,,> ~ .. AgustaWestland A Finmeccanica Company 

August 5, 2015 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, 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) 

Dear Addressee, 

AgustaWestland Philadelphia Corporation (AWPC) is developing the world's first 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 for the 

AW609 tiltrotor, under Part 142, under an 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 

of aircraft such as the tiltrotor and as such; there are currently no provisions in part 60 to 

accept alternate FSTD qualification standards other than 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 for a tiltrotor that 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 of applicable FSTD qualification standards representing aircraft class 

that are not covered in other sections of this rule. 

(a) For special classes of aircraft (e.g. Powered-Lift, tiltrotors, gliders, airships, and other 

nonconventional aircraft) for which FSTD qualification standards have not been 

issued under this part, the applicable requirements will be the portions of those other 

FSTD qualification standards contained in Appendix A, B, C, or D of this part found by 

the FAA to be appropriate for the aircraft and applicable to a specific type design or 

such criteria as the FAA may find provide an equivalent level of safety. 

(b) For FSTDs qualified under this section, the standards used to initially evaluate and 

qualify the FSTD will become the permanent qualification basis of the FSTD and 

recorded in the FSTD's Master Qualification Test Guide (MQTG). 

(c) The evaluation and qualification of an FSTD that represent an aircraft whose category 

and class has not been addressed in other appendices of this rule may be evaluated 

and qualified utilizing alternate means of compliance. 

(d) The alternate means of compliance standards for qualification of the FSTD will be 

developed by the sponsor and approved by the FAA NSPM. 
As a possible example/template, reference 14 CFR Part 21, §21.17 Designation of applicable 

regulations: 

(b) For special classes of aircraft, including the engines and propellers installed thereon (e.g., 

gliders, airships, and other nonconventional aircraft), for which airworthiness standards have 

not been issued under this subchapter, the applicable requirements will be the portions of 

those other airworthiness requirements contained in Parts 23, 25, 27, 29, 31, 33, and 35 

found by the FAA to be appropriate for the aircraft and applicable to a specific type design, or 

such airworthiness criteria as the FAA may find provide an equivalent level of safety to those 

parts. 

This proposed action would be in the public interest because: 

• In the absence of a 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 of technical standards can be derived from the existing part 60 QPS 

where applicable. 

Specific facts or circumstances supporting or demonstrating the need for the 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 of this 

effort. 

• An alternative approach could be to publish new part 60 QPS appendices to cover 

tiltrotor FSTD qualification, but since the impact on the number of FSTDs that would 

need qualification is expected to be very small, it makes more sense to allow for the 

FAA to accept alternate standards in the very limited circumstances where a special 

class/category of aircraft 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 our timeline with regard to 

the aircraft entry into service. Since this rule change would have a very limited impact 

outside of the tiltrotor community, we request that the FAA propose a direct final rule 

if possible. 

We look forward 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@Ag ustaWestland .com