EAA Aviation Center ▪ PO Box 3086, Oshkosh, WI 54903

- 3086 ▪ Ph: 920

- 426

- 4800 ▪ Fax: 920

- 426

- 6560 ▪ www.eaa.org June 17, 2011

U.S. Department of Transportation Docket Management System 400 7 th Street SW Room PL

- 400 Washington, DC 20591

- 0001
Dear Sirs: Reference: Petition for Exemption from Federal Aviation Regulations 14 CFR part 91.315 to allow initial type

- rating flight training for compensation and hire in EAA’s Boeing B

- 17, N5017N, and Boeing B

- 25, N10V, both Limited Category Civil Aircraft

. EAA (Experimenta l Aircraft Association) is the world leader in recreational aviation. With an international membership of 170,000 people in more than 112 nations, EAA brings together aviation enthusiasts, pilots and aircraft owners who are dedicated to the continued grow th of aviation, the preservation of its history and a commitment to aviation’s future. EAA programs, activities and events are known throughout the world for Preserving the heritage of aviation, Promoting access to flight, Protecting the right to fly, Pre paring the future of aviation, and of
our Passion for aviation safety and education.
EAA curren tly holds FAA exemptions No. 6541 (B

- 17) and No. 4941 (B

- 25) that allows our flight training department, under the direct supervision of the Milwaukee Flight Standards District Office (FSDO) , to conduct recurrent training and biennial flight reviews in both these aircraft for previously qualified flight crewmembers. Our ability to continue to operate these aircraft with fully qualified flight crewmembers is sl owly being reduced as the existing pool of pilots is aging. In order to continue to provide the safest historic flight experiences to the public EAA is requesting, through this petition for exemption, the authority to conduct initial type

rating training in these aircraft for compensation and hire. EAA believes that flight training is one of the two key cornerstones of flight safety, with maintenance being the other cornerstone. By allowing EAA to conduct initial type

- rating training and flight checks, the FAA and EAA will be creating the most qualified and safest B

- 17 and B

- 25 historic aircraft pilot pool in the U.S. The EAA Boeing B

- 17, N5017N :

**•** I s currently operating under FAA historic aircraft experience and flight training exemption, number 6541

**•** Its limited category airworthiness certification was issued on March 28, 2006

**•** Is being maintained to the highest standards under the terms of exemption 6541The EAA Boeing B

- 25, N10V

**•** I s currently covered by the FAA flight training exemption, number 4941

**•** Its limited category airworthiness certificate was issued on June 27, 1956

**•** It is being restored to the highest standards of maintenance for flight operations During its discovery research, EAA has determined that this petition for exemption would n ot set a precedent as several other very similar exemptions

– No. 8593; No. 10057; and No. 10191

- currently exist.
EAA could not find another B

- 17 operator authorized to provide initial type rating ground and flight training and evaluations.
To ensure the safest possible flight training environment, EAA will ensure the pilot in command of the training flight will:

**•** Hold at least a current and valid commercial pilot certificate with a multiengine land airplane rating;

**•** Hold a current and valid flight inst ructor certificate with an airplane multiengine rating;

**•** Have completed B

- 17 or B

- 25, as appropriate, aircraft qualification and recurrent flight and ground training within the previous 12 calendar months;

**•** Have accomplished three takeoffs and landings to a full stop in a B

- 17 or B

- 25 aircraft, as appropriate, within the previous 90 days before serving as PIC; and

**•** Hold at least a second

- class medical certificate To ensure the safest possible airworthiness standards are maintained, EAA will ensure:

**•** The B

- 17, N5017N, is maintained per the issued FAA historic aircraft flight experience exemption No. 6541; and

**•** The B

- 25, N10V, is maintained in an airworthy condition in accordance with:
o The maintenance requirements specified in the B

- 25 aircraft type specification sheet, as amended;
o An inspection program that meet the requirements of § 91.409; and
o Appropriate military technical manuals for the B

- 25. Therefore, EAA is requesting a n e xemption from Federal Aviation Regulations 14 CFR part 91.315 to allow initial type

- rating flight training for compensation and hire in EAA’s Boeing B

17, N5017N, and Boeing B

- 25, N10V, both Limited Category Civil Aircraft. Sincerely,

Randy Hansen Government Relations Director