Exemption Request FAR 91.319(c)

Commemorative Air Force

Aircraft: B-29 N529B

Request: Exemption from FAR 91.319(c) and associated conditions in the aircraft 

operating limitations

1. Reason for Exemption:

The Commemorative Air Force is requesting this exemption to provide operational 

relief from the restrictions of operating over Densely Populated Areas for our B-29 

Superfortress N529B. This request is to allow participation in the flyover of the 

National Mall celebrating the 70th anniversary of the end of WW II, on 8 May, 2015. 

The concept of the flyover was briefed to Administrator Huerta by Congressman 

Graves and summarized in the letter to the Administrator (attachment 1). The letter 

clearly establishes the event as in the Public Interest. The basis of our equivalent 

level of safety is focused on the fact the B-29 has outstanding engine reliability and 

also has excellent 3 engine capability for continued flight to suitable recovery bases.

The B-29 operates with a LHFE exemption (6802) and complies with the required 

maintenance program and crew qualifications/training; the same as the limited 

category aircraft in the exemption. The oversight of the B-29 is focused on safe 

operations with checks and balances managed within the policies and procedures 

established in the CAF Safety Management System.

2. Overview of VE Day Flyover:

WHEN: May 8, 2015 

•WHY: Honor and pay tribute to our nation’s greatest generation on the 70th 

anniversary of VE Day 

•WHERE: Washington, DC and the World War II Memorial through the established 

“Honor Flight” model 

•HOW: Fly historic WWII planes over National Mall 
“THE PLAN” 

•Capitol Mall Flyover 

•Trainers followed by 13 Historically Sequenced Warbird formations and 

concluding with a missing man formation to “taps” 

•Formations in 90-second intervals 

•70+ planes representing the major battles of World War II, from Pearl Harbor to 

the final air offensive to defeat Japan 

HISTORICAL AERIAL REVIEW FLOW 

•Trainer Formation “Pass in Review” (Boeing Stearmans, Piper L-Birds, North 

America T-6s, Cessna/Beech Twin Bomber Trainers

•Pearl Harbor/Flying Tigers (Curtis P-40 Warhawks) 

•Doolittle Raid (North American B-25 Mitchells) 

•Guadalcanal Campaign (Bell P-63/P-39 Kingcobras/Aerocobras) 

•Battle of Midway (Consolidated PBY Catalina, Grumman F4F/FM-2 Wildcats, 

Douglas SBD Dauntless) 

•Yamamoto Shoot down (Lockheed P-38 Lightnings) 

•Ploesti Raid (Consolidated B-24 Liberators) 

•Combined Bomber Offensive—Long-Range Fighter Escort/Tuskegee Airman 

(North American P-51 Mustangs) 

•Big Week (Boeing B-17 Flying Fortress) 

•D-Day (Douglas C-47/R4D Skytrain, Douglas A-26 Invader) 

•Marianas Turkey Shoot/Battle of Leyte Gulf (Grumman TBM Avengers, Grumman 

F6F Wildcats, Grumman F8F Bearcats, Curtis SB2C Helldivers) 

•Battle of the Bulge (Republic P-47 Thunderbolts) 

•Iwo Jima (Vought FG-1D Corsairs) 

•Final Air Offensive to Defeat Japan (Boeing B-29 Superfortress) 

CONCLUDES WITH A MISSING MAN FORMATION TO TAPS 

3. Route of Flight/Restricted Area Waivers

The route of flight and approvals for flight in the restricted areas are being worked 

thru Mr. James Johnson (703) 563-3118 IAW the Administrators’ Letter of 19 

August, 2014 (attachment 2). The interagency suspense’s for these approvals are

very close to the event and history has shown they will not become final until the 

month before the event, or later. However, Mr. Johnson and the General Aviation 

Operations Branch, AFS-830 will be working together as meetings and the process 

continues. 


4. Equivalent Level of Safety:

A. Similar aircraft operation with limited certificates:

Similar aircraft of the same vintage and equipment have been certified in the limited

catagory and are not restricted by the densely populated area over flight rules. 

These aircraft are of comparable make, construction, and materials. The Boeing 

B-17 represents the best example of a Boeing built product with 4 engines and 

similar design and construction. The major reason our B-29 is certificated in the 

experimental category is the modifications we made to improve engine reliability.

B. Engine Design & Reliability

The B-29 is fitted with four (4) Curtis Wright R-3350 power plants. Each of these 

engines have been carefully re-designed and constructed by industry leaders to 

provide maximum reliability and longevity. Each engine was constructed from 

certificated parts to provide an engine that is de-rated for the same equivalent

power output. In 2010 all four (4) engines on the B-29 were retrofitted to these new 

engine designs and were carefully tested for operation. 
C. Equivalent Level of Safety Questions and Answers

1. What are the design and manufacturing features of the B-29 that create 

hazardous conditions which could impact people and property being overflown 

which would not be found by the operation of a similar civil type, i.e. DC-7?

A: Though the design and manufacturing features of the B-29 are very unique, 

the only potential hazardous conditions which could have impacted people 

and property being overflown were the aircraft’s original engines which have 

been eliminated. 

2. What safety data do you have concerning the aircraft while in service such as 

accident rate and types and classification of accidents? In other words, what failed 

and what is likely to fail, and how, and what is being done to mitigate these.

A: We do not have access to, or know where such records are and don’t know if 

they exist. However, our failure history is provided for your information.

During the second test flight with the new engine combination on N529B in 

2010 the #2 engine began backfiring under power loads. The situation did not 

warrant shutting the engine down, but the aircraft immediately performed 

and uneventful landing in order to perform a maintenance evaluation. 

Troubleshooting revealed the rotor locking device hardware inside one of the 

distributors was inadequate in locking the rotor in place. As the rotor slipped 

it caused improper ignition timing thereby causing the engine to backfire. As 

a precaution, the engine was removed from service and returned to the 

overhaul facility for a top end teardown and inspection. No cylinder or valve 

train damage was discovered, oil samples from the nose case and main section 

were both clean. The engine was reassembled and returned to service. An 

improved rotor locking hardware combination was installed inside both 

distributors of this engine, as well as, all of the other engines. This corrective 

action has mitigated this failure scenario from repeating again. 

There was precautionary in-flight shut-down of the #2 engine and uneventful 

landing at MAF in 2012 due to an accessory drive shaft failure. This incident 

was tied back to a 2010 distributor failure. The distributor backfiring 

incident in 2010 drove the engine to be removed from service and a 

precautionary top end disassembly to take place. No defects were found and 

since no metal particles were found in the oil a teardown of the bottom end 

was deemed unnecessary; the engine was returned to service. The engine 

remained in service for 2 more years until the accessory drive shaft failed. A 

subsequent 2012 metallurgical analysis of the sheared accessory drive shaft 

revealed a fatigue fracture had taken place from stress induced cracks 

prorogating in both torsional directions. The nature and directions of these 

stress cracks are consistent with and tied back to the 2010 backfiring under a 

load incident. As a precaution, inspections of the other engines and their 

accessories were conducted; no defects were discovered and no other similar 

or related incidents of this nature have occurred.
The third and final incident involved an exhaust stack fire in February, 2014. 

This exhaust stack fire occurred on the #2 engine right after landing from the 

aircraft's maintenance flight following the annual inspection. During the

annual maintenance inspection, the #2 engine carburetor was removed, 

overhauled and its parameters reset to the median settings IAW technical 

data. No problems were experienced with the #2 engine during the 

maintenance flight, but after landing and pulling off the runway, the #2 

engine's idle crept below the ground minimum, the engine quickly became too 

rich, it loaded up with fuel and a subsequent exhaust stack fire ensued. The 

fire was easily extinguished by restarting the engine and increasing the idle 

with the throttle lever. The idle circuit was adjusted and rigged to a slightly 

higher setting within the prescribed technical data range. The engines 

performed flawlessly during the aircraft’s follow-up maintenance flight, as 

well as, during the following 50 hours of flight time since the repairs were 

made.

3. How have you incorporated the applicable Air Force Regulations and SOPs 

(operational) applicable to the B-29 to CAF’s operations?

A: Incorporation of Air Force Regulations and such have been reviewed 

extensively and incorporated for the maximum safety of the operation. 

Although many of the modern CRM and TEM concepts for cockpit 

communication and operation is likely the most modernized part of the 

operation, many of the crew concepts which incorporate the scanners and 

flight engineer are directly from Military Manuals. The B-29 with a minimum 

crew of 6 is unlike most civil aircraft and the complexities of the aircraft 

require coordinated efforts between crewmembers. Examples of this include 

scanner callouts for positioning of gear, flaps, and flight controls in a 

prescribed manner. The focus on standardization and crew utilization is 

based upon a strict adherence to checklist usage. Each year these checklists, 

policies, and crew procedures are scrutinized and updated based upon 

operational input. 

4. What is the technical substantiation for the modifications to the R-3350 engines 

(-95 Power case & -26 Blower) installed in the aircraft? Please submit a copy of 

these materials to include a reliability analysis, proving & validation test data. 

A: The best answer to this question is a narrative of what and why we have done 

what we have on the engines.

The Wright R-3350-21 and -57 model engines originally developed, 

manufactured, and installed on Boeing B-29 aircraft during the mid-1940’s 

were inherently problematic and unreliable. Historical accounts show these 

engines operating during wartime conditions, on average, to have a service 

life of only 50-100 hours. Though the Commemorative Air Force’s B-29 (N529B) does not at all operate under wartime conditions, flight profiles, or 

heavy operating weights, the aircraft’s original model engines are still plagued 

with design deficiencies and now developing serious fatigue issues. In order to 

increase reliability, sustainment, and safety of flight conditions of this last 
flying example of our Greatest Generation’s most significant aircraft an engine 

upgrade is definitely required.

The R-3350-21 and -57 were unique to the B-29 and no other radial engine 

equivalent is a direct bolt-on replacement. Later versions of the 3350 engine 

family were vastly redesigned, significantly improved, and incredibly reliable. 

By utilizing and combining parts from two of these later versions of R-3350 

engines an excellent replacement engine was made to fit the B-29 with no indepth reconfiguration or reengineering of airframe mounts or structures. The 

power section, blower section, and accessory section from the newer R-3350-

26WD was combined with the nose case, rotating assembly, and cylinders 

from an R-3350-95W to create what has been designated an R-3350-B29

engine; a safe and reliable bolt-in replacement for the B-29. The -26WD engine 

components used bolt directly to the existing B-29 engine mount structure 

and accommodate existing accessories while the -95W components allow for 

the use of the original B-29 propeller assembly. These engines have proven 

themselves over and over to be excellent engines on everything from 

transport aircraft, military aircraft, and air racers.

The only associated components requiring a complete re-engineering to 

accommodate this new engine installation involved the exhaust system. The 

front cylinders on the originally installed R-3350-57 engines exited from the 

front side of the cylinders into large collectors and were routed aft down both 

sides of each nacelle. The exhaust ports on the front cylinders of the R-3350-

B29 engine exit rearwards. New collector rings were fabricated to 

accommodate this difference and tie them into the aircraft’s remaining 

original exhaust system. In order to enhance performance, simplify the 

installation, and improve reliability, the unused air intake intercoolers and 

associated ducting was removed and a direct flowing induction trunk was 

manufactured inside of each nacelle. This modification greatly increases and 

streamlines airflow into each carburetor. Another benefit of using this R3350-B29 engine and exhaust configuration is that it eliminates the need for 

any outside modifications to the aircraft’s ring cowlings and nacelles thereby 

preserving the aircraft’s historical original appearance.

There was a negligible effect on the aircraft’s Weight & Balance due to this 

alteration. Upon completion and approval, the aircraft was weighed and its 

weight and balance records updated.

5. How were engine-related issues in the C-119 and Douglas AD-series 

considered? Were the -95 and the -26 option chosen because these were available 

and affordable or because a civil certificated version of the powerplant was not 

technically possible? Please explain.

A: No civil certificated version of the 3350 family of power plants was a

technically possible direct bolt-on replacement engine for the B-29. 

(See question #4)
6. What is the modification status of the aircraft? Please submit relevant records, 

especially those made to the aircraft after it was grounded in 2006?

A: Due to the aircraft being categorized as Experimental no 337's were 

submitted for any modifications made. Aside from the previously mentioned 

engine and exhaust system modifications, passenger seating changes and the 

installation of additional batteries were the only modifications made that 

would go beyond minor/enhanced reliability, or cosmetic changes. In 

addition to the original crew seating accommodations, provisions for 7 

additional passengers has been installed in the aircraft. 6 of these seats 

comprised of 2 airline triple seat assemblies have been installed to the 

fuselage sub-structure in the aft crew compartment. The 7th additional seat is 

an OEM B-29 radio operator/navigator seat installed to the sub-structure in 

the flight deck. Additional batteries have been installed into the tail gunner’s 

compartment as an enhanced system to start the aircraft engines verses 

utilizing the APU. These improvements and all other modifications passed a 

physical conditional inspection by agency representatives (Lubbock FSDO) 

when N529B was returned to service and issued its airworthiness certificate 

in 2010. 

7. What is being done to address the recent deficiencies (Aug 2014) which 

resulted in the FSDO not accepting the AIP for N529B?

A: The updated AIP for N529B that was sent to the DFW FSDO in August 2014 

was only a preliminary, unfinished working draft. Due to the huge scope and 

magnitude of this project we requested an early informal review of our 

progress to date to ensure we were headed in the right direction and to help 

spread out this overwhelming workload on the inspector. 

The draft version to date is by far more enhanced and detailed and most of the 

noted deficiencies within the draft AIP involved us mirroring the layout and 

format of the current AIP that was issued back on April 17, 2000. The CAF 

maintenance policies, practices and procedures for the B-29 far surpass the 

industry standards and current AIP. We are continuing to capture and 

documents these actions in what will become a comprehensive and detailed 

AIP for future sustainment. 

 

8. Can you provide a listing and data showing that all applicable USAF T.Os and 

TCTOs (to end of operational service) have been complied with?

A: No official USAF records for the aircraft were released to the CAF. At the 

time of active duty retirement B-29 serial number 44-62070 (N529B) was 

maintained to applicable standards and TCTO completeness including the 

Saddletree modification to carry nuclear weapons was current and complied 

with IAW USAF standards. Since acquisition of the B-29 by the CAF, no related 

military technical order, or TCTO update, or modification has been released. 
9. What ADs, SBS, or other civil requirement/guidance applicable to the R-3350s 

and the propellers installed in N529B has been considered? In other words, what 

safety issues were addressed in the civil side is relevant to enhancing the safety of 

N529B?

A: The engine builder (Anderson Aeromotive, 824 N. D. St, Grangeville, ID 83530) 

tracks and accomplishes any and all required, recommended and necessary 

actions on N529B’s engines. In addition, dynamic propeller balances are 

performed in the interest of enhancing safety and reliability. Also, AD 81-13-

06R2 is accomplished every 5 years on each propeller assembly.

10. What are all of the applicable USAF T.Os for the aircraft in effect at the time of 

retirement?

A: We don’t know the answer about “all”, but can tell you this:

The parent publications and sub-chapter job guides of the following USAF 

technical orders were all in effect at the time of retirement and are still 

currently being used by the CAF to maintain 529B: 1B-29A-1 Flight Manual, 

1B-29A-2 Maintenance and Erection Manual, 1B-29A-3 Structural Repair 

Manual, 1B-29A-4 Illustrated Parts Breakdown Manual, 1B-29A-5 Weight and 

Balance Manual & the 1B-29A-9 Loading Manual.

11. What flight emergencies, in-flight failures, and post-flight discrepancies have 

occurred since the aircraft returned to airworthy condition in August 2010?

A: (See the 3 fore mentioned engine related incidents addressed in question 2) 

12. Is the fire detection and suppression system functional and properly inspected?

A: The B-29 is not equipped with an automated fire detection system. Fire 

detection is performed by the flight engineer and two scanners. The fire 

suppression system is fully operational and inspected during the aircraft’s 

annual maintenance inspection. The serviceability of the fire suppression 

system is verified during each pre-flight inspection by the flight engineer. 

13. What is the SOAP frequency and results since August 2010?

A: SOAP samples have been and continue to be taken every 50 hours of inservice time on each engine. To date, the results have revealed no 

discrepancies, or negative trends. SOAP samples will continue to be taken on 

this schedule and the results tracked throughout the life of each engine.

14. What are the details of the aging aircraft and corrosion control programs in 

place?

A: Aging aircraft and corrosion control issues are a large part of the CAF’s B-29 

sustainment program. During the annual maintenance inspection, in-depth 

inspections of the wings and tail structures are performed including nondestructive testing of spar, primary structural components and attachment 

points. Aircraft secondary structures and surface skins also undergo 

corrosion inspections. Regular lubrication and corrosion preventative 

treatments are made, as well as, touch up painting whenever necessary. The 
written version of this aging aircraft and corrosion control program is still in 

development and will be incorporated into the new AIP. 

15. What are the configurations and redundancies installed in the aircraft?

A: Numerous redundancies and back-up systems are built into the B-29 

aircraft. Today, the aircraft is only operated and configured at half of its 

designed combat weight. The proven design and light operational weight 

make this aircraft the safety and reliability standard for all heavy war birds. 

16. The expectation is that the most experienced crew would be used. As such, can 

you please provide the qualifications and experienced of the proposed crew for the 

flight?

A: Our crews train to the standards of the LHFE program which you have on file 

as exemption 6802L and our crews are type rated. 

The great advantage to operating one of the rarest aircraft in the world is the 

interest and desire from pilots around the world. The selection process for 

flight crews includes interviews, vetting, and financial contribution. This 

process often starts with the candidate being reviewed in smaller training 

aircraft. Copilots are then vetted and Aircraft Commanders are very 

specifically trained and chosen. Many of our Aircraft Commanders are former 

airline or military pilots with over 20,000 hours of flying experience. Their 

experience includes Formation training, systems training, along with 

extensive emergency procedures and Crew Resource Management training. 

17. Can you provide information showing that the FE in the B-29 properly rated? 

A: This aircraft does not hold a Type Certificate, it is certified as an 

Experimental aircraft and therefore flight engineers are not required to hold a 

FAA-issued Flight Engineer License and all currency requirements of 14 CFR 

Part 91.529 for FAA certificated Flight Engineers need not be met in order to 

operate this aircraft. All flight engineers must complete Commemorative Air 

Force (CAF) ground and flight training requirements and accomplish an 

annual flight engineer check, conducted by a designated CAF flight engineer 

examiner prior to being authorized to conduct the duties of the assigned 

position. The ground training, flight training, and check ride documentation 

will be made a part of the flight engineer records and maintained by CAF 

Headquarters.

18. What special pre-flight and post-flight inspections can be performed to enhance

safety?

A: Pre-flight and post-flight inspections performed by the flight engineer each 

and every time the aircraft is operated encompass a very in-depth, serious and 

detailed safety and serviceability inspection of the aircraft. The mechanical 

condition, proper servicing, safety equipment condition, loading and dropped 

object prevention are incorporated into each of these inspections. 
19. What QC processes are used in addressing supplier and parts acquisition and 

use?

A: Parts acquisition and spares serviceability are all controlled by and solely 

the responsibility of the B-29/B-24 Squadron’s head Crew Chief. This ensures 

a specific focal point of high level of experienced quality control and vendor 

oversight. 

20. Has the CAF implemented SMS/CRM/MRM/ORM? If so, please provide details.

A: Yes, our SMS Program is attachment 3

21. On the issue of engine/powerplant and propeller failure and related issues, 

please provide the mitigating strategies for the following: 

(Including Overheating, Magnesium Components, Accessory 

Drave Shaft, PRTs, Low Compression, Valves (e.g., Pounding), Cylinders, Metal in 

Sumps);

A: Detailed instructions are provided within the flight manual and checklists 

for these types of engine failures.

APU Fire & Containment;

A: The APU is only used as a secondary engine starting source and for 

situations in-flight where and additional generator could possibly be needed. 

In the event of a fire, the APU is equipped with a self-contained fire 

extinguishing system with a fire sensing loop and automatic agent dispensing 

with a manual back-up. 

Propeller Overspeed and Separation;

A: Detailed instructions are provided within the flight manual and checklists 

for these types of propeller failures.

Hydraulic & Electrical Failures;

A: Detailed instructions are provided within the flight manual and checklists 

for these types of failures.

Tail Strike and Landing Gear Failure;

A: Detailed instructions are provided within the flight manual and checklists 

for these types of failures.

MEL & Flight Abort Criteria;

A: The flight must be VFR and all inflight emergencies will result in an abort to 

the nearest suitable, or available airport as required by the emergency.

An MEL list has been compiled for the aircraft according to its current 

configuration. The aircraft does not operate outside this document. Flight 

Abort Criteria is at the discretion of the PIC. Abort Criteria for rejected 

takeoffs is included in the Aircraft Flight Manual. The squadron SOP requires 

6000 feet of runway length available for takeoff and landing. This 
requirement guarantees accelerate stop distance inside normal operating 

parameters. 

22. What coordination has been done with other Military/Federal entities 

concerning the proposed overflight?

A: See section 3 above

23. For flight over populated areas, please discuss and provide detail on the 

following:

Egress/Ingress (Airports & Areas);

A: See section 3 above

Ground References & Landmarks;

A: See section 3 above

Formation, Mixed Formation, and In-Trail;

A: The plan is for the B-29 to be flying solo and not in formation, however, the 

pilots will be formation qualified IAW the National FAST standards if a change 

puts the airplane in a formation 

Lateral Separation & Maneuvering Room;

A: A: Non-formation flight requires separation of at least 500 feet

Straight & Level, Minimum Maneuvering;

A: Maneuvering room for the B-29 is not appreciably larger than aircraft of 

equivalent speed and maneuverability. Although the aircraft appears large 

and cumbersome it can be maneuvered in confined areas appropriate with its 

normal cruise speed. Roll rates for the aircraft are likely close to 20-30 

degrees per second.

Rehearsal, if Special Event is involved;

A: There will not be a rehearsal; all procedure will be standard point to point 

navigation with radio communications between ATC and other aircraft

mum airspeed for which it is still possible to climb 

away, without change of configuration, if any one engine fails, (2) symmetrical 

thrust should be maintained at all times, and power changes minimized, (3) glide 

ratio.

A: (1) The answer to this question depends on a number of factors. The 

minimum control speed with one outboard engine inoperative is 125mph. 

This speed is an indication of control more than performance but its 

important to note that speeds greater than this number in most any 

configuration with gear or flaps will provide sufficient aircraft control. 

For the purpose of a complete answer, this speed does not guarantee climb or 

acceleration performance. Performance will be dependant upon aircraft 
configuration. At mid-operating weight ranges (approximately 90,000#s or 

less) the aircraft will maintain altitude with gear down and flaps at 35 degrees 

with one engine inoperative. To climb will however require a reduction in 

drag and increasing performance will result. 

(2) Symmetrical power is used with one engine inoperative. This procedure is 

standard to prevent the use of excessive rudder and provide a balanced power

application from each side; higher than cruise power settings will require 

unsymmetrical power application which is considered normal and easily 

managed with airspeeds above minimum control. 

(3) No published glide ratios can be found. It’s conceivable that with the B29’s weight and high aspect ratio wing its glide range is likely better than most 

large aircraft. 

In-Flight Divert Procedures Including Divert Airports (e.g. DCA, Andrews AFB) 

and Crash Landing Areas (e.g. Potomac River);

A: See section 3 above

Reduced operating weight, power settings;

A: The aircraft can be operated at minimum operating weights which would 

likely not exceed 80,000#s. Takeoff power is consistent at 44 inches and 2400 

rpm for all operating weights. Climb power settings are at the discretion of 

the PIC. Cruise power settings would be on demand for the airspeed and 

altitude of the mission. 25-30 inches of manifold would likely be the operating 

range. 

D. Standards for Crew Training

Our crews train to the standards of the LHFE program, which are the same

standards required for aircraft with limited certifications and our crews are type 

rated.

 (CONTINUED ON NEXT PAGE)
5. Risk Mitigation and Assessment:

The answers to the questions above touch on specific risk and mitigations requested 

by AFS-830. However and in general terms, this assessment addresses events which 

pose a danger to people and structures on the ground. The scores are listed here and 

the risks are shown in the Matrix. None of the risks are in the caution or danger 

zones.

1. There is no history with the B-29 which shows catastrophic failures resulting in 

immediate loss of aircraft control. Assessment: improbable/catastrophic

2. The most significant failure would be an engine fire and a simultaneous failure 

of the fire suppression system, or a fire in a component located in an area where 

the crew would be unable to fight the fire with onboard suppression systems. 

The immediate action in either case would be an immediate diversion to the 

closest diversion field, which during the flyover would only take 3-5 minutes 

and is within the window for a safe recovery. Assessment: remote/negligible 

3. Engine failures without fire, or fires successfully suppressed are managed by 

shutting down the engine and proceeding to a suitable airport. Three engine

performance is sufficient for maintaining altitude and airspeed and normal 

procedures are followed for flight to the suitable airport. 

Assessment: occasional/negligible 

4. The possibility of two engines failing is extremely remote; however, two engine 

performance at the operating weight for the flyover, and other local flights, is 

sufficient for continued flight to the diversion airports along the route of flight 

during the flyover. Assessment: remote/negligible

5. The possibility of a midair collision within a formation is mitigated by managing 

the qualifications of the pilots and the flight profiles. The pilots flying formation 

will be qualified IAW FAST standards and the flight profiles are straight and 

level point to point. Furthermore, midair collisions within a formation rarely 

result in loss of control, or major aircraft damage. Midair collisions within 

formations which result in loss of control are primarily in high “G” or highly 

maneuvering elements. Assessment: remote/marginal

 (CONTINUED ON NEXT PAGE)
Risk Assessment Matrix

Population/Structures in DC Area for VE Day Flyover

Severity

Likelihood Negligible 

IV

Less than

minor injury 

and/or less 

than minor 

structure

damage

Marginal

III

Minor injury 

and/or minor 

structure

damage

Critical

II

Severe injury 

and/or major 

structure

damage

Catastrophic

I

Results in 

fatalities 

and/or loss 

of structures

Frequent = A

Continuously 

experienced

Probable = B

Will occur often

Occasional = C

Likely to occur 

sometime

Engine failure

Remote = D

Unlikely, but 

possible

Uncontrolled 

fire/two 

engine failure

Midair

Improbable = E

So unlikely, it can 

be assumed it will 

not occur

Loss of 

control

 (CONTINUED ON NEXT PAGE)
6. Summary:

Participation of the B-29 in the flyover of the National Mall celebrating the 70th

anniversary of the end of WW II is in the public interest and the safety of the 

population is equivalent to previously approved flyovers with similar routes in the 

Washington DC area. I look forward to the opportunity to work with the Agency 

answering questions as they arise during the staffing of our request. Please contact 

me on my cell, or via email should the need arise.

Sincerely,

Robert A. Stenevik

Vice President of Safety, Maintenance and Operations

Commemorative Air Force

Cell 817-705-5817

rstenevik@cafhq.org

3 Attachments:

- Congressional Letter to the Administrator

- Administrators’ Letter of 19 August, 2014

- CAF Safety Management System Guide