AFS-16-8453-E

April 23, 2016

 Exemption No. 10518B

 Regulatory Docket No. FAA-2011-0814

Mr. Itash Samani

CAE, Inc.

P.O. Box 619119

2929 W. Airfield Drive

DFW Airport, Texas 75261

Dear Mr. Samani:

This letter is to inform you that we have granted your petition to extend and amend Exemption

No. 10518, as amended. It explains the basis for our decision, describes its effect, and lists 

the conditions and limitations. The FAA has modified the conditions and limitations 

associated with this exemption as detailed below. 

The Basis for Our Decision

By letter dated January 12, 2016, you petitioned the Federal Aviation Administration (FAA) 

on behalf of CAE, Inc. (CAE) for an extension of Exemption No. 10518, as amended. That 

exemption from part 60, Appendix C, Table C2A, paragraph 4.b.1, 4.b.2, and 4.b.3 of 

Title 14, Code of Federal Regulations (14 CFR) allows a geometric error between the image 

generator eye point and the pilot eye point up to 12° for the AgustaWestland AW-139,

Sikorsky S-76C++, Sikorsky S-92, AgustaWestland AW-189, Eurocopter EC-225, Sikorsky 

UH-60L, Sikorsky UH-60M, Bell B-407, Bell B-429, and Bell B-525 Level D Full Flight 

Simulators (FFS). 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA finds that the original exemption allowing up to 12 degrees of parallax/geometric 

error needs to be reduced to 10 degrees. 
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The factors leading to the decision to use the 10 degree limit are:

1. The FAA National Simulator Program (NSP) review of an AW-139 showed that the 

larger angle of geometric error was unacceptable to both the NSP Inspector as well as 

other subject matter expert pilots. After CAE reworked the cockpit layout, a measured 

offset of 9.75 degrees was achieved, and this was found to be generally acceptable. 

Even so, a restriction was added to the Statement of Qualification (SOQ) at the time of 

the initial evaluation:

Visual eye point parallax error was measured 9.75 degrees at a point center of 

the two pilots. Complications occur during two pilot coordinated crew 

operations when the eye point is not selected to the center position. Multi Crew 

Pilot tasks are not authorized when the eye position is selected for one of the 

pilot positions which creates an excessive parallax for the other pilot.

2. International Civil Aviation Organization (ICAO) 9625 Volume II – Helicopters, First 

Edition 2012 also specifies a maximum limit of 20 degrees for a pilot not flying, and 

recommends that for two-pilot training, the design eye point be centrally located 

thereby providing both pilots with a less than or equal to 10 degree offset.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of, and amendment to, the exemption 

would not set a precedent, and any delay in acting on this petition would be detrimental to 

CAE.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 10518, as 

amended, remains valid with respect to this exemption and is in the public interest. Therefore, 

under the authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, CAE, Inc. is granted an extension to Exemption 

No. 10518, as amended. 

This grant exempts CAE from the part 60, continuous field-of-view tests as stated in Table 

C2A paragraph 4.b.1, 4.b.2, and 4.b.3 to the extent necessary to allow CAE to obtain FAA 

qualification of the applicable Flight Simulation Training Devices (FSTDs) to the 

qualification level requested for any helicopter aircraft types manufactured by CAE, subject to 

the following conditions and limitations.

Conditions and Limitations

1. This exemption applies to the following helicopters:
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a. Augusta-Westland AW-139;

b. Sikorsky S-76C++;

c. Sikorsky S-92;

d. Augusta-Westland AW-189;

e. Eurocopter EC-225;

f. Sikorsky UH-60L;

g. Sikorsky UH-60M; 

h. Bell B-407;

i. Bell B-429; and

j. Bell B-525.

2. The training implications of a visual image parallax offset will remain the same 

regardless of the specific helicopter being simulated. 

3. A geometric error of no greater than 10 degrees (per pilot flying) is allowed subject 

to evaluation by a National Simulator Program (NSP) Aviation Safety Inspector by 

conducting ground and flight maneuvers to validate the geometric/parallax error 

does not negatively affect qualified training, testing, or checking tasks. 

4. If the objective/subjective testing is successful, the NSP Inspector will make a 

recommendation to the National Simulator Program Manager (NSPM) for final 

approval.

Any training maneuver found to not be subjectively acceptable due to 

geometric/parallax error will be task restricted on the FSTD’s Statement of 

Qualification (SOQ) as determined appropriate by the NSPM.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 10518, as amended, to April 30, 

2018 unless sooner superseded or rescinded. 
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Any FSTDs previously qualified under earlier versions of this exemption retain the 

qualification status under which they were qualified, providing a copy of the exemption in 

effect at the time of qualification is retained within the Master Qualification Test Guide 

(MQTG) for that device.

Sincerely,

/s/

John Barbagallo

Deputy Director, Flight Standards Service