## Exemption Request

Aircraft:

B‐29					N529B

B‐24					N24927

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

Reason for Exemption:

The	Commemorative	Air	Force	is	re questing	this	exemption	to	pro vide	operational relief	from	the	restrictions	of	operating	over	Densely	Populate d	Areas	for	our	B‐29 Superfortress	N529B	and	our	B‐ 24	N24927.	The	inability	to	opera te	over	densely populated	areas	significantly	prevents	the	aircraft	from	being placed	on	display	in prominent	public	arenas.		Further more,	both	aircraft	are	approv ed	for	the	LHFE program	and	the	densely	populated	area	restriction	severely	lim its	the	public’s opportunity	for	the	experience	s upported	by	the	agency	in	autho rizing	the	LHFE	for

both	aircraft.		The	basis	of	our request	is	focused	on	the	fact both	aircraft	are	four engine	airplanes	with	outstanding	engine	reliability	and	also	h ave	excellent	3	engine operational	capability.

Equivalent Level of Safety:

1. Similar aircraft operation with limited certificates:

Similar	aircraft	of	the	same	vin tage	and	equipment	have	been	ce rtified	in	the	limited catagory	and	are	not	restricted by	the	densely	populated	area	o ver	flight	rules. These	aircraft	are	of	comparable make,	construction,	and	materi als.		They	are	often produced	by	the	same	manufacture rs	and	constructed	to	the	same standards.		Often equipment	and	parts	for	both	air frame	and	power	plant	construct ion	are	identical. Examples	of	the	aircraft	that	ar e	comparable	are	the	B‐17,	B‐25 ,	A‐26,	&	DC‐3.		The Boeing	B‐17	represents	the	greate st	example	of	a	Boeing	built	p roduct	with	4 engines	and	similar	design	and	c onstruction.	The	major	reasons our	B‐29	and	B‐24 are	certificated	in	the	experime ntal	category	is	the	modificati ons	we	made	to improve	engine	reliability	on	the	B‐29	and	the	modifications	to return	the	B‐24	to its	wartime	configuration	from	t he	modifications	made	to	the	ai rplane	when	it	was used	for		civilian	transportation.

2. Engine Design & Reliability The	B‐29	is	fitted	with	four	(4 )	Curtis	Wright	R‐3350	power	pla nts.		Each	of	these engines	have	been	carefully	re‐designed	and	constructed	by	indu stry	leaders	to provide	maximum	reliability	and	longevity.		Each	engine	was	con structed	from certificated	parts	to	provide	an	engine	that	is	de‐rated	for	th e	same	equivalent

power	output.In	2010	all	four	(4)	engines	on the	B‐29	were	retrofitted	to	th ese	new	engine designs	and	were	carefully	tested	for	operation. The	B‐24	operates	with	Pratt	& Whitney	R‐1830‐94	engines.		Thes e	engines although	on	an	experimental	airc raft,	are	maintained	to	the	sta ndards	of	a	type certificated	‐94	power	plants	use d	on	many	limited	and	standard category	aircraft, most	notably	the	DC‐3.

4. Standards for Crew Training

Our	crews	train	to	the	standards of	the	LHFE	program,	which	are the	same	as standards	required	for	aircraft	with	limited	certifications	and our	crews	have	the same	requirements	for	type	r atings	in	both	aircraft.

5. Operational Weights Operational	capability	is	further	enhanced	by	the	low	operating weights	of	both

aircraft.	The	Commemorative	Air	F orce	has	taken	drastic	measure s	to	reduce	weight and	make	two	engine	operations	even	more	feasible	for	both	airc raft.

7. Fire Suppression and Detection Fire	Suppression	is	provided	thr ough	two	Halon	bottle	systems	i n	each	aircraft.		In addition	to	this	are	highly	trai ned	flight	crew scanners	who	ar e	trained	in	the detection	and	prevention	of	fire	related	emergencies.

Summary: The	authorization	to	operate	in the	LHFE	program	is	evidence	of a	recognized	public benefit.	The	populated	area	over flight	restriction	severely	li mits	the	public’s	access and	ability	to	enjoy	and	learn	a bout	these	aircraft	and	their	c ontribution	to	our victories	in	WW	II.	The	reliability	of	the	engines	and	the	fact there	are	four	of	them, establish	the	equivalent	level	of	safety	to	aircraft	with	fewer engines. I	look	forward	to	the	opportunit y	to	work	with	the	Agency	answe ring	questions	as they	arise	during	the	staffing	of	our	request.

Robert	A.	Stenevik Vice	President	of	Safety,	Maintenance	and	Operations

Commemorative	Air	Force

Cell	817‐705‐5817 rstenevik@cafhq.org