## Exemption Request FAR 91.319(c)

Commemorative Air Force

Aircraft: B

- 29 N529B

Re quest: Exemption from FAR 91.319 (c) and associated condition s in the aircraft operating limitations



## 1. Reason for Exemption:

The Commemorative Air Force is requesting this exemption to provide operational

relief from the restriction s of opera ting ov er Densely Populated Areas for our B

- 29 Superfortress N529B

. This reque st is to allow participation in the flyover of the

Nationa l Mall celebrating the 70 th an nive rsary of the end of WW II, on 8 May, 2015.

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

Grave s and summarized in the letter to the Administrator (attachment 1) . The lette r 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 operate s 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 Syst em

.



## 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 off

ensive 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 Corsair s ) •Final Air Offensive to Defeat Japan (Boein g 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 Administra tor s’ 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 Avi ation 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 li mited

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 Boein g built product with 4 engines and similar design and construction. The maj or reason our B

- 29 is certificated in the experimental category is the modifications we mad e 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 t hat 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 a re 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 manufacturin g features of the B

- 29 are very unique, the only potential hazardous conditions which could have impact ed 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 hard ware 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

ove rhaul 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 hardwa re 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.

The re 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 bac k 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 access ory 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

stre ss 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 w ere 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 s tack fire in February, 2014

.

Th is 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 quick ly 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 highe r 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 incorpora ted 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 operatio n, 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 cre wmembers. 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 checkl ists, 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 aircraf t? 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 e ngines 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

li fe of only 50

- 100 hours. Though the Commemorative Air Force’s B

- 29 (N

529B) 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 lastflying 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 pa rts from two of these later versions of R

- 3350 engines an excellent replacement engine was made to fit the B

- 29 with no in

depth reconfiguration or reengineering of airframe mounts or structures. The power section, blower section, and accessory section fro m 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 bol t 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 e verything 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 install ed 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 fabricate d 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 R

3350

- B29 engine and exhaust configuration is that it eliminat es 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 complet ion 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. ( S ee 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, o r cosmetic changes. In

addition to t he 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 sys tem to start the aircraft engines verses utilizing the APU. These improvements and all other modifications passed a physical condition al inspection by agency representatives (Lubbock FSDO)

when N 529B was returned to service and issued its airworthiness ce rtificate

in 20 10

.

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, un finished 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 th is overwhelming workload on the inspector.

T he 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, p ractices and procedures for the B

- 29 far surpass the industry standards and current AIP . We are continu ing to capture and

documents these actions in what will become a comprehensive and detailed

AIP for future sustainment.

8. Can you pr ovide 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

mili tary 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 we re 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, A D 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 operat ional 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 2 010?

A: SOAP samples have been and continue to be taken every 50 hours of in

service 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 r esults tra cked 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 non

destructive testing of spar, primary structural components and attachment points. Aircraft secondary structures and surface skins a lso undergo corrosion inspections. Regular lubrication and corrosion preventative treatments are made, as well as, touch up painting whenever necessary. Thewritten 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 reliab ility 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 t he 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 train i ng.

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 Experimenta l 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 ass igned 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/CR M/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 failure s.

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 sensin g 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. Thisrequirement guarantees accelerate stop distance inside normal opera ting

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 separa tion 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 indicatio n 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 aircraftconfiguration. 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 inope rative. 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; h igher 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 B

29’s weight and high aspect ratio wing its glide range is likely better than most large aircraft.

In

- Flight Divert Procedures I ncluding 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 LHF E program, wh ich are the same standards required for aircraft with limited certifications and our cr ews 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 risk s are in the caution or danger

zones.
1. T here 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, wh ich during the flyov er wo uld 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 wit hin 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 collisio ns 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 tha n minor inju ry and/or less

than minor

structure damage Marginal

III Minor injury and/or minor

structure damage Critical

II

S evere injury and/or major

structure damage Catastrophic

I

Results in

fata lities 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 c an 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 70 th anniversary of the end of WW II is in t he public interest and the safety of the populati on 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

- Administra tor s’ Letter of 19 August, 2014

- CAF Safety Management System Guide