AFS-15-2820-E 

This letter amends Condition and Limitation No. 6 of Exemption No. 12558, originally issued 

by the FAA on August 20, 2015. The correction includes the type of maintenance program 

that the petitioner needs to comply with for the duration of this exemption. This version is the 

amended Exemption No. 12558 that includes the aforementioned changes. We have made the 

correction in our records as of August 31, 2015. 

August 20, 2015 

 Exemption No. 12558 

 Regulatory Docket No. FAA-2002-12993 

Ms. Kathleen A. Yodice 

Counsel 

Stallion 51 Corporation 

411 Aviation Way, Suite 245 

Frederick, MD 21701 

Dear Ms. Yodice: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated June 18, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Stallion 51 Corporation (Stallion 51), for an extension of Exemption No. 8593, as 

amended. That exemption from § 91.315 of Title 14, Code of Federal Regulations (14 CFR) 

allowed Stallion 51 to provide initial and recurrent training flights in its two North American 

TF-51 (TF-51) airplanes certificated as limited category civil aircraft. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to Stallion 51. 

Corrected Copy
 2

Although you requested an extension of Exemption 8593, as amended, that exemption expired 

on July 31, 2015. Therefore, we are issuing Stallion 51 a new exemption. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 8593, as amended (copy 

enclosed), the FAA found that it is becoming increasingly difficult to provide initial and 

recurrent training in older, high performance aircraft. The FAA concluded that an equivalent 

level of safety could be met by the petitioner’s use of approved flight and maintenance 

manuals, as well as following the conditions and limitations stated in this exemption. 

Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously granted in Exemption No. 

8593, as amended; 

 the reasons stated by the FAA for granting the enclosed exemption also apply to the 

situation you present; and 

 a grant of exemption is in the public interest. 

Our Decision 

The FAA updates and modifies conditions and limitations of its exemptions as they are 

issued. The conditions and limitations of Exemption No. 8593, as amended, have been 

updated for consistency with similarly issued exemptions in light of recent safety concerns. 

The FAA has modified and supplemented the conditions and limitations of Exemption No. 

8593, as amended, to better define the intent and add additional oversight. Please note that the 

conditions and limitations included with an exemption are not based on specific regulations 

but are the FAA’s means of ensuring an equivalent level of safety. This necessitates 

limitations that go beyond the established regulations due to the fact that the proposed 

operation is, by its need for an exemption, outside the normal regulatory structure. These new 

conditions and limitations match those contained in grants of exemption issued to similarly 

situated organizations. 

Condition and Limitation No. 1 was added to describe the aircraft covered by this exemption. 

 Condition and Limitation No. 2(b) in Exemption No. 8593, as amended, was removed to 

match those contained in subsequent grants of exemption issued to similarly situated 

organizations. 

Condition and Limitation Nos. 2 and 3 were added to define the activity permitted under this 

exemption, and to define requirements for persons receiving flight instruction in the aircraft 

identified in Condition and Limitation No. 1. In your petition, you state that “[o]rientation 

flights are offered to [...] even individuals who are currently student pilots, or may become 

student pilots in the future.” Under the terms of this exemption, Stallion 51 may only offer 

flights for the purpose of recurrent pilot training or proficiency to persons who hold at least a 
 3

private pilot certificate with a single engine land rating. This exemption does not permit 

Stallion 51 to conduct orientation rides or training flights for those persons who do not hold at 

least a private pilot certificate. This limitation is consistent with the FAA’s findings in 

Exemption No. 10205, as amended, which established that persons receiving flight training 

under that exemption must hold at least a private pilot certificate with applicable category and 

class ratings. 

The training syllabus and chief instructor requirements identified in Condition and Limitation 

Nos. 4 and 5 will allow the FAA to be aware of the scope of the training activity under the 

exemption, and will add some assurances regarding the qualifications of the chief instructor 

employed by Stallion 51. 

Condition and Limitation No. 6, which is Condition and Limitation No. 1 in Exemption 8593, 

as amended, has been amended to emphasize specific 14 CFR requirements that apply to the 

aircraft and operation. 

Condition and Limitation No. 7, which is Condition and Limitation No. 2 in Exemption 8593, 

as amended, has been amended to include a minimum total of 1,500 hours of aeronautical 

flight experience, including 25 hours as pilot-in-command in the aircraft make and model; 25 

takeoffs and 25 landings in any variant of P-51 or TF-51 airplane. This amendment is 

necessary to meet recent safety concerns and for consistency with similarly granted 

exemptions. 

Condition and Limitation No. 8 was added to require Stallion 51 to inform persons receiving 

flight instruction under this exemption that its aircraft hold a limited airworthiness certificate, 

the significance of the limited airworthiness certificate as compared to a standard 

airworthiness certificate, and that the FAA has authorized this flight under a grant of 

exemption from the requirements of § 91.315. 

Condition and Limitation No. 9 was added to require Stallion 51 to notify the jurisdictional 

Flight Standards District Office (FSDO) by written report, electronic mail, or facsimile, of 

certain occurrences of damage, failure, or malfunction within 24 hours. 

Condition and Limitation No. 10 has been added to increase operational safety by specifying 

minimum flight visibility. 

Condition and Limitation No. 11 has been added to ensure that only a flight instructor and a 

trainee are permitted aboard the aircraft during flight operations. 

Condition and Limitation No. 12 has been added to ensure that Stallion 51 aircraft have the 

equipment listed in §§ 91.205 (as applicable to the operation being conducted) and 91.207 and 

that the equipment must be in an operable condition during the flight. 

The FAA has determined that the justification for the issuance of Exemption No. 8593, as 

amended, remains valid with respect to this exemption and is in the public interest. 
 4

Therefore, under the authority provided by 49 U.S.C. 106(f), 40113 and 44701, which the 

FAA Administrator has delegated to me, I grant Stallion 51 Corporation (Stallion 51) an 

exemption from 14 CFR § 91.315 to the extent necessary to allow Stallion 51 to provide 

initial and recurrent training flights in its two North American TF-51 (TF-51) airplanes 

certificated as limited category civil aircraft, subject to the conditions and limitations below. 

Conditions and Limitations 

1. This exemption applies only to the Stallion 51 TF-51 aircraft. The aircraft, when 

used for flight instruction under this exemption, must be in the operational control 

of Stallion 51. 

2. The privileges of this exemption are limited to flight training intended for the 

purpose of recurrent pilot training, proficiency, or training for an FAA certificate, 

rating, or authorization. 

3. Persons receiving flight training under this exemption must hold at least a private 

pilot certificate with applicable category and class ratings. 

4. The privileges of this exemption may only be exercised under the auspices of a 

training manual that identifies specific syllabi for all ground and flight training 

activities conducted. The exemption holder must provide all students with a copy 

of the appropriate syllabus prior to conducting training. The training manual must 

also contain the following information: 

a. A syllabus of each training activity under this exemption. 

b. A description of operational limitations for each aircraft used for flight training 

under this exemption. 

c. A requirement that pilots receiving instruction under this exemption must log 

the flight time in a pilot logbook or training record. Each entry must cite the 

appropriate Stallion 51 syllabus and lesson taught during that flight. 

d. The training manual must identify the name and contact information for the 

individual acting as chief instructor for Stallion 51 operations under this 

exemption. The individual named as chief instructor must meet all the 

following qualifications: 

i. Hold a commercial pilot certificate or airline transport pilot certificate 

with instrument, category, and class, ratings for all aircraft operated 

under this exemption. 

ii. Hold a flight instructor certificate with appropriate category and class 

ratings. 

5. Before Stallion 51 may exercise the privileges of this exemption, it must provide 

the following documents to the Flight Standards District Office (FSDO) with 

geographic responsibility for the principal airport where flight training will be 
 5

conducted, and must be provided to any representative of the FAA Administrator 

upon request: 

a. A copy of the current exemption; 

b. A copy of the most current Stallion 51 training manual, and; 

c. The qualifications of each instructor conducting training under the terms of the 

exemption. 

6. Stallion 51 must continue to maintain its TF-51 aircraft in an airworthy condition 

in accordance with the: 

a. Maintenance requirements specified in the TF-51 aircraft type specification 

sheet, as amended; 

b. FAA-approved maintenance inspection program that meets the requirements of 

§§ 91.409(a) and (b); and 

c. Appropriate military technical manuals for the TF-51 aircraft. 

7. The person providing instruction in the TF-51 must: 

a. Hold at least a commercial pilot certificate with an airplane single-engine land 

rating and flight instructor certificate (CFI) with airplane single-engine rating; 

b. Have at least a total of 1,500 hours of aeronautical flight experience, including 

25 hours as pilot-in-command in the aircraft make and model; 25 takeoffs and 

25 landings in any variant of P-51 or TF-51; and have accomplished within the 

previous 90 days, three takeoffs and three landings to a full stop in any variant 

of P-51 or TF-51 airplane. 

8. Stallion 51 must inform anyone receiving flight instruction under this exemption 

that its aircraft hold a limited airworthiness certificate, explain the significance of 

the airworthiness certificate as compared to a standard airworthiness certificate, 

and that the FAA has authorized this flight under a grant of exemption from the 

requirements of § 91.315. The explanation of the significance of a limited 

airworthiness certificate compared to a standard airworthiness certificate must 

include at least the following information: 

a. The FAA has not established nor has it approved limited category 

airworthiness certificated aircraft manufacturing standards. In contrast, 

standard category airworthiness certificated aircraft are manufactured to FAAapproved standards, including standards addressing the design of the aircraft 

and life-limited parts; 

b. Limited category airworthiness certificated aircraft are issued when the FAA 

finds the aircraft— 

i. Has been previously issued a limited category type certificate and the 

aircraft conforms to that type certificate; and 
 6

ii. To be in a good state of preservation and repair and is in a safe 

operating condition. 

c. Standard category airworthiness certificates are issued for an aircraft when the 

FAA finds the— 

i. Aircraft has been built and maintained in accordance with that aircraft’s 

type certification standards as established by the FAA; and 

ii. Aircraft’s inspection and maintenance requirements are in compliance 

with the applicable Federal Aviation Regulations. 

9. Stallion 51 must notify the jurisdictional FSDO by written report, electronic mail, 

or facsimile, of any of the following occurrences within 24 hours. For the purpose 

of this section, “during flight” or “in-flight” means the period from the moment the 

aircraft leaves the surface of the earth on takeoff until it touches down on landing. 

a. Any of the following in-flight occurrences: 

i. Each in-flight fire in any system or area that requires activation of any 

fire suppression system or discharge of a portable fire extinguisher; 

ii. Each aircraft component or system that causes, during flight, 

accumulation or circulation of noxious fumes, smoke, or vapor in any 

portion of the cabin or crew area; 

iii. Each occurrence of in-flight engine shutdown or propeller feathering 

and the reason for such shutdown or feathering; 

iv. Any landing gear system or component failures or malfunctions which 

require use of emergency or standby extension systems; and 

v. Each malfunction, failure, or defect in any system or component that 

requires taking emergency action of any type during the course of any 

flight; 

b. Any of the following in-flight and/or ground occurrences: 

i. Each exhaust system component failure, including the 

turbocharger/supercharger components, that causes damage to any 

engine, structure, cowling, or components; 

ii. Each failure of the propeller governing systems or feathering systems; 

and 

iii. Each failure or malfunction of the fuel system, tanks, pumps, or valves; 

c. Each failure or malfunction of the wheel brake system that causes any loss of 

brake control on the ground; and 

d. Each aircraft structure that requires major repair due to damage, deformation, 

or corrosion and the method of repair. 
 7

10. All flight operations must be conducted with a minimum flight visibility of not 

less than three statute miles and a minimum ceiling of not less than 1,500 feet 

above ground level (AGL), unless the flight is conducted under instrument flight 

rules (IFR) or special visual flight rules (SVFR). 

11. No one other than the following persons may be permitted aboard the aircraft 

during flight operations: 

a. The person acting as flight instructor, and; 

b. The person who possesses at least a private pilot certificate with appropriate 

single engine airplane category and class rating receiving flight instruction. 

12. All aircraft must have the equipment listed in §§ 91.205 (as applicable to the 

operation being conducted) and 91.207 and that equipment must be in an operable 

condition during the flight. 

13. Failure to comply with any of the conditions and limitations of this exemption will 

be grounds for the immediate suspension or revocation of this exemption. 

The Effect of Our Decision 

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

//s// 

John Barbagallo 

Deputy Director, Flight Standards Service 

Enclosures 

Exemption No. 8593