From: Young, Mike [ mailto:myoung@simulato r.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 32 822 407.275.1050 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 sub mitted 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 supervi sed instruction . The supervisory instructor will be a qualified MU

2B 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 Lev el 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 quali fied 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 tr aining 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 i nstruction 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 in structors, 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 characte ristics 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

- 810Federal 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