From: Young, Mike [mailto:myoung@simulator.com] 

Sent: Monday, February 08, 2016 2:20 PM

To: Lundgren, Douglas (FAA)

Cc: Goonen, Tom

Subject: RE: Petition SFAR 108

Mr. Lundgren,

Please see my responses below in RED. If I may be of further assistance please contact me.

Michael Young

Director- Training Operations and Quality

6989 Lee Vista Blvd.

Orlando, FL 32822

407.275.1050 Office

407.409.1788 Mobile

From: Douglas.Lundgren@faa.gov [mailto:Douglas.Lundgren@faa.gov] 

Sent: Tuesday, February 02, 2016 6:06 PM

To: Young, Mike <myoung@simulator.com>

Subject: RE: Petition SFAR 108

Dear Mr. Young:

We have received the latest addendum to the SimCom petition for exemption project number 2015-

1081.

We copy the information submitted toward the public interest; however it would be helpful if you could 

elaborate on the “equivalent level of safety”

plan as it relates to the alternative for the 50 hours of recent flight experience in an aircraft.

Question 1:

Please clarify what the proposed 50 hours of supervised instruction means. I am enclosing excerpts 

from the attached documents supplied by SimCom:

“all new instructors will still be required to complete the same amount of hours (50 hours) as required 

by the SFAR, except that these hours may be accrued as received instruction from a previously qualified 

MU-2 instructor.”
“In lieu of this requirement SimCom proposes to substitute the 50 hour aircraft flight time initial 

requirement with 50 hours of supervised instruction. The supervisory instructor will be a qualified MU2B instructor.”

Does this mean that for a new instructor who does not have the 50 hours of recent MU-2 PIC time nor 

has given 50 hours of MU-2 instruction, will RECEIVE 50 hours of FTD Level 5 time (presumably 

instructor training) or will be supervised GIVING his first 50 hours of instruction to live students? The 

intent is to supervise the delivery of instruction. The new instructor will be delivering while under the 

supervision of a qualified instructor for at least 50 hours.

Question 2:

Still missing in the SimCom petition and subsequent supplemental submissions is mention as to what if 

any Level E aircraft instruction will be provided to instructor candidates, beyond the Initial PIC training 

that SimCom indicates that it will be provide to their new instructors in accordance with SFAR 108. (6 

hours of FTD, 6 hours of Level E aircraft). We have not seen what the SimCom MU-2 instructor training 

program would entail in terms of hours of instruction received in the left and right seat of the Level 5 

FTD, and we have not seen a proposal to provide instructor training in the Level E MU-2 aircraft.

These instructors will not be providing in aircraft training. Consequently, there is no need to provide 

right seat instructor training. 

What is SimCom’s proposed initial new hire flight instruction training curriculum?

 We believe that in order to provide an equivalent level of safety, for an exemption to the 50 

hours of recent MU-2 flight experience to even be considered, the petitioner would have to 

propose some kind of equivalent level of safety mitigation that would incorporate Level E 

aircraft instructional training. Level E training will be provided during their initial SFAR training. 

This will include at minimum 8 hours consisting of 6 hours training and 2 hours final phase 

check.

 The Level E recent aircraft experience requirement for MU-2 FTD instructors could possibly be 

mitigated either by higher level FSTD training and experience, (if available) or by increasing the 

quality of the Level E aircraft instructional experience, in order to reduce the quantity of recent 

MU-2 aircraft experience required (50 hours). Since this pertains to only simulator and not in 

aircraft instructors, we are only asking for relief from the initial SFAR requirement of instruction 

given. We will mitigate the level of safety by supervising, with an SFAR qualified instructor, the 

first 50 hours instruction given by the simulator only instructor.

 We believe that training new instructors in the Level 5 FTD alone is not adequate, considering 

that MU-2B PIC Initial requirements include actual MU-2B aircraft flight requirements (6 hours) 

to expose the new MU-2 PIC to specific flight characteristics that cannot be replicated in the 

Level 5 FTD.

All instructors will receive a minimum of 8 hours level E training in the aircraft. 

I am available to discuss these topics. Thanks again for your cooperation.

Sincerely

Douglas J. Lundgren

Aviation Safety Inspector

Airman Certification and Training Branch AFS-810
Federal Aviation Administration HQ

800 Independence Avenue

Washington, DC 20591

Douglas.lundgren@faa.gov

Office: 202-267-0150

Telework office: 301-969-0536

From: Young, Mike [mailto:myoung@simulator.com] 

Sent: Friday, January 29, 2016 3:37 PM

To: Johnson, Carl N (FAA)

Cc: Lundgren, Douglas (FAA); Pat Cannon

Subject: Petition SFAR 108

Carl,

Thanks for your call this morning. Now having a better understanding of the issue surrounding the 

decision process for our petition, I have included a statement of public interest and equivalent safety as 

an addendum. Please find attached the addendum as submitted to Regulations.gov.

Thank you for your attention to this matter. 

Michael Young

Director- Training Operations and Quality

6989 Lee Vista Blvd.

Orlando, FL 32822

407.275.1050 Office

407.409.1788 Mobile