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### Petition for Exemption Name: Jim Bilbrey

DBA: Adventure Flights Date: 10 - 01 - 16 Address: 19301 Jasmine Court, L ake Elsinore, California 92530 Phone: Office: 951 - 678 - 4334 Mobile: 951 - 232 - 3025 Email: jim007@advflights.com Regarding CFR 141.5 D ocket Number: FAA - 2010 - 0715 Reason for Request: Since 1975 Adventure Flights, Inc. (AF) has trained over 35 0 Lighter - Than - Air balloon pilots who have earned their private or commercial Lighter - Than - Air balloon rating. Since 1993, AF has trained over 150 s tudents under CFR 141, who have earned their private or commercial Li ghter - Than - Air Ratings. The school’s FAA certification number is QJBV584K. To date, AF has enjo yed a 100% pass rate. Under contract with the FAA, we have trained many FAA Lighter - Than - A ir Balloon Designated Examiners, who are currentl y deployed all over the United States. AF has assisted in setting up many Li ghter - Than - Air training facilities in foreign countries that had no Lighter - Than - Air training facilities or regulations. Since 1978 , AF has operated an FAA Certified L ighter - Than - Air Repair Station (QJBR584K) in California and has set up similar L ighter - Than - Air repair stations in foreign countries that had no L ighter - Than - Air repair stations facilities. FAR 141.5(d) was written to address training requirements primaril y for fixed wing and helicopter schools and not Part 141 L ighter - Than - Air schools. The pool of Li ghter - Than - Air students in the United States that a Part 141 L ighter - Than - Air school has to draw from is far less than 1 % of the size available to a fixed wing or helicopter Part 141 school. Yet, FAR 141 requires the same minimum number of students to be trained at a L ighter - Than Air school as compared to fixed wing or helicopter schools. For the past 20 years, the FAA has interpreted FAR 141.5(d) to mean at least 10 courses must be completed with an 80% pass rate. AF and several other Li ghter - Than - Air part 141 schools have been able to achieve this minimum requirement. It appears that after October 20, 2009, the FAA is interpreting this regulation to mean that the minimum requirement is now 10 different individuals rather than training courses. The effect that this new “interpretation” of 141.5 has on the 6 existing L ighter - Than - Air schools is catastrophic. It appe ars that no existing Lighter - Than - Air Part 141 pilot school can meet the “new requirements” of FAR 141.5(d) and (e). Therefore, when a Lighter - Than - Air school certificate comes up for renewal as it does every 24 months, it will not be renewed. The effect that the new interpretation has on all Lighter - Than - Air schools is that they will cease to exist. The public is not served by forcing all Lighter - Than - Air Part 141 Pilot Schools out of business. There is no CFI rating for L ighter - Than - Air pilots and the refore no professional training other than under Part 61. Under Part 61, an y commercial L ighter - Than - Air pilot has instructor privileges.Page 2 of 2

Very few commercial balloon pilots have the level of knowledge and experience of a Lighter Than - Air Part 141 balloon instructor. Also, under Part 141, there is 18 minimum flight hours required to earn a commercial Lighter - Than - Air rating. Under Part 61, 35 hours are required. If no L ighter - Than - Air Part 141 Schools are available to students, the quality of L ighter - Than - A ir training will greatly

decrease at the same time the cost of training will greatly increase due to the fact that an additional 17 hours of flight training are required under Part 61. As of November 8, 2016, our school has trained 9 of the 10 required st udents. Unless we complete a 10 th student by November 30, 2016, our Air Agency certificate will expire and will not be renewed. Extent of Relief I request that: 1) Our Part 141 School be given an exemption to rule 141.5, as we have thus far trained on ly 9 of the 10 required students. 2 ) As a long term solution, FAR 141.5 be amended to included the following language as indicated in red: Recommended FAR 141.5: **141.5 Requirements for a pilot school certificate.**  The FAA may issue a pilot school c ertificate with the appropriate ratings if, within the 24 calendar months before the date application is made, the applicant— (a) Completes the application for a pilot school certificate on the form and in the manner prescribed by the FAA; (b) Has held a p rovisional pilot school certificate; (c) Meets the applicable requirements under subparts A through C of this part for the school certificate and associated ratings sought; (d) Has trained and recommended at least 10 different people, or in the case of L - T - A schools 4 different people , for a knowledge test or a practical test, or any combination thereof, and at least 80 percent of those persons passed their tests on the first attempt; and (e) Has graduated at least 10 different people, or in the case of L - T - A schools 4 different people, from the school's approved training courses. I respectfully

request that this Petition for Exemption be granted expeditiously due to the fact that our L - T - A Part 141 School will be forced to cease operations on December 1, 20 16. Sincerel y, Jim Bilbrey