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# ..AgustaWestland AFinmeccanicaCompany August 5, 2015 Docket Management Facility US Department ofTransportation 1200 NewJerseyAvenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590 Ref: Petition for Exemption/Rulemaking to 14 CFR Part 60, in regard to the AgustaWestland AW609 Flight Simulation Training Device (FSTD) DearAddressee, AgustaWestland Philadelphia Corporation (AWPC) is developing the world'sfirst PoweredLift Category, commercial tiltrotor aircraft, the AW609. In partnership with Rotorsim; AWPC currently holds a certificate under Part 142. We are expecting to provide training forthe AW609 tiltrotor, under Part 142, underan FAA approved training program. Part 142 requirements state that an FSTD used in an FAA approved training program must be qualified under part 60. However, Part 60 does not adequately address special categories ofaircraft such as the tiltrotorand as such; there are currently no provisions in part 60 to accept alternate FSTD qualification standards otherthan what is in the part 60 Qualification Performance Standards (OPS). There is significant overlap in the current Appendix A/B (fixed wing), and Appendix C/D (helicopter), standards

.The problem is that certain sections will not be applicable (such as takeoff and landing in the airplane-mode configuration) and (more importantly), there are several unique training maneuvers fora tiltrotorthat are not covered in the existing (fixed wing and helicopter) FSTD qualification standards which should be validated against an agreed upon technical standard to ensure the FSTD accurately replicates the aircraft. Therefore, we are requesting the following (possible) rule change to 14 CFR, Part 60: §60.38 Designation ofapplicable FSTD qualification standards representing aircraft class that are not covered in other sections ofthis rule. (a) Forspecial classes ofaircraft (e.g. Powered-Lift, tiltrotors, gliders, airships, and other nonconventional aircraft) forwhich FSTD qualification standards have not been issued underthis part, the applicable requirements will be the portions ofthose other FSTD qualification standards contained in Appendix A, B, C, or D ofthis partfound by the FAAto be appropriate forthe aircraft and applicable to a specific type design or such criteria as the FAA mayfind provide an equivalent level ofsafety. (b) For FSTDs qualified underthis section, the standards used to initially evaluate and qualify the FSTD will become the permanent qualification basis ofthe FSTD and recorded in the FSTD's Master Qualification TestGuide (MQTG)

. (c) The evaluation and qualification ofan FSTD that represent an aircraft whose category and class has not been addressed in otherappendices ofthis rule may be evaluated and qualified utilizing alternate means of compliance. (d) The alternate means of compliance standards forqualification ofthe FSTD will be developed by the sponsorand approved by the FAA NSPM.As a possible example/template, reference 14 CFR Part 21, §21.17 Designation ofapplicable regulations: (b) For special classes ofaircraft, including the engines and propellers installed thereon (e.g., gliders, airships, and other nonconventional aircraft), forwhich airworthiness standards have not been issued underthis subchapter, the applicable requirements will be the portions of those otherairworthiness requirements contained in Parts 23, 25, 27, 29, 31, 33, and 35 found by the FAA to be appropriate forthe aircraftand applicable to a specific type design, or such airworthiness criteria asthe FAA mayfind provide an equivalent level ofsafety to those parts. This proposed action would be in the public interest because:

• In the absence ofa qualified FSTD, this training and checking would have to be conducted in the aircraft which would have obvious safety implications. Information and arguments supporting this proposed action, including relevant technical and scientific data available:

• Aircraft certification regulation (in 21 .17) demonstrates a past precedent in this type of issue and therefore should be applied to this FSTD qualification.

• Also, much oftechnical standards can be derived from the existing part 60 QPS where applicable. Specificfacts orcircumstances supporting ordemonstrating the need forthe action we propose:

• AWPC is already working with the FAA on this and have come to a tentative agreement on potential technical standards that could be used in support ofthis effort.

• An alternative approach could be to publish new part 60 QPS appendices to cover tiltrotor FSTD qualification, but since the impacton the numberof FSTDs that would need qualification is expected to be very small, it makes more sense to allowforthe FAAto accept alternate standards in the very limited circumstances where a special class/category ofaircraft is involved.

• Lastly, time is critical. AWPC is working towards aircraft type certification not later than 40 2017. We understand that the normal rulemaking process can be lengthy and typically takes years to complete. This will likely impact ourtimeline with regard to the aircraft entry into service. Since this rule change would have avery limited impact outside ofthe tiltrotorcommunity, we requestthatthe FAA propose a directfinal rule if possible. We lookforward to your response and are ready to proceed under FAA guidance in continuing with the AW609 FSTD development and certification process. Best regards, 1-

# ~~n~**~** AW609 Chief Engineer AgustaWestland Philadelphia Corporation Work: (817) 375-7300 or Mobile: (215) 327-3957 Email: David.King@AgustaWestland.com