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 ty pe specific training in FAR 135.327 and FAR 135.335 . Regulatio ns currently prohibit flight training on equipment in the same aircraft famil y , 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 C 90 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 serve s the public interest. From a safety standpoint, using an aircraft simulator that replicates our fleet allows us to train in a risk

- fr ee 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 program s . Of the two Level D s imulators, both are at F light 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, th is C90B simulator at Flight Safety is twice as expensive as other providers and extremely difficult to schedule training on for small operato rs such as Thunderbird Aviation. Flight Safety’s programs are primarily designed for large corporate flight department s and charter operators, who get priority scheduling and volume discounts which we do not qualify for

. Having only one simulator in the United S tates, 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 ty pe 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 appli cant 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 bel ieve 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 operation s .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 wo uld 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