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Petition for Exemption 

Name: Jim Bilbrey DBA: Adventure Flights Date: 10-01-16

Address: 19301 Jasmine Court, Lake Elsinore, California 92530

Phone: Office: 951-678-4334 Mobile: 951-232-3025 Email: jim007@advflights.com

Regarding CFR 141.5 Docket Number: FAA-2010-0715

Reason for Request: 

Since 1975 Adventure Flights, Inc. (AF) has trained over 350 Lighter-Than-Air balloon pilots 

who have earned their private or commercial Lighter-Than-Air balloon rating. Since 1993, AF 

has trained over 150 students under CFR 141, who have earned their private or commercial 

Lighter-Than-Air Ratings. The school’s FAA certification number is QJBV584K. 

To date, AF has enjoyed a 100% pass rate. Under contract with the FAA, we have trained many 

FAA Lighter-Than-Air Balloon Designated Examiners, who are currently deployed all over the 

United States. AF has assisted in setting up many Lighter-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 Lighter-Than-Air Repair Station (QJBR584K) in California and has 

set up similar Lighter-Than-Air repair stations in foreign countries that had no Lighter-Than-Air 

repair stations facilities. 

FAR 141.5(d) was written to address training requirements primarily for fixed wing and 

helicopter schools and not Part 141 Lighter-Than-Air schools. The pool of 

Lighter-Than-Air students in the United States that a Part 141 Lighter-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 Lighter-ThanAir 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 Lighter-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 Lighter-Than-Air 

schools is catastrophic. It appears 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 Lighter-Than-Air pilots and therefore no professional training other 

than under Part 61. Under Part 61, any commercial Lighter-Than-Air pilot has instructor 

privileges. 
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Very few commercial balloon pilots have the level of knowledge and experience of a LighterThan-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 Lighter-Than-Air Part 141 Schools are available to students, the quality of Lighter-Than-Air 

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 students. Unless we 

complete a 10th 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 only 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 certificate 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 provisional 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, 2016. 

Sincerely, 

Jim Bilbrey