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TO: U.S. Departrilent ofTransportation Docket Management Facility 1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590



### PETITION FOREXEMPTION FROMFEDERAL AVIATION REGULATION 14 CFR PART 139.101 TO PERMIT CERTAIN UNSCHEDULED AIR CARRIER OPERATIONS AT WITTMAN REGIONAL AIRPORT (KOSH) AT LIMITED TIMES DURING EAA AIRVENTURE 2017

PETITIONER: Wittman Regional Airport 525 W 201h Avenue Oshkosh, Wisconsin 54902-6871 Dated: February 8, 2017I

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Petition Summary Wittman Regional Airport (KOSH), owned and operated byWinnebago County, and located in Oshkosh, Wisconsin, seeks an exemption from Federal Aviation Regulation (FAR) 14 CFRPart 139.101, general requirements for airport certification. The reliefsought under the exemption is to permit certain unscheduled air carrier operations at KOSH at limited times during the week ofExperimental Aircraft Association (EAA) Air Venture Oshkosh, July 24-30, 2017. Wittman Regional Airport, a large general aviation airport comprised ofapproximately 1,400 acres, does not hold a 14 CFRPart 139 certificate; that certificate was surrendered in 2006 following the discontinuation ofairline service in 2003. Fourrunways are maintained at the airport: • Runway 18-36: 8,002 ft x 150ft (concrete in good condition); ILS Rwy 36 (ILS NOTAMED out ofservice for EAAAirVenture Oshkosh) • Runway 9-27: 6,179 ft x 150ft(concrete in good condition) • Runway 5-23: 3,697 ft x 75 ft (asphalt in fair condition)- NOT AMED closed to air operations during EAA AirVenture • Runway 13-31: 3,061 ft x 75 ft (asphalt in fair condition)

- NOT AMED closed to airoperations during EAA AirVenture Taxiway A, which parallels Runway 18-36, is designated Runway 18L-36R from Taxiway A6 to a point 6,700 north (between Taxiway A2 and A1) for EAA AirVenture Oshkosh. Runway 18-36 is re-designated 18R-36L during that same time period. Runway 18L-36R is used byB-II aircraft or less. One hundred sixty-three (163) aircraft are based at the airport, ranging from turbine corporate aircraft and large piston multi-engine aircraft to gyrocopters. The airport sees nearly 70,000 aircraft operations annually, ofwhich approximately 18,000 occur during 10-dayperiod around EAA AirVenture Oshkosh. Operations in the air traffic control tower (ATCT) is contracted through Midwest AirTraffic Control Services, although FAA controllers and supervisors assume air traffic control operations duties for a 10- dayperiod for EAAAir Venture Oshkosh. Normal ATCT hours outside ofEAA AirVenture Oshkosh are 0600-2200 local daily. Wittman Regional Airport has a dedicated maintenance crew for operations and maintenance duties. ARFF services are provided by Oshkosh Fire Department utilizing Winnebago County-owned ARFF equipment, which meets 14 CFR Part 139.315 Index C standards. Reason for Petition EAA AirVenture Oshkosh is the largest fly-in event in the world. More than 10,000 aircraft visit KOSH overthe course ofoneweek. General aviation aircraft make up the vast majority ofthose visiting aircraft. Despite this, the airport receives requests to operate unscheduled charter operations or air carrier operations. Limited unscheduled charter operations occur during AirV enture, bringing attendees to the event. EAA members from a specific region ofthe US orforeign countries make up the majority ofthe fare-paying passengers on these charters. Thepassengers onthese flights are primarily comprised ofpilots and aviation enthusiasts who wish to attend EAA AirVenture Oshkosh but may not have the ability to attend by othertravel means. On a smaller scale, passengers may be employees and/or guests ofa specific aviation vendor, or also news media personnel attending to cover a specific topic occurring at AirVenture.The aircraft are operated by 14 CFR Part 121-certified air carriers. These flights maybe round-trip or one-way, depending on arrangements made bythe group. Additionally, AirVenture is host to the Old Glory HonorFlight ofNortheast Wisconsin. As a general aviation airport, both ofthese operations would necessarily call for the airport to meet the requirements of 14 CFRPart 139. Previously, the Federal Aviation Administration (FAA) Airport Division granted a time-limited Part 139 certificate to KOSH to accommodate these operations. Due to a recent legal decision, the FAAwill no longer grant a time

limited 14 CFR Part 139 operating c. ertificate. These charter and 

### aircarrier operations are essential to the continued success ofAirVenture, necessitating an exemption from 14 CFR Part 139.101 to allow them during the 2017 event. Description of ReliefSought Due to the scheduling nature ofthese operations, the specific aircraft type used for them cannotbe reasonably determined within the time constraints required to file this petition. The following aircraft were used for the aforementioned operations during AirVenture 2016: Carrier Flight Aircraft Operation Date Scheduled ARFF Number Index American 9490 B737-800 DFW-OSH 07/28/16 Arrival@ 

# c 1610 hrs American 9491 B737-800 OSH-DCA 07/29116 Depart@ 

# c 0645 hrs American 9492 B737

-800 DCA-OSH 07/29116 Arrival@ 

# c 1810 hrs American 9482 B737

-800 OSH-DFW 07/29/15 Depart@ 

# c 1910hrs Wittman Regional Airport is seeking relieffrom 14 CFR Part 139.101 for similar operations during Air Venture 2017. The operations during the 2017 event may include, but are not necessarily limited to, the above aircraft. American Airlines has historically operated aircraft for the Old Glory HonorFlights; however, it is anticipated that another airline will be the carrier in 2017 for the flight. As previously noted, charter flights may bebooked with any 14 CFRPart 121 operator. Operations ofaircraft to/from Wittman Regional Airport will be limited to aircraft no larger than ARFF Index C-category aircraft, with seating capacities ofno greaterthan 240 passengers. Airport Certification Manual Wittman Regional Airport will maintain and comply during air carrier operations with a current Airport Certification Manual (ACM) throughout the exemption period. All airport tenants and stakeholders in the ACM will have the opportunity to share, review and discuss their applicable portions ofthe manual. These participants include, but are not limited to management and personnel from airport management and maintenance/operations, Oshkosh Fire Department (ARFF), Winnebago County Sheriffs Department, Winnebago County Emergency Management, Oshkosh Police Department, FAA ATCT, FAATechnical, EAA, BaslerFlight Service, and Myers Aviation.

Operations Wittman Airport is responsible for, will train, and maintain records all personnel who have driving privileges on the airport, particularly those who have access to runway safety areas. Topics in this training include airport familiarization, signage, pavement markings, radio communications, and access to safety:

areas. This includes, but is not limited to, airport maintenance/operations staff, FAATechnical Operations staff , tenants who may assist in aircraft maintenance/recovery, ARFF and security personnel, and EAA employees/volunteers who have a need to access operational surfaces. All safety areas will be maintained and controlled in accordance with 14 CFRPart 139.309. Signage, pavement markings, and lighting necessary for aircraft operations will be maintained per 14 CFR Part 139.311 and will further be in accordance with the Signage Plan submitted with the Airport Certification Manual. Airport Rescue and Fire Fighting <ARFF) Requirements To mitigate safety risks to aircraft occupants as well as persons and property on the ground, and to further comply with applicable sections of 14 CFRPart 139, the following actions will betaken during applicable air carrier operations: • ARFF equipment is provided with a minimum capacity of3,000 gallons ofwater for AFFF production along with firefighters who have received live fire training and additional training as outlined in 14 CFRPart 139.319(i) in the past 12 months. Additional firefighting apparatus from the City ofOshkosh Fire Department are on standby status at the airport fire station orcan respond to any incidents onthe airport. • ARFF equipment will be located at pre-determined positions onthe airport a minimum of 15 minutes before the arrival and departure ofthese aircraft and will remain a minimum of 15 minutes after the operation is complete. • ARFF vehicles fire suppression systems are tested annually prior to EAA AirVenture Oshkosh by the vehicle manufacture; this includes dry chemical and refractometer testing ofeach applicable system. ARFF equipment based at KOSH: • ARFF 114- 2000 Ford F550, Rapid Intervention Vehicle 150 gallons ofpre-mixed foam and water 500 lbs Purple K

• ARFF 214-

• ARFF 314- 10 lbs C02 1986 Oshkosh T-1500 frre /rescue truck 1585 gallons ofwater 205 gallons offoam 700 lbs ofdry chemical 10 lbs C02 2009 Oshkosh Striker 1500 frre/rescue truck 1500 gallons ofwater 210 gallons offoam 500 lbs Purple K dry chemical 20 lbs C02 In addition to the above safety mitigations, all ARFF personnel stationed at the airport and those assigned to duty at the airport during AirVenture undergo extensive training to properly respond to emergencies involving air carrier aircraft. • ARFF personnel receive initial and recurrent training (minimum every 12 months) in the following areas: • Airport familiarization; • Aircraft familiarization;I

• Rescue and frrefighting personnel safety; • Emergency communication system on the airport, including frre alarms; • Use ofthe frre hoses, nozzles, turrets, and other appliances required; • Application ofthe types ofextinguishing agents required for compliance with this part; • Emergency aircraft evacuation assistance; • Firefighting operations; • Adapting and using structural rescue and firefighting equipment for aircraft rescue and frrefighting; • Aircraft cargo hazards, including hazardous materials/dangerous goods incidents; • Familiarization with frrefighters' duties under the Airport Emergency Plan. • ARFF personnel are trained inthe above subject areas following a site specific training curriculum. The City ofOshkosh FireDepartment is responsible for maintaining the ARFF training curriculum and records ofall training given to each individual. • Live Fire Training • All ARFF personnel that will be on duty on the day oftheplanned charter flight(s) shall participate in a live-frre drill prior to initial performance ofARFF duties and participate in live-fire training at least once every 12 months at an FAA acceptable Regional ARFF training facility. • Basic Emergency Medical Training • The City ofOshkosh Fire Department is responsible for providing training for, and maintaining the records ofall frrefighter and Emergency Medical Services (EMS) personnel. These personnel will be providing medical services during EAA AirVenture. Emergency Plan The Emergency Plan required by CFR Part 139.325 is an appendices to the overall EAA, Airport Emergency Plan for EAAAirVenture. This review is conducted in conjunction with a tabletop exercise of the EAA AirVenture Oshkosh emergency plan. The stakeholders ofeach plan comprise the same individuals and agencies. Fueling Operations • Fueling ofall 14 CFR Part 139-related flights will be conducted byBaslerFlight Service. • The fuel supervisor receives biennial training through the National Air Transportation Association (NATA) Safety 151 Supervisor Online Training course for 14 CFR 139.32 1(b)(l) through (b)(6) and 139.321(e)(l). This individual further trains all other line personnel in refueling operations for 14 CFRPart 139 operations. • Each employee additionally receives live fire exinguisher training annually prior to the commencement ofEAA AirVenture Oshkosh. • Each fueling employee will also receive drivertraining from airport management on airport familiarization, signage, pavement markings, and communications, even though these personnel are restricted from operating fueling vehicles on air operations areas. Airfield Operations Safety • Wittman Regional Airport management and maintenance/operations personnel are all trained in airport self-inspection procedures and conduct inspections at least twice daily prior to ATCT opening and after ATCT closing. Additional inspections are conducted as needed during the day, as requested by ATCT orupon reports bypilots orpersonnel ofrunway contaminants. • Arrivals and departures ofair carrier aircraft will operate from Runway 18R-36L exclusively. • During EAA Air Venture, the OSH ATCT hours are 0600 hours local until 2000 hours local time, as published in the event Notice to Airmen (NOT AM). The airport is closed to all aircraft

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operations, including air carrier arrival and departure operations, outside ofthe published ATCT hours. • The Runway 18R-36L safety area of500 feet wide and 1000 feet long will be clear ofaircraft, personnel, vehicles, and any object not fixed by function; ordeclared distances will be implemented to create the required runway safety area and disseminated to pilots as a Notice to Airmen (NOT AM). • Runway 18R-36L shall be inspected bytrained Wittman Airport maintenance and management personnel prior to each air carrier operation. Up to ten (1 0) airport personnel are on duty at any time during air carrier operations. Each employee has received training in all aspects of 14 CFR 139.303. • Wittman Regional Airport enters into a Letter ofAgreement (LOA) with the FAAATCT, Oshkosh Fire Department, and Experimental Aircraft Association annually to outline procedures for aircraft emergency responses during EAA AirVenture Oshkosh. • Wittman Regional Airport enters into a Letter ofAgreement (LOA) with FAAATCT and Experimental Aircraft Association for control ofaircraft movement and non-movement areas on the airport during EAAAirVenture Oshkosh. Interest ofthe Petitioner As the host airport for EAA' AirVenture Oshkosh, Wittman Regional Airport has a vested interest in the continued success ofthe event. AirVenture is the flagship aviation event in the United States and is one of the premier aviation events in the world. With 550,000 annual attendees, more than 10,000 visiting aircraft, and hundreds ofparticipating exhibitors, AirVenture is a cornerstone ofAmerica' s general aviation community. Participants at EAA AirVenture run the gamut ofaviation interests, from ultralight and light sport aircraft, rotorcraft, amateur-built aircraft, vintage aircraft, warbird aircraft, general aviation production aircraft, corporate aircraft, and military aircraft to space travel vehicles. Many ofthe attendees are active general aviation pilots; others are student pilots, and others are simply aviation enthusiasts. Regardless ofthe level ofinterest, increasing the means oftravel for all interested parties to attend EAA AirYenture Oshkosh-in this case via unscheduled air carrier charters-is important to the success ofthe airport, the EAA organization, and the aviation community as a whole. Dueto its importance to both the local economy (estimated $111 million inregional economic benefits) and the national aviation community, EAA AirVenture and its weeklong operations can only benefit from the proposed 14 CFRPart 139 exemption request.

Interest ofthe Public Old Glory Honor Flight is a non-profit organization that sends veterans from World War IT, the Korean War, and the Vietnam Warto Washington D.C. to visit the nation's war memorials. Specifically, Old Glory Honor flight caters to veterans from the state ofWisconsin who wish to personally see the monuments dedicated to their service. By hosting Old Glory Honor flight during AirVenture, KOSH provides the facilities for a well-deserved homecoming for dozens ofveterans every year. Bringing them home to Oshkosh not only serves to thank them for their service, butto teach AirVenture attendees, who greet them upon their return flight yearly, ofthe sacrifices they made. By facilitating certain, non-scheduled charter flights to bring attendees to the world' s largest fly-in event, KOSH can contribute to the diversity ofits attendees. Due to the nature ofAirVenture, which attracts the general public, grassroots aviators, aviation business leaders, and international visitors alike, the airport must be flexible in its ability to accommodate multiple types ofarrivals. Ensuring Wittman Regional

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Airport can accept limited air carrier operations during the week ofAirVenture will serve to maintain the diverse nature ofthe event's attendees. 

### Conclusion As the largest fly-in event 

### in the world, AirVenture attracts a diverse set ofaviation operations. Over the course ofone week, KOSH needs to have the ability to accommodate all aircraft that attend the event, from light sport aircraft to air carriers. KOSH has made the logistical and operational preparations to host a wide spectrum ofaircraft during AirVenture, but regulatory barriers exist to ensuring the event can accept all attendees wit hout interruption. KOSH urges the FAA to consider the above information and grant the airport an exemption from 14 CFRPart 139.101 to ensure the continued success ofEAA Air Venture.

Wittman Regional Airport



# (/~)u Jtill() PeterM. Moll Airport Director February 8, 2017