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 7th 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 (Experimental 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 growth 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, Preparing the future of aviation, and of 

our Passion for aviation safety and education.

EAA currently 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 slowly 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 typerating 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:

• Is 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 6541
The EAA Boeing B-25, N10V

• Is 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 not 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 instructor 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 an 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 B17, N5017N, and Boeing B-25, N10V, both Limited Category Civil Aircraft. 

Sincerely,

Randy Hansen

Government Relations Director