February 15, 2017

VIA ELECTRONIC SUBMISSION

The Rules Docket (AGC 200)

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC. 20591

Re: Petition from the Lone Star Flight Museum for an amendment to exemption 14580 to add Douglas A24B S/N 42-54682 N93RW, and for relief of 91.319(a) since the A-24 is an experimental category aircraft. 

To Whom It May Concern:

Enclosed is an amendment to exemption 14580 to add the A-24B and seek relief from 91.319(a) 

since the A-24 is an experimental category aircraft. The Lone Star Flight Museum’s (LSFM) existing 

exemption 14580 currently provides relief from Federal Aviation Regulations 91.9, 91.315, 119.5(g), and 

119.21(a) for the operation of our B-25 and B-17 aircraft. The LSFM’s B-17 and B-25 are limited category 

aircraft. 

Very Truly yours,

 

Larry J. Gregory

President & COO

Lone Star Flight Museum
TO: The Rules Docket (AGC 200)

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC. 20591

PETITION FOR AN AMENDMENT TO THE LONE STAR FLIGHT MUSEUM’S LIVING HISTORY 

FLIGHT EXPERIENCE EXEMPTION NUMBER 14580 TO ADD THE DOUGLAS A-24B AIRCRAFT 

(N93RW S/N 42-54682) AND SEEK RELIEF FROM 91.319(A) SINCE THE AIRCRAFT IS IN THE 

EXPERIMEMTAL CATEGORY.

PETITIONERS: LONE STAR FLIGHT MUSEUM

P.O. BOX 3099

2002 TERMINAL DR.

GALVESTON, TX 77552
PETITION SUMMARY

The Lone Star Flight Museum (LSFM), a § 501(c) (3) non-profit educational museum, requests 

consideration for an amendment to its Living History Flight Experience (LHFE) exemption number 14580. 

The LSFM requests the addition of our Douglas A-24B, S/N 42-54682, N93RW to our LHFE exemption 

which currently covers our B-17 and B-25. We also seek relief from 91.319(a) since the A-24 is an 

experimental category aircraft. The A-24, more commonly known as an SBD Dauntless, was the leading 

scout bomber in the U.S. Navy fleet when World War II began in 1941. The Dauntless earned its place in 

history at the Battle of Midway and served throughout the war. Today, only five examples are airworthy. 

The LSFM wishes to provide historical flight experiences in the A-24 aircraft to its members and the 

general public. 

REASON FOR PETITION

The LSFM currently holds an LHFE exemption and operates its B-17 and B-25 aircraft under the 

requirements contained therein. We wish to add the A-24 to our exemption to provide flight experiences 

in this historic aircraft. Only qualified airmen are utilized in our LHFE flight operations, and each is 

required to participate in initial and recurrent flight and ground training. Aircraft maintenance is performed

pursuant to the applicable regulations and appropriate military technical orders. We will update our 

operations and maintenance manuals included in our original petition to include the pertinent information 

regarding the A-24. The LSFM completed a three-year restoration of the A-24 in 1997 to award-winning 

standards. The A-24 has flown regularly and our maintenance personnel are very familiar with the 

aircraft. It is very similar in terms of technology and systems to the B-17 and B-25 as well as other aircraft 

in our collection. As per our original petition, the LSFM’s Safety Management System (SMS), General 

Operations Manual, Pilot Qualifications and Training Manual and a General Maintenance Manual will

provide enhanced safety measures to insure an equivalent level of safety for the public.
PUBLIC INTEREST

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented herein. In each case, the FAA found that preserving historic U.S. aircraft is in the public 

interest, in the same manner that preserving historic buildings, landmarks, and neighborhoods, has been 

determined to be in the public interest. While the aviation history can be represented with static displays 

in museums in the same manner that historic landmarks can be represented in museums, the public has 

shown a willingness to support the preservation and operation of historic aircraft and a desire to 

experience flights in them. The FAA has previously approved the SBD/A-24 type to operate in the LHFE 

program. Based upon that recognition and the assurances of safety set forth by the LSFM in this Petition 

for Exemption, the scope of §§ 91.9, 91.315, 91.319(a), 119.5(g), and 119.21(a), specific to the operation 

of the LSFM B-25, B-17 and A-24 aircraft, does not set a precedent with the FAA.

EQUIVALENT LEVEL OF SAFETY

The LSFM is committed to the safe operation of the B-25, B-17 and A-24 aircraft. All aircraft 

underwent a detailed restoration process prior to return to service. In order to preserve these aircraft to 

their restored condition, we maintain these aircraft at a level that meets or exceeds the regulations. FAA 

Approved Inspection Programs have been established for the B-17 and B-25 for nearly three decades, 

and we have operated the A-24 since 1997. Appropriate military tech orders are also included in the

maintenance of the aircraft in order to assure safe operation.

Operational safety issues are a prime concern to the LSFM. The LSFM has developed an SMS

to foster and maintain a proactive safety culture. All pilots are required to meet or exceed the experience 

and training requirements specified in our operations manual system. All flight operations, ground and 

flight training are conducted in accordance with the Flight Manuals for the aircraft as well the LSFM 

General Operations Manual and Pilot Qualifications and Training Manual. 

The implementation of our manual systems which includes, the enhanced pilot training syllabus 

and the maintenance training requirements, demonstrate the requisite equivalent level of safety provided 

to individuals who participate in a flight experience and/or dispersal of cremated human remains in all 

aircraft. The LSFM realizes these manuals are living documents and will regularly undergo a revision 

process as we operate in the future. AFS-830 has a copy of these documents on file.
The following summarizes LSFM’s Equivalent Level of Safety (ELoS) in that it meets or exceeds 

the requirements of the FAA policy published on July 21, 2015:

A. The A-24 is “Historically Significant”:

 US Operated

 The A-24 is no longer in military service

 Fragile – Only five A-24/SBD aircraft are operational.

 Age (the A-24 was built in 1942)

 No standard category aircraft exists for this type.

B. Designation of a Responsible Person and Operational Control Structure

 The designations are found in the General Operations Manual.

C. Safety & Risk Analysis

 Operational safety issues are a prime concern to the LSFM. The LSFM has 

developed a Safety Management System (SMS) to foster and maintain a proactive 

safety culture.

D. Manual System

• LSFM has developed a manual system similar in terms of intent and scope of those 

in 14 CFR Part 135 to include:

o LSFM General Operations Manual (GOM)

o LSFM Pilot Qualifications and Training Manual

o LSFM SMS Manual

o LSFM General Maintenance Manual.

o LSFM Approved Inspection Program(AIP) including, but not limited to:

 Review of previously approved AIPs as provided by 14 CFR 91.415

 Maintenance training elements.

 Replacement plan for time-limited parts or development of an oncondition inspection program for such parts.

 Aging aircraft inspection program.

 Corrosion inspection program.
 Continued Operational Safety (COS).

E. LSFM prohibits the following for LHFE flight operations, as stated in the General Operations 

Manual:

 Flight training

 Aerobatics

 Passenger manipulation of the flight controls.

 Formation flights

 Skydiving

Based upon the foregoing, the LSFM requests the FAA to grant our amendment petition for the

operation of its A-24 aircraft.

LONE STAR FLIGHT MUSEUM

Dated: February 15, 2017 By:________________________________________________

Larry J. Gregory, President

Lone Star Flight Museum

P.O. Box 3099

2002 Terminal, Dr.

Galveston, TX 77552