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 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. 8593C

Regulatory Docket No. FAA-2002-12993

Enclosed is our petition to renew Exemption No. 8593C 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 

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 basis 

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

Enclosure
2

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 91.315 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, 2013
3

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. Stallion 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 PETITION

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 issuing 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 functional 
4

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 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 

exceptionally 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 91.315 without additional 

conditions or limitations. 
5

BACKGROUND

Stallion 51 operates three dual-cockpit, dual-control P51s, 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 interesting 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 of 
6

authorization is required to act as pilot in command of a 

limited category P-51 Mustang.

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 

command 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 standard 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 grant 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 FAA 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, 2002, Stallion 51 again petitioned the FAA for a 
7

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 dated 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 operates 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 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. 
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. Recurrent 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 relative 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; however, 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 "numbered" exhibits were attached to the June 2000 
9

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 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 

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. When 

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 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 

pilot's initial pilot training. One shortcoming of this 

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 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 potential for the aircraft to be "upset" from 
11

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 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 is 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, Stallion 
12

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 past 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 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 twoplace 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 

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 and 

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 Formation & Aerobatic Training.

Many of the civilian flown warbird fighter aircraft are P51 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 

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 pilot 
14

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 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 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 

Exemption. 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

Lakeland, 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 2013
15

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, 

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 

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 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 safety overview. The 

seminars were well attended by the FAA, NTSB, and numerous 
16

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 of 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 

Heritage 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 followed. 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 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. 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 manner 
18

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 and 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 another 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 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) 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 

relating to ground and flight operations. Reviewed at the 
19

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 approximately 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, 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.
20

At the advice of its safety consultant, Stallion 51 

implemented an additional safety 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 

contributions 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 Mustangs 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-51A-6. See Exhibit C (attached to original 
21

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 maintenance 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 that 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 certified 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 9,000 
22

hours in the Mustang. He is a certified single and multi-engine 

flight 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 Examiner. 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 participates 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. Busch 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 5200 flight hours and 
23

logged time in over 30 different types of military aircraft. He 

has over 1000 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 51 

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. 

Specifically, Stallion 51's self-imposed safety measures, such 

as mandatory safety stand-down days, constant review of 

standardization of operations and instruction, and utilization 
24

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 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 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, 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 Pilot
25

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 28, 2013