U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140 1200 New Jersey Avenue, SE. Washington, D.C. 20590

Dear Director Flight Standards,

The American Aeronautical Foundation (AAF) is the holder of Exemption Letter 9705D, dated April 29, 2014, Regulatory Docket No. FAA-2008-0479. This document allows exemption from 14 CFR 91.315, 14 CFR 119.5(g) and 14 CFR 119.21 for the purpose of carrying passengers on our North American B-25 for compensation or hire until June 30, 2016.

There have been no changes in our operating program except in the areas of improved safety via more standardization, tighter limitations, updated and improved checklists, and a newly developed “performance package” that allows us to calculate all takeoff, landing and single-engine performance data in varied atmospheric conditions.

Since the granting of our initial Exemption Letter in 2008, our aircraft has operated flawlessly without accident, incident, or any passenger injuries whatsoever due to the “equivalent level of safety” at which we operate the aircraft. In that time span, we have given thousands of passengers the safe experience of flying in a W.W.II aircraft to understand the sacrifices that our Greatest Generation has made. This “equivalent level of safety” is made possible by our strict adherence to the limitations of not only our Exemption Letter, but all applicable FAR's and the highly experienced pilots and maintainers who keep our aircraft in a safe, airworthy state.

We believe an extension of our current Exemption Letter is “in the public interest” due to the large numbers of people impacted by experiencing flight with us. Our aircraft has been involved in many “high visibility” events including, but not limited to: 1) the 70 th and final Reunion of the Doolittle Raiders; 2) many W.W. II reunions; 3) being seen by hundreds of thousands of people at the numerous airshows, fly-ins, and public events we attend; 4) media exposure involving news outlets, documentaries and published articles; 5) public education by school field trips to our base of operations and events; 6) honoring of our Veterans by flyovers during funerals, Memorial /Veterans Day events and FAA /State approved ash-scattering services. We believe that all of the previous factors have had a positive impact on the public through education, history and remembrance of our Veterans.

Due to the recent change of conditions necessary to obtain a Living History Flight Experience (LHFE) Exemption renewal, we now find ourselves unable to comply with the new extensive, complex rules in a timely manner, prior to the expiration of our current Exemption Letter. On behalf of the American Aeronautical Foundation, I am submitting a request to the FAA for an extension of our current Exemption Letter 9705D, which expires June 30, 2016. To allow us uninterrupted service to Veterans, their families and the public at large, we respectfully ask for the longest extension you can grant us to allow time to fully comply with the new LHFE rules.

Dana Dorsey Director of Operations, Chief Pilot
American Aeronautical Foundation

P.O. Box 22 Camarillo, CA 93011-0022 aafgroup.org (805) 559-9802