student to acknowledge in writing that they will be receiving flight instruction in an aircraft that is certificated in the limited category. Each student al so acknowledges that they are a crewmember and capable of performing the operational21 and safety related tasks which are covered in the pre

- flight briefing. All flight operations are conducted by certified flight instructors wh o cumulatively possess over 15 ,5 00 hours of operational experience in the P

- 51 and TF
- 51 Mustang. The Chief Instructor is Lee C. Lauderback. Mr. Lauderback is a graduate of Embry
- Riddle, Daytona with a degree in Aeronautical Science and Business Management. He has been the chief fli ght instructor since Stallion 51’s inception, amassing over 21 ,000 flight hours in all types of aircraft, including over 9,000 hours in the Mustang. He is a certified single and multi

- engine flight and ground instructor, holds an Airline Transport Pilot

c ertification as well as instrument, helicopter and glider ratings. His expertise and vast experience in both corporate and private aviation has earned him the distinction of being an FAA Examiner. Mr. Lauderback is often called upon to flight test variou s Vintage planes, helicopters , and Turbojets before they are accepted. In addition to instructing Stallion 51 flight operations, he performs at air show s in his signature solo Mustang, participates in the USAF Heritage Flight program as civilian lead in t he Mustang , and instructs for the Navy Test Pilot School at Patuxent River, MD. In November 2013,
Mr. Lauderback was inducted i nto the EAA Warbird Hall of Fame .22 Additionally, Stallion 51 employs a full

- time Flight Surgeon on staff, Dr. William T. Busch, Captain, United States Navy (retired). Stallion 51 is likely t he only civilian operator of it s kind to do so. Dr. Busch is a Senior AME and a HIMS Independent Medical Sponsor. Prior to retiring from the Navy after 29 years of military service, Dr. Bus ch was head of the Navy Aero
- Medical Dual

- Designator Program while flying as a current Naval Aviator and serving as the senior flight surgeon at Naval Air Station Jacksonville. Dr. Busch also served as the Chairman of Ophthalmology at Naval Hospital Camp Lejeune, and Chairman of the Navy Aerospace Medicine Institute in Pensacola, Florida. Dr. Busch has accumulated over 5 , 200 flight hours and logged time in over 30 different types of military aircraft. He
has over 1 , 000 hours in WWII era vintage aircraft and hundreds of aircraft carrier landings. Stallion 51 is confident that it has demonstrated that it has established an appropriate level of safety to support the granting of this exemption.
RELIEF SOUGHT In this petition and in its operations, Stallion 51 has illustrated that it is in the public interest in aviation safety for the FAA to grant this Petition to renew the Grant of Exemption from FAR §91.315. The training that Stallion 5123 offers to civilian and military pilots through its various forms
of instructional flights supports and exceeds the safety standards set by the FAA and it is in the public interest and the interest of safety to continue that effort. Additionally, the indirect benefit provided to the general public, concerning
the role of the P
- 51 aircraft in our country's history, through Stallion 51's participation in airshows around the country is substantial. Stallion 51's excellent safety record also illustrates that Stallion 51 exceeds the required equivalent level of safety. Specifi cally, Stallion 51's self

- imposed safety measures, such as mandatory safety stand
- down days, constant review of standardization of operations and instruction, and utilization of in

- flight videos, enhance safety. In addition, Stallion 51 frequently updates its training syllabus to ensure aviation safety. Further, the use of military maintenance Technical Orders (TO's) provides a sound foundation for Stallion 51's safety program. Finally, the high experience level of Stallion 51's chief instructor is a k ey element in the safety considerations relevant to the granting of this exemption. Considering the overriding public interest in the continuation of the training provided by Stallion 51, the safety measures which have24 contributed to Stallion 51's excelle nt safety record, and the commitment that Stallion 51 has demonstrated toward maintaining safe operations, Stallion 51 requests that Exemption No. 6811 from FAR § 91.315, originally issued by the FAA on September 17, 1998, renewed as Exemption No. 6811A on September 8, 2000, as Exemption No. 6811B on September 4, 2002, as Exemption No. 8593 on August 1, 2005, as Exemption No. 8593A on July 23, 2007 , as Exemption No. 8593B on July 20, 2009, as Exemption No. 8593C on July 14, 2011, and most recently a s Exempt ion No. 8593D on July
29 , 2013, once again be renewed with an extended termination
date.
STALLION 51 CORPORATION Lee C. Lauderback President/Chief Pilot By: /s/ Kathleen A. Yodice Kathleen A. Yodice Counsel to Stallion 51 Corporation Law Offices of Yodice Associates 411 Aviation Way, Suite 245 Frederick, MD 21701 301
- 695
- 2300 301
- 695
- 2151 (facsimile)

Dated: June 18 , 2015