Law Offices of Yodice Associates 411 Aviation Way, Suite 245 Frederick, MD 21701
THROUGH U.S. DEPARTMENT OF TRANSPORTATION DOCKET MANAGEMENT SYSTEM
-- WWW.REGULATIONS.GOV June 22, 2013

Federal Aviation Administration c/o U.S. Department of Transportat ion 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. 8593C Regulatory Docket No. FAA
- 2002
- 12993 Enclosed is our petition to renew Exemption No. 859 3C 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 y ears operated their aircraft at a more than equivalent level of safety without incident and without any compromise to aviation safety. There has not been any significant change to the reasons relative to the public interest and safety that were the basi s for granting the original exemption, nor is there any need to change the conditions and limitations contained in the original grant of exemption. Therefore, we respectfully request that the Exemption No. 8593C be renewed in its current form and that its effectiveness be extended until July 31, 2015. 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
Enc losure2 TO: U.S. Department of Transportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12
- 140 Washington DC 20590

PETITION FOR RENEWAL OF EXEMPTION FROM FEDERAL AVIATION REGULATION SECTION 91.31 5 FOR THE OPERATION OF THE STALLION 51 CORPORATION'S NORTH AMERICAN TF
- 51 MUSTANGS

Petitioner: Stallion 51 Corporation 3951 Merlin Drive Kissimmee, FL 34741

Dated: June 28 , 20133 PETITION SUMMARY The Stallion 51 Corporation seeks a renewal of FAA Exemption No. 8593C (Regulatory Docket No. FAA

- 2002
- 12993). Specifically, Stallion 51 seeks the renewal of its exemption from Federal Aviation Regulation (FAR) Section 91.315 for the operation of its North American TF

- 51 Mustangs. Stalli on 51's Mustangs are currently certificated in the limited category. Stallion 51 wishes to continue providing various types of training in its aircraft, and will do so with a level of safety that exceeds what is required by the regulations.
REASONS FOR PE TITION Since April of 1987, Stallion 51 has operated TF

- 51 aircraft. The original TF

- 51, when purchased, possessed a standard airworthiness certificate. However, after approximately three years of operation, the FAA determined that it made an error in i ssuing the certificate, and a limited category special airworthiness certificate was issued. Although FAR §91.315 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 the FAA that since the TF

- 51 has dual cockpits and fully functional4 dual controls, and the trainee is a cr ewmember and not a passenger, the regulation would not apply. In the late 1990's, the increased use of aircraft 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 discussed 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 instructions, a maintenance program conducted in accordance with the FARs, and a highly trained staff of Certified Flight Instructors, including an exceptiona lly qualified Chief Pilot and full time Flight Surgeon, who conduct training in a manner that meets or exceeds the requirements of the FARs. Stallion 51’s incomparable operations warrant exceptional treatment, justifying the continued exemption from FAR 9 1.315 without additional conditions or limitations.5 BACKGROUND Stallion 51 operates three dual

- cockpit, dual

- 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 contracts, initial/recurrent training, unusual attitude training, types specific formation and aerobatic training, and orientation flights. Stallion 51 does not seek to provide air transportation for compensation or hire in its TF

- 51 aircraft. The relief sought under this Petition for Renewal of Exemption is for the sole purpose of providing training in the aircraft, as further described in this petition . Among the many different forms of training offered by Stallion 51 is the Unusual Attitude and Upset Recovery training, a form of training not equivalently available in standard category certificated aircraft. In regard to this Petition, it is interesti ng to note that the FARs allow a student pilot with complex, tail wheel, and high performance aircraft endorsements to act as pilot in
command of the P
- 51 Mustang. Additionally, a private pilot would be allowed to fly passengers in a P

- 51 Mustang with no more training than is required to obtain the private pilot certificate. Other than requirements set by the insurance companies, no specific training program or letter of6 authorization is required to act as pilot in command of a limited category P

- 51 Musta ng. The foregoing discussion is relevant to this Petition for two specific reasons. First, based upon financial, insurance, and experimental concerns, it would be a very rare case where a student pilot or low

- time private pilot would act as pilot in

comm and of a P
- 51 Mustang. However, such a scenario does illustrate that the training provided in Stallion 51 orientation flights does not differ significantly from similar training provided to student or private pilots in a complex aircraft possessing a stan dard airworthiness certificate. Second, there is a unique potential inherent to utilization of the TF

- 51 Mustang for various training operations, including the Unusual Attitude and Upset Recovery training. In 1998, Stallion 51 petitioned the FAA for a gr ant of exemption from FAR §91.315. Recognizing that the services provided by Stallion 51 are in the public interest, the FAA granted Stallion 51's request on September 17, 1998 and issued Exemption No. 6811. On June 22, 2000, Stallion 51 petitioned
the F AA for a renewal of Exemption No. 6811. The FAA determined that the justifications for issuing the original exemption remained valid and granted a renewal of the exemption, by letter dated September 8, 2000, and issued Exemption No. 6811A. On July 22, 20 02, Stallion 51 again petitioned the FAA for a7 renewal of Exemption No. 6811A, which the FAA granted on September 4, 2002, and issued 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 Petition as a new request for exemption. The FAA granted the request for exemption and issued Exemption No. 8593 in a letter da ted August 1, 2005. Stallion 51 filed a Petition for Renewal of Exemption On June 7, 2007. The FAA granted the petition and issued Exemption No. 8593A in a letter dated July 23, 2007. On May 21, 2009, Stallion again petitioned for Renewal of Exemption, which the FAA granted on July 20, 2009 and issued Exemption No. 8593B. This exemption is set to expire on July 31, 2011.
INTERESTS OF THE PETITIONER Stallion 51 operates three of only sixteen known TF

- 51 Mustangs in existence in the world. Stallion 51 o perates these trainers at a level that meets, and generally exceeds, military 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 condi tions. 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.8 See Exhibit A (attached to original Petition for Exemption). 1 The training covers such issues as aircraft systems, normal and abnormal procedures, basic flight maneuvers, slow and high performance maneuvering, stalls and spins, and 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. Also, recurrent training is offered for those who successfully complete initial training, as well as for pilots of other high performance aircraft. Recurr ent training, depending upon the pilot's skill level, can vary from one to three flights. The program provides an intensive review of aircraft systems, procedures and various flight maneuvers, as well as introducing the latest safety materials available r elative to the operation of the aircraft. Another essential element of the Stallion 51 training program consists of orientation training flights. These flights are conducted under the same and equivalent safety standards as initial/recurrent training; ho wever, completion of the dual training syllabus is not envisioned, nor is it expected that the student will perform at a level consistent with the standards for a type rating. Orientation flights are offered to

1 Cites to "lettered" exhibits were attached to the original Petition for Exemption and are not attached hereto. They can be provided upon request if necessary. Cites to "nu mbered" exhibits were attached to the June 20009 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 operators, airline pilots seeking unusual attitude recovery training, and even individuals who are currently student pilots, or m ay 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 operat ion is the service it has provided through military contracts. For the majority of the past twenty six (26) years, except for a few years during which lack of funding 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 training provided test pilot students and staff with military qualitative evaluations. Utilization of the TF

- 51 Mustang is a 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 Pilot School, a school that provides flight test services and training to civil and military customers from around the world. Wh en Stallion 51 first petitioned the FAA for its exemption, approximately five hundred (500) training flights had been

Petition for Renewal of Exemption. They can also be provided upon request if necessary.10 conducted for the military. That number now stands at approximately six hundred fifty (650 ). 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 Training" to the curriculum. See Exhibit #1 (attached to the June 2000 Petition for Renewal of Exemption). Stallion 51 has su ccessfully 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 le vel 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 pilot's initial pilot training. One shortcoming of this traini ng 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 attitude," 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 p otential for the aircraft to be "upset" from11 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 t hat: 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 normal 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 i s being controlled by automatic flight control systems, and unusual attitudes that result from flight control malfunctions and uncommanded flight control surface movements. See NTSB Recommendations 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 replicate any possible flight condition. Because an equivalent level of unusual attitude and upset recovery training is not readily available in standard category certificated aircraft, Stallion12 51 provides a service that may otherwise be unavailable to a pilot. 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. Stallion 51 seeks to continue these training activities in full compliance with the FARs, as it has done so for the pa st 15 years. Accordingly, Stallion 51 requests a renewal of the Grant of Exemption No. 8593B 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 its original Petit ion 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 air craft 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. M ore importantly, aircraft certificated in the Standard Airworthiness Category are not capable of performing this training. The TF

- 51 Mustang is particularly ideal for providing this training mission.13 Through May 2013, Stallion 51 has provided training an d aircraft familiarization to over 8000 individuals in various fields including: (1) Initial Checkouts; (2) Recurrent Training; (3) Unusual Attitude and upset training; (4) Orientation Flights; (5) Military Test Pilot Training; and (6) Types specific Forma tion & Aerobatic Training. 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 pil ots would be unable to obtain adequate insurance. Without doubt, it is in the public interest for Stallion 51 to be able to provide this training, which qualifies civilian warbird pilots for adequate insurance coverage. Of greater importance is the fact that through the Stallion 51 training program, pilots receive required training, which enables them to operate their aircraft safely whether in solo flight or with a passenger. The need for this training has been illustrated in a study conducted on civil pilot accidents in high performance military surplus aircraft.
See Exhibit B (attached to original Petition for Exemption). In addition to the training necessary for future P

- 51 pilots, the TF

- 51 also serves as an excellent training aircraft for pilots who fly the Spitfire, Corsair, Bearcat, P

- 47, and other fighter aircraft. Considering the minimal pilot14 qualifications which are required to fly the Mustang or other fighters under the FARs, participation in Stallion 51's training program, which is often a condition precedent to obtaining liability and hull insurance, provides an essential service to the aviation community and promotes safety in air commerce. Finally, in addition to the enhancement of the public interest through Stallion 51's training act ivities, 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, Sta llion 51 has attended numerous airshows over the years. Since November 2004, Stallion 51 has attended and participated in over one hundred (100) air shows, approximately 16 of which occurred in the past two years since the last Petition for Renewal Of
Exe mption. Most recently, Stallion 51 attended airshows in: Caldwell, ID

– June 2011 Driggs, ID

– July 2011 Tacoma, WA
– July 2011 Great Falls, MT

– July 2011 USAF Academy, CO

– September 2011 MacDill AFB, FL

– November 2011 Pensacola, FL

– November 2011 Lake land, FL

– March
- April 2011 Robins AFB

– April 2012 Driggs, ID

– June 2012 McChird AFB, VA

– July 2012 Cocoa Beach, FL

– September 2012 Pensacola, FL

– November 2012 Stuart, FL
– November 2012 Lakeland, FL

– April 2013 Polk City, FL

– May 201315 At these a irshows, Stallion 51 performs various maneuvers in the TF

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

- 51 Mustang in World War II, the 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

re presenting 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
Borma n, and Bill Anders, 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 (attached to the June 2000 Petition for Renewal of Exemption), engine maintenance panel discussions, and an operational saf ety overview. The seminars were well attended by the FAA, NTSB, and numerous16 insurance 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 by either weather or mechanical and schedule difficulties. Many of the same great pilots also returned, along with a variety of others. Stallion 51 is currently planning another such Gathering o f Mustangs and Legends. 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. Stallion 51 has also participated in various television shows about the history of
the P
- 51 airplanes. In addition to and as part of airshows, Stallion 51 participates in the USAF Heritage 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
H eritage Flight Program features historic aircraft such as the
P - 47 and P
- 51, flying with today's A

- 10, F
- 15, F
- 16, F
- 22 and F4 demonstration jets at air shows across the country.17 The response at public events was overwhelming and a formal program soon f ollowed. USAF holds an annual Heritage Flight 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 pa rt 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 Je t fighters. Through May 2011, Stallion 51 has continued its participation in this important educational program by flying in an additional 225 formation demonstrations, bringing its formation flight total to
245. Since the last Petition, Stallion 51 has also participated in the International Test Pilot School.
SAFETY ISSUES After twenty
- six years of extensive flight operations, and over 15,000 hours of operating the TF

- 51 Mustang, Stallion 51 has a flawless safety record. A Petition for Exemption can say much concerning a plan to provide an equivalent level of safety, but Stallion 51's record represents the ultimate proof. This record is possible since all training is conducted in a manner18 that is equivalent to, and generally exceeds, the requirements
of the FARs. Between 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 2000 hours without incident. Between the 2002 Petition for Renewal of Exemption a nd the 2005 Petition for Renewal of Exemption, Stallion 51 flew about 1500 hours without incident; 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; and a nother 1,000 between May 2009 and the 2011 Petition. Stallion 51 has continued to demonstrate its commitment to safety by improving its excellent safety record with about 2,500 additional flying hours since June, 2011, incident free. These hours are comp rised 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) maintenance and ferry flights; and (7) unusual attitude and upset training. 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 meetings are held and pilots discuss safety issues
rel ating to ground and flight operations. Reviewed at the19 meeting are any recent incidents or mishaps in the warbird community, and changes to local operations, and a discussion concerning a designated "emergency of 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 information critical to the safe operation of Stallion 51's aircraft. Additionally, since the last Petition, Stallion 51 has implemented 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. Further, during all training operations, an in

- flight video is recorded. This video runs from engine start to stop, and is utilized as a training aid not only for the student, bu t 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.20 At the advice of its safety consultant, Stallion 51 implemented an additional sa fety precaution. 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 training 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 contributi ons towards flight safety and warbird operations worldwide." Additionally, 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." Certainly, the excellent safety record is enhanced by a
well
- organized maintenance program. Stallion 51 employees a Director of Maintenance who oversees the program, working one on one with the people and companies performing the maintenance.
The TF
- 51 Mu stangs are maintained in accordance with Subpart E of FAR Part 91, as it applies to aircraft which are operated for hire. All aircraft receive an annual inspection, and one hundred hour inspections pursuant to United States Air Force Technical Order 1F

- 51 A - 6. See Exhibit C (attached to original21 Petition for Exemption). All maintenance procedures are conducted in accordance with United States Air Force Technical
Order 1F
- 51D
- 2. see Exhibit D (attached to original Petition for Exemption). Additional main tenance guidance is obtained through utilization of the Cavalier Mustang F

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

- flight briefing. All flight operations are conducted by c ertified flight instructors who cumulatively possess over 15,000 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 flight instructor since Stallion 51’s inception, amassing over 20,000 flight hours in all types of aircraft, including over 9,00022 hours in the Mustang. He is a certified single and multi

- engine flig ht and ground instructor, holds and Airline Transport Pilot certification 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 Examine r. Mr. Lauderback is often called upon to flight test various Vintage planes, helicopters and Turbojets before they are accepted. In addition to instructing Stallion 51 flight operations, he performs at air shows in his signature solo Mustang and partici pates in the USAF Heritage Flight program as civilian lead in the Mustang. Mr. Lauderback also instructs for the Navy Test Pilot School at Patuxent River, MD. Additionally, Stallion 51 employs a full

- time Flight Surgeon on staff, Dr. William T. Busch, Captain, United States Navy (retired). Stallion 51 is likely the only civilian operator of this 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 P ensacola, Florida. Dr. Busch has accumulated over 5200 flight hours and23 logged time in over 30 different types of military aircraft. He has over 1000 hours in WWII era vintage aircraft an d 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 5 1 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 51 offers to civilian and military pilots through its various forms of i nstructional 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 th e 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. Specifica lly, Stallion 51's self

- imposed safety measures, such as mandatory safety stand
- down days, constant review of standardization of operations and instruction, and utilization24 of in

- flight videos, enhance safety. In addition, Stallion 51 frequently updates i ts 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 key 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 have contributed to Stallion 51's excellent 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 S eptember 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, and most recently as Exemption No. 8593C on July 14, 2011, once again be amended by extending the termination date.

STALLION 51 CORPORATION Lee C. Lauderback President/Chief Pilot25 By: /s/ Kathleen A. Yodice Kathleen A. Yodice Counsel to Stallion 51 Corporation Law Offices of Yodice Associates 411 Aviation Way, Suite 245 F rederick, MD 21701 301
- 695
- 2300 301
- 695
- 2151 (facsimile)

Dated: June 28 , 2013