Stallion 51 Flight Operations LLC - Exemption/Rulemaking

May 13, 2024 Jimeca Callaham Office of Rulemaking Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591 Dear Ms. Callaham, I am writing to you today to give the strongest possible recommendation that the FAA restore the flight operations exemptions that Stallion 51 has exercised for over a quarter of a century. As you may be aware, Stallion 51 is the premier warbird training center in the world.  In 37 years of conducting "Hands-on" warbird flights in the P-51 Mustang, they have had a flawless safety record with over 20,000 flight hours. There are roughly 200 P-51s operating in the United States today, with amazing restoration efforts adding to that total each year. As a retired Air Force fighter pilot, I have been honored to be closely associated with the U.S. warbird community for more than 27 years and have flown in the Stallion 51 Mustang training program. Therefore, I can personally attest to the quality and rigor of Stallion 51's spectacular flight training program that rivals any of the training I received in various fighters while serving in uniform.    Stallion 51's dynamic training regimen has produced more than 230 graduates from their robust and comprehensive Mustang checkout syllabus. This training is conducted by an extraordinary, hand-picked cadre of experienced P-51 instructor pilots, led by the highest time P-51 pilot in history - Lee Lauderback, who has logged well over 10,000 hours piloting the P-51.    One of the important features in Stallion 51's program that the current FAA exemption process may be jeopardizing is to take away the capability for flights to be conducted in formation.  There is a very strong safety rationale as to why fighter aircraft have been flown in formation since WW I.  It is called "mutual support".  Just as Crew Resource Management is crucial to multi-place aircrew decision making, formation flight is how we achieve the same objective in single seat aircraft. It is critical that we encourage, versus discourage, formation trained aviators to fly together, which is why so many of us involved in backcountry recreational flying encourage formation flying and the safety multiplying factor that is integral to formation flight. I strongly urge the FAA to continue to permit, as it has done for decades, Stallion 51 to conduct formation operations.  Finally, it should not be lost on anyone that the cost of providing the best warbird training in the world, with aircraft that are very expensive to own, operate and particularly – maintain, takes a great deal of financial resources. Additionally, the cost of retaining highly experienced instructors and mechanics is extremely robust. This is why the orientation sorties that Stallion 51 has conducted under its long-standing waiver with an impeccable safety record, are so vital to fund and sustain the high quality of training within our nation's Mustang pilot community. If Stallion 51 were to be restricted to flying only "Rated" pilots, this would make the entire operation financially unsustainable.  We are all acutely aware that safety is the FAA's 'North Star". It would be unquestionably an "anti-safety" decision to force Stallion 51 to close its doors by not allowing them to continue to operate under the same exemptions that have produced their unparalleled safety record. As a reminder, in our nation today, we allow non-rated paying passengers to book orientation flights on SpaceX, Blue Origin and Virgin Galactic to be launched on uncertified vehicles into the unforgiving environment of space. In summary, the aviation community fully understands the scrutiny that the FAA is under in the light of the Warbird Adventures/FAA legal fiasco and the Colling's B-17 accident. However, for years, from the Administrator on down the FAA chain of command, it has been proudly proclaimed that our nation's aviation safety regulator makes decisions based on data. For decades Stallion 51 has held exemptions to operate L…