.·I 

TO: U.S. Departrilent ofTransportation 

Docket Management Facility 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

PETITION FOR EXEMPTION FROM FEDERAL 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 201

h Avenue 

Oshkosh, Wisconsin 54902-6871 

Dated: February 8, 2017 
I 

) 

Petition Summary 

Wittman Regional Airport (KOSH), owned and operated by Winnebago County, and located in Oshkosh, 

Wisconsin, seeks an exemption from Federal Aviation Regulation (FAR) 14 CFR Part 139.101, general 

requirements for airport certification. The relief sought under the exemption is to permit certain 

unscheduled air carrier operations at KOSH at limited times during the week of Experimental Aircraft 

Association (EAA) Air Venture Oshkosh, July 24-30, 2017. 

Wittman Regional Airport, a large general aviation airport comprised of approximately 1 ,400 acres, does 

not hold a 14 CFR Part 139 certificate; that certificate was surrendered in 2006 following the 

discontinuation of airline service in 2003. 

Four runways are maintained at the airport: 

• Runway 18-36: 8,002 ft x 150ft (concrete in good condition); ILS Rwy 36 (ILS NOTAMED out 

of service for EAA AirVenture 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 air operations 

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 by B-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, of which approximately 18,000 occur during 10-day period around EAA AirVenture Oshkosh. 

Operations in the air traffic control tower (ATCT) is contracted through Midwest Air Traffic Control 

Services, although FAA controllers and supervisors assume air traffic control operations duties for a 10-

day period for EAA Air Venture Oshkosh. Normal ATCT hours outside of EAA AirV enture 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 

over the course of one week. General aviation aircraft make up the vast majority of those 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 of the US or foreign countries make up the majority ofthe fare-paying 

passengers on these charters. The passengers on these flights are primarily comprised of pilots and 

aviation enthusiasts who wish to attend EAA AirVenture Oshkosh but may not have the ability to attend 

by other travel means. On a smaller scale, passengers may be employees and/or guests of a 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 may be round-trip or 

one-way, depending on arrangements made by the group. Additionally, AirVenture is host to the Old 

Glory Honor Flight of Northeast Wisconsin. As a general aviation airport, both of these operations would 

necessarily call for the airport to meet the requirements of 14 CFR Part 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 FAA will no longer grant a timelimited 14 CFR Part 139 operating c.ertificate. These charter and air carrier operations are essential to the 

continued success of AirVenture, necessitating an exemption from 14 CFR Part 139.101 to allow them 

during the 2017 event. 

Description of Relief Sought 

Due to the scheduling nature of these operations, the specific aircraft type used for them cannot be 

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 relief from 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 Honor Flights; 

however, it is anticipated that another airline will be the carrier in 2017 for the flight. As previously 

noted, charter flights may be booked with any 14 CFR Part 121 operator. Operations of aircraft to/from 

Wittman Regional Airport will be limited to aircraft no larger than ARFF Index C-category aircraft, with 

seating capacities of no greater than 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 of the 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, 

FAA Technical, EAA, Basler Flight 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, FAA Technical 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 CFR Part 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 CFR Part 139, the following actions will be taken during applicable 

air carrier operations: 

• ARFF equipment is provided with a minimum capacity of 3,000 gallons of water for AFFF 

production along with firefighters who have received live fire training and additional training as 

outlined in 14 CFR Part 139 .319(i) in the past 12 months. Additional firefighting apparatus from 

the City of Oshkosh Fire Department are on standby status at the airport fire station or can 

respond to any incidents on the airport. 

• ARFF equipment will be located at pre-determined positions on the airport a minimum of 15 

minutes before the arrival and departure of these 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 of each applicable 

system. 

ARFF equipment based at KOSH: 

• ARFF 114- 2000 Ford F550, Rapid Intervention Vehicle 

150 gallons of pre-mixed foam and water 

500 lbs Purple K 

• ARFF 214-

• ARFF 314-

10 lbs C02 

1986 Oshkosh T -1500 frre/rescue truck 

1585 gallons of water 

205 gallons of foam 

700 lbs of dry chemical 

10 lbs C02 

2009 Oshkosh Striker 1500 frre/rescue truck 

1500 gallons of water 

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 of the frre hoses, nozzles, turrets, and other appliances required; 

• Application of the types of extinguishing 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 in the above subject areas following a site specific training 

curriculum. The City of Oshkosh Fire Department is responsible for maintaining the ARFF 

training curriculum and records of all training given to each individual. 

• Live Fire Training 

• All ARFF personnel that will be on duty on the day of the planned charter flight(s) shall 

participate in a live-frre drill prior to initial performance of ARFF 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 of Oshkosh Fire Department is responsible for providing training for, and 

maintaining the records of all 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 EAA AirVenture. This review is conducted in conjunction with a tabletop exercise of 

the EAA AirVenture Oshkosh emergency plan. The stakeholders of each plan comprise the same 

individuals and agencies. 

Fueling Operations 

• Fueling of all 14 CFR Part 139-related flights will be conducted by Basler Flight Service. 

• The fuel supervisor receives biennial training through the National Air Transportation 

Association (NATA) Safety 151 Supervisor Online Training course for 14 CFR 139.321(b)(l) 

through (b)(6) and 139.321(e)(l). This individual further trains all other line personnel in 

refueling operations for 14 CFR Part 139 operations. 

• Each employee additionally receives live fire exinguisher training annually prior to the 

commencement ofEAA AirVenture Oshkosh. 

• Each fueling employee will also receive driver training 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 or upon reports by pilots or personnel of runway contaminants. 

• Arrivals and departures of air carrier aircraft will operate from Runway 18R-36L exclusively. 

• During EAA Air Venture, the OSH A TCT 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 
, 

,./ 

operations, including air carrier arrival and departure operations, outside of the published ATCT 

hours. 

• The Runway 18R-36L safety area of 500 feet wide and 1000 feet long will be clear of aircraft, 

personnel, vehicles, and any object not fixed by function; or declared 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 by trained 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 of Agreement (LOA) with the FAA ATCT, 

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 of Agreement (LOA) with FAA ATCT and 

Experimental Aircraft Association for control of aircraft movement and non-movement areas on 

the airport during EAA AirVenture Oshkosh. 

Interest of the Petitioner 

As the host airport for EAA 'AirVenture Oshkosh, Wittman Regional Airport has a vested interest in the 

continued success of the 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 of participating exhibitors, AirVenture is a cornerstone of America's general 

aviation community. Participants at EAA AirVenture run the gamut of aviation 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 of the attendees 

are active general aviation pilots; others are student pilots, and others are simply aviation enthusiasts. 

Regardless of the level of interest, increasing the means of travel for all interested parties to attend EAA 

AirY enture Oshkosh-in this case via unscheduled air carrier charters-is important to the success of the 

airport, the EAA organization, and the aviation community as a whole. 

Due to its importance to both the local economy (estimated $111 million in regional economic benefits) 

and the national aviation community, EAA AirVenture and its weeklong operations can only benefit from 

the proposed 14 CFR Part 139 exemption request. 

Interest of the Public 

Old Glory Honor Flight is a non-profit organization that sends veterans from World War IT, the Korean 

War, and the Vietnam War to Washington D.C. to visit the nation's war memorials. Specifically, Old 

Glory Honor flight caters to veterans from the state of Wisconsin 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 of veterans every year. Bringing them 

home to Oshkosh not only serves to thank them for their service, but to teach AirVenture attendees, who 

greet them upon their return flight yearly, of the 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 of its attendees. Due to the nature of AirVenture, 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 of arrivals. Ensuring Wittman Regional 
, 

Airport can accept limited air carrier operations during the week of AirVenture will serve to maintain the 

diverse nature of the event's attendees. 

Conclusion 

As the largest fly-in event in the world, AirVenture attracts a diverse set of aviation operations. Over the 

course of one 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 of aircraft during AirVenture, but regulatory barriers exist to ensuring the event can 

accept all attendees without interruption. KOSH urges the FAA to consider the above information and 

grant the airport an exemption from 14 CFR Part 139.101 to ensure the continued success ofEAA 

Air Venture. 

Wittman Regional Airport 

(/~ )u Jtill() 

Peter M. Moll 

Airport Director 

February 8, 2017