Law	Offices

Yodice Associates 

411	Aviation	Way,	Suite	245

Frederick,	MD	21701

Office:		(301)	695-2300				FAX:		(301)	695-2151

www.yodice.com

JOHN S. YODICE*

KATHLEEN A. YODICE*

MICHAEL A. YODICE

PARALEGAL

RAYMOND C. SPECIALE

LEONARD CERUZZI‡

ELIZABETH M. CANDELARIO**

OF COUNSEL

 *MD & DC; ‡CT ONLY; 

**PA & DC

THROUGH U.S. DEPARTMENT OF TRANSPORTATION

DOCKET MANAGEMENT SYSTEM -- WWW.REGULATIONS.GOV

June 18, 2015

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. 8593D

Regulatory Docket No. FAA-2002-12993

Enclosed is our petition to renew Exemption No. 8593D 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 change in the conditions and 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. 8593D be renewed in its current form and that its 

effectiveness be extended until at least July 31, 2017, or 
longer given the more than 15 years of safe operations under the 

FAA’s exemption authority.

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
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 18, 2015
2

RELIEF SOUGHT

The Stallion 51 Corporation seeks a renewal of FAA 

Exemption No. 8593D (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 seeks continued relief from the application of FAR 

91.315 to provide various types of training in these aircraft 

and will continue to 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 
3

FAA that since the TF-51 has dual cockpits and fully functional 

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 
4

continued exemption from FAR 91.315 without additional 

conditions or limitations. 

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. 

In 1998, Stallion 51 petitioned the FAA for a grant of 

exemption from FAR §91.315 in order to be able to provide 

training in the aircraft as further described in this petition. 

Stallion 51 did not seek to provide air transportation for 

compensation or hire in these aircraft. 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. 
5

6811A. On July 22, 2002, Stallion 51 again petitioned the FAA 

for a 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

petitioned for another Renewal of Exemption, which the FAA 

granted and issued Exemption No. 8593B on July 20, 2009. On 

June 10, 2011, Stallion again petition for and was granted a 

Renewal of Exemption by the FAA with the issuance of Exemption 

No. 8593C on July 14, 2011. This exemption was most recently 

renewed when Stallion filed a petition on June 28, 2013 and the 

FAA issued Exemption No. 8593D on July 29, 2013. This current 

exemption is set to expire on July 31, 2015.

INTERESTS OF THE PETITIONER

Stallion 51 operates three of only sixteen known TF-51 

Mustangs in existence in the world. Stallion 51 operates these 
6

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. 

See Exhibit A.1 The training covers such issues as aircraft 

systems, normal and abnormal procedures, basic flight maneuvers, 

slow and high performance maneuvering, stalls and departures, 

with 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. Recurrent training is offered for 

those who successfully complete initial training, as well as for 

pilots of other high performance aircraft. Depending upon the 

pilot's skill level, recurrent training 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.

 

1 Cites to "lettered" exhibits are to those exhibits that 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 are to 

those exhibits that were attached to the June 2000 Petition for Renewal of 

Exemption. They can also be provided upon request if necessary. 
7

Another essential element of the Stallion 51 training 

program consists of orientation training flights. These flights 

are conducted under the same 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 

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 28 years, except for a few years during 

which lack of funding has 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 key to the 
8

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 

conducted for the military. That number now stands at 

approximately seven hundred (700). 

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. 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 
9

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 

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.
10

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 

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 and meets a safety training need that is not 

otherwise easily or efficiently accessible in the industry. 

Stallion 51 seeks to continue these training activities in full 

compliance with the FARs, as it has done so for the past 28

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 
11

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.

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 

required 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 

training that 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 
12

pilot accidents in high performance military surplus aircraft. 

See Exhibit B. 

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, which are forms of 

training not equivalently available in standard category 

certificated aircraft. The TF-51 thus serves as an excellent 

training aircraft for pilots who fly the Spitfire, Corsair, 

Bearcat, P-47, and other fighter aircraft. Considering the 

minimal pilot qualifications which are required to fly the 

Mustang or other fighters under the FARs2, 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.

Through May 2015, Stallion 51 has provided training and 

aircraft familiarization to over 9,000 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 

 

2 Under the FARs, a student pilot with complex, tail wheel, and high 

performance aircraft endorsements can act as Pilot in Command of a limited 

category 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 authorization is 

required to act as pilot in command of a limited category P-51 Mustang. 
13

specific Formation & Aerobatic Training. The fact that so many 

individuals have reached out and participated in the training 

demonstrates the need and the public’s interest in its 

availability.

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. In the past 10 

years, Stallion 51 has attended and participated in over one 

hundred (100) air shows, approximately seven of which occurred 

in the past two years since the last Petition for Renewal Of 

Exemption. Most recently, Stallion 51 attended airshows in:

Lakeland, FL – April 2014

Jacksonville, FL – October 2014

Stuart, FL – October/November 2014

Melbourne, FL – March 2015

Tuscaloose, AL – March 2015

Tyndall AFB, FL – April 2015

Lakeland, FL – April 2015

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 
14

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, engine maintenance 

panel discussions, and an operational safety overview. The 

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

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 
15

the same great pilots also returned, along with a variety of 

others. 

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. Additionally, Stallion 

51 has participated in various television shows about the 

history of the P-51 airplanes. Stallion 51 intends to continue 

participating in and hosting similar events for public benefit 

in the future. 

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 A-10, F-15, F-16, F-22 and F4 

demonstration jets at air shows across the country. 

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 
16

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. Stallion 

51 has continued its participation in this important educational 

program and as of May 2015, has flown in over 255 formation 

demonstrations.

Stallion 51 also participates in the International Test 

Pilot School (ITPS) training for students and instructors,

providing flight test training and qualitative evaluation to 

civil and military customers alike. In the past four years 

since beginning involvement with ITPS, Stallion has participated 

in approximately 15 sorties, further demonstrating Stallion 51’s 

contribution to the public’s interest in renewing the exemption. 

LEVEL OF SAFETY

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: after 28 years of extensive 

flight operations and over 16,000 hours of operating the TF-51 

Mustang, Stallion 51 has a flawless safety record. This record 
17

is possible because all training is conducted in a manner 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 2,000 hours 

without incident. Between the 2002 Petition for Renewal of 

Exemption and the 2005 Petition for Renewal of Exemption, 

Stallion 51 flew about 1,500 hours without incident; another 

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; 1,000 between May 2009 and the 2011 

Petition; and approximately 2,500 between the May 2011 and the 

2013 petition. Stallion 51 has continued to demonstrate its 

commitment to safety by improving its excellent safety record 

with 1,000 additional flying hours since May, 2013, all 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 
18

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 

meeting are any recent incidents or mishaps in the warbird 

community, 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. Stallion 51 also 

holds 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. An in-flight 

video is recorded during all training operations. 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 
19

instructor pilots. These videos are periodically reviewed by 

the Chief Instructor to ensure standardization and compliance 

with Stallion 51 procedures.

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." In 2013, Chief Instructor Lee Lauderback was 

inducted into the Experimental Aircraft Association (EAA) 

Warbird Hall of Fame. As an FAA-recognized industry leader in 

aerobatic competency in warbird aircraft, EAA Warbirds of 

America’s recognition of Mr. Lauderback’s training and safety is 

speaks particularly highly of the safety standards utilized by 

Mr. Lauderback in Stallion 51’s operations. Additionally, 

Stallion 51 is recognized by virtually every major aircraft 
20

insurance company and is known in the insurance industry as the 

"Flight Safety of High Performance Fighter Aircraft."

Stallion 51’s excellent safety record is enhanced by a 

well-organized maintenance program. Stallion 51 employs 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. All maintenance procedures are 

conducted in accordance with United States Air Force Technical 

Order 1F-51D-2. See Exhibit D. Additional maintenance guidance 

is obtained through utilization of the Cavalier Mustang F-51D 

maintenance instructions manual. See Exhibit E. 

The United States Air Force Flight Operating Instructions 

Handbook, AN 01-60JE-1, is utilized for aircraft operations. 

See Exhibit H. 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 
21

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 15,500 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 21,000 

flight hours in all types of aircraft, including over 9,000 

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

flight and ground instructor, holds an 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, participates in the USAF Heritage Flight program 

as civilian lead in the Mustang, and instructs for the Navy Test 

Pilot School at Patuxent River, MD. In November 2013, 

Mr. Lauderback was inducted into the EAA Warbird Hall of Fame. 
22

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 its 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 5,200 flight hours and 

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

has over 1,000 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 
23

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 

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 
24

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, as Exemption No. 8593C on 

July 14, 2011, and most recently as Exemption No. 8593D on July 

29, 2013, once again be renewed with an extended termination 

date.

STALLION 51 CORPORATION

Lee C. Lauderback

President/Chief Pilot

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 18, 2015