October 9, 2014

U.S. Department of Transportation

Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

Dear Sir:

Thunderbird Aviation, Inc., holder of FAA Air Carrier Certificate #TBDA360I, is petitioning for an exemption from 

type specific training in FAR 135.327 and FAR 135.335. Regulations currently prohibit flight training on 

equipment in the same aircraft family, if the type certificate for the airplane is different. In Thunderbird Aviation’s 

case, we operate a fleet of Beechcraft King Air C90 aircraft. The aircraft we operate are generally common to the 

King Air 200 Series of airplanes, including flight deck panel design, systems operation and training procedures. 

Under the current rulemaking, we are unable to conduct flight training in a King Air 200 (BE-200) Level C 

simulator while operating King Air C90 aircraft.

Using a BE-200 full motion, Level C or D, simulator for King Air C90 aircraft training, along with appropriate 

differences training, both enhances safety and serves the public interest. From a safety standpoint, using an aircraft 

simulator that replicates our fleet allows us to train in a risk-free environment, duplicating emergencies that could 

not be legally completed in the aircraft. 

From a public interest standpoint, there are only three Level C or D Beechcraft King Air 90 simulators in the United 

States. The Level C simulator is at Simcom, Inc and is leased to a Chinese airline on a full time basis. Since the 

simulator is unavailable to outside customers, Simcom has not pursued having their C90 simulator approved for 

FAR 135 training programs. Of the two Level D simulators, both are at Flight Safety, Inc. The first simulator at 

Flight Safety is based on a King air C90 Gti. This airplane is all glass, with Collins Pro Line 21 avionics, and is 

completely different from our fleet of non-glass airplanes. The remaining simulator is a King Air C90B, which is 

outfitted similarly to the King Air 200 simulator we currently use. Economically, this C90B simulator at Flight 

Safety is twice as expensive as other providers and extremely difficult to schedule training on for small operators 

such as Thunderbird Aviation. Flight Safety’s programs are primarily designed for large corporate flight 

departments and charter operators, who get priority scheduling and volume discounts which we do not qualify for. 

Having only one simulator in the United States, with one provider, places us, and operators like us, at an economic 

disadvantage.

Thunderbird Aviation believes there is a strong justification for continuing to allow simulator based flight training in 

a group or family of aircraft that have different type certificates. First, under FAR 121.400 and FAR 121.418, the 

Federal Aviation Administration allows for training in a “family” of airplanes that have different aircraft data type

certificates. For example, The Boeing 757/767 series of aircraft have different type certificates. Under FAR 121, 

pilot flight training programs in the 757 are transferable to the 767 and visa versa. Completion of an FAA approved 

training program in either the 757 simulator or a 767 simulator provides the applicant an FAA type rating in both 

aircraft. 

Second, current FAA regulations allow us to complete pilot checkrides in this group of airplanes. Under 135.293, 

Thunderbird Aviation can continue to conduct checking events in a King Air 200 simulator. We believe that since 

the FAA has already determined this practice to be acceptable and in the public interest, adding our ability to train,

in addition to flight check, in this family of aircraft would actually enhance the safety of our air carrier operations.
Thunderbird Aviation has developed curriculum based on guidance from FAR 121.400 and 121.418 that specifically 

addresses the King Air 200 and 90 Series airplanes and the appropriate differences training necessary. All pilots 

completing simulator training in the King Air 200 simulator must complete our King Air 90 differences training.

Thank you in advance for your consideration. If you have any questions or would like further information, please 

feel free to contact me at anytime, via e-mail at ccape@thunderbirdaviation.com or via telephone at (952) 941-1212.

Sincerely,

Christopher M. Cape

Chief Pilot

Thunderbird Aviation, Inc.

CMC