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 A

24B S/N 42

- 54682 N93RW , an d for relief of 91.319(a) since the A

- 24 is an experimental category aircraft.

To Whom It May Concern: Enclosed is a n amendment to exemption 14580 to add the A

- 24B and seek relief from 91.319(a) since the A

- 2 4 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 L SFM’s B

- 17 and B

- 25 are limited category aircraft.

Very Truly yours,

Larry J. Gregory President & COO Lone Star Flight MuseumTO: 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 77552PETITION 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) e xemption number 14580. The LSFM requests the addition of our Douglas A

- 24B, S/N 42

- 54682, N93RW to our LHFE exemption which currently c overs 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.
R EASON FOR PETITION The LSFM currently holds an LHFE exemption and operates its B

- 17 and B

- 25 aircraft under the require ments contained therein . We wish to add the A

- 24 to our exemption to provide flight experiences in this historic aircraft. Only qualifi ed 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 orde rs. 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 ha s 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 safet y 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 th e 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 aircraf t 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 exp erience 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 w ho 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 reg u larly 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 n o longer in military service

 Fragile

– Only five A

- 24 /SBD aircraft are operational

.

 Age (the A

- 24 was built in 1942 )

 No standard cat egory 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 develope d 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 Prog ram(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 on

condition inspection program for such parts.

 Aging aircra ft 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 , 201 7 By:

_ _______________________________________________ Larry J. Gregory, President Lone Star Flight Museum P.O. Box 3099 2002 Terminal, Dr. Galveston, TX 77552