### Petition for Exemption Western Michigan University September 19, 2014

Contact Information:

Thomas C. Grossman Chief Flight Instructor Western Michigan University College of Aviation
237 N Helmer Rd. Battle Creek, MI 49037

Office Phone: (269) 964

- 4029 Office Fax: (269) 964

- 4676 Email: thomas.grossman@wmich.edu

The specific section or sections of Title 14 of the Code of Federal Regulations (CFR) from which you seek an exemption :

On behalf of Western Michigan University I am respectfully reque sting an exempti on from 14 CFR 141 Appendix B 4

, 14 CFR 141 Appendix C 4 and 14 CFR 141 Appendix D 4.

The extent of relief you seek and the reason you seek the relief :

On behalf of Western Michigan University (WMU) I am requesting a temporary exemption from the minimum flight training time requirements as listed in 14 CFR 141 Appendix B 4

, 14 CFR 141 Appendix C

4 and 14 CFR 141 Appendix D 4 up to the extent that will all ow WMU students to use WMU’s Frasca training devices as approved in WMU’s current FAA issued Letter of Authorization. This exemption is requested until WMU ’ s Frasca training devices are upgraded and approved as Level 5 FTD s but not to exceed December 31, 2015.

Western Michigan University owns and operates two Frasca model 241/Cirrus SR20 training devices that are currently approved as Conferred Level 1 Status

. In accordance with the FAA ’ s FTD policy change published in the Federal Register January 2, 201 4, these devices will no longer be approved as Conferred
Level 1 Status effective January 1, 2015. WMU is working with Frasca International to have these devices approved as Aviation Training Devices and Frasca fully expects that a new Letter of
Authoriza tion ( LOA ) authorizing the devices to be operated as Advanced

- Aviation Training Devices will be received from the FAA before the end of 2014. In addition to the above, WMU has contracted with Frasca International for the purchase of a third Frasca model 2 41/Cirrus SR20 training device that is to
be built and certified to Level 5 FTD standards. It is anticipated that the delivery of this dev ice will occur by April 2015. Once this new device is delivered, the purchase contact also calls for the upgrade and
certification of WMU ’s two existing training device s to Level 5 FTD standards. Unfortunately, Frasca has indicated the upgrade to the two existing devices cannot occur until after the manufacture andcertification of the new device which has a lead time of nine months. As such, t he upgrade and
certification is not anticipated to be complete until mid

- 2015. In summary, WMU currently operates

two FTD approved at Conferred Status Level 1, which will drop to Advanced

- ATD status on January 1,
2015 and then be upgraded to Level 5 FTD by mid

- 2015.

WMU currently holds a n FAA issued LOA for the two Frasca devices that allow s WMU to use these
devices

, in part

, in accordance with “section 141.41 (b)

– As allowed within the FAA

- approved part 141 training course ”, “section 141.55 (d) & (e)

– As allowed within the FAA

- approved part 141 reduced hours training course” and “section 141.57

– As allowed within the FAA

- approved part 141 special training curricula”. A scan of this LOA is attached to this petition. This pe tition seeks authorization for WMU to continue to use their Frasca training devices up to the extent permitted in the most recent FAA issued LOA and the currently approved Part 141 approved Training Course Outline during the period that the
devices are cla ssified as Aviation Training Devices.

WMU realizes that an alternative solution to this petition is that WMU modify their current ly approved part 141 Training Course Outline and request that the affected courses be approved under 14 CFR 141.55 (d) & (e), thus allowing the affected curriculums to be approved without meeting minimum training time requirements. WMU does not believe this to be the best solution as a re

- write of the curriculum would require a substantial investment of work along with the challenges of transitioning over 250 students from one curriculum to another. Additionally, WMU uses a web

- based computer program to maintain training records along with TCO compliance and transitioning them from one
curriculum to the new would compromis e the integrity of the checks and balances of TCO compliance. Seeing as the training device status is anticipated to be a temporary problem, WMU believes a temporary exemption is the best solution.

How your request would benefit the public as a whole ?

Currently WMU’s part 141 training curriculum allows for 3.0 hours of FTD time in the private pilot course, 14.0 hours of FTD time in the instrument course and 9.5 hours of training device time in the commercial course (2.7 hours FTD and 6.8 hours A

- ATD). Performing training in a quality training device allows for a reduction in training cost , more efficient scheduling of training resources and improved training outcomes by allowing high risk scenario based training activities to be accomplished in the
safe ty of a training device. All owing WMU to continue to train to the standards currently set forth in their FAA part 141 approved training course outline will save the students training costs, allow them to
train in a more condensed time schedule and allow t hem to be trained to a higher level of skill, knowledge and safety. Preparing quality pilots to a higher standard and more efficiently, in both time and money, will benefit the entire aviation industry and general public as a whole.

Reasons why the exem ption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule :

This exemption, if granted, would allow WMU to continue to train students in the same devices and to
the same standard that is currently allowed. Granting this exemption will not adversely affect safety
and would no t degrade the quality of training that students receive. On the contrary, reducing the number of hours that can be taught in a quality training device and forcing certain training elements to
the aircraft , or omitting them from the training curriculum altogether, could compromise the level ofskill, knowledge and safety to which students are trained. Many of the scenario based training activities and subsequent abn ormal and emergency tra ining activities cannot be safel y accomplished in the
aircraft. Allowing the continued use of the Frasca training devices as currently allowed will permit WMU
to continue to train their students to the level of quality that exists t oday.

A summary to be publish ed in the Federal Register:

Western Michigan University (WMU) is requesting a temporary exemption from 14 CFR 141 Appendix B 4, 14 CFR 141 Appendix C 4 and Appendix D 4. When granted, this exemption will allow WMU to continue to utilize their Frasca model 241/Cirrus SR20 training de vices in their private, instrument and commercial courses as currently authorized by their FAA approved part 141 Training Course Outline and FAA issued Letter of Authorization. This temporary exemption would not extend beyond December 31,

2015.

A ddition al information, views, or arguments to support this request :

Concerned about the change in FAA policy and the impact it would have on student training, on February 21, 2014, sent an email to their Principal Operations Inspector (POI), Marc Webber, asking about the future use of WMU’s devices. In an email response on March 7, 2014, Marcel Bernard, AFS

810, stated that the devices “will have [the] same authorizations for logging time for private,

ins trument, and commercial as provided by the current letters of authorization. (LOA)”. A copy of this email is attached to this petition.

After conversing with Jeremy Brown of Frasca International in early August, an email was sent on August 18, 2014 to Ma rc Webber asking for clarification of whether final LOAs would grant levels of use as
stated in Marcel’s March 7 email or if the level of use would be limited to those stated in current regulation. Marc Webber responded indicating that effective January 1 , 2015, WMU ’ s devices, assuming they had a new LOA approving them as an A

- ATD or B

- ATD

, would be limited by the hours as published in current regulations.

In light of Mr. Bernard’s assurance that WMU ’ s current devices would be able to be used to the exten t as permitted in the current LOAs along with the understanding that WMU ’ s existing devices will be upgraded and approved at Level 5 FTD , WMU respectfully requests this exemption

, thus allowing WMU
to continue to use its devices in accordance with the curr ent LOA until such time that the existing devices are approved at Level 5 FTD status, but not to exceed December 31, 2015.