AFS-17-00019-E 

Exemption No. 17139 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

In the matter of the petition of 

SIMCOM INTERNATIONAL, INC. 

DBA SIMCOM AVIATION 

TRAINING ORLANDO 

For an exemption from § Part 91.9(a); 

Part 91.531(a)(1) and (2) 

of Title 14, Code of Federal 

Regulations 

 Regulatory Docket No. FAA-2000-8527 

GRANT OF EXEMPTION 

By letter dated December 3, 2015, Mr. Michael Young, Director of Training Operations, 

SimCom International, Inc. dba SimCom Aviation Training Orlando (SimCom), 6989 Lee 

Vista Boulevard, Orlando, FL 32822 petitioned the Federal Aviation Administration (FAA) 

on behalf of SimCom for renewal and amendment to Exemption 7487, as amended. That 

exemption, from §§ 91.9(a) and 91.531(a)(1) and (2) of Title 14, Code of Federal Regulations 

(14 CFR), allows SimCom to train, test, and approve pilots (under its 14 CFR part 142 

training center certificate, V61X042K) to operate certain Cessna CE-500 series aircraft 

without a pilot who is designated as second-in-command (SIC). 

In your petition, you indicate similar conditions and reasons relative to public interest and 

safety that were the basis for granting the exemption continue to exist. 

SimCom also requested an amendment to Condition and Limitation No. 23, which limits 

operations to within the United States. 

The petitioner requests relief from the following regulations:

Section Part 91.9(a) prescribes, in pertinent part, that no person may operate a civil 

aircraft without complying with the operating limitations specified in the approved 

Airplane or Rotorcraft Flight Manual, markings and placards, or as otherwise 

prescribed by the certificating authority of the country of registry. 
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Section 91.531(a)(1) and (2) prescribes, in pertinent part, that no person may operate 

the following airplanes without a pilot who is designated as second in command of a 

large airplane, as well as a turbojet-powered multiengine airplane for which two pilots 

are required under the type certification requirements for that airplane. 

The petitioner supports its request with the following information:

SimCom states that it seeks clarification and amendment to Condition and Limitation 

No. 23, that operations under this exemption are limited to operations within the United 

States. SimCom references the following FAA statement that “If SimCom TC (or any 

pilot authorized for single pilot operation by SimCom TC) wishes to be able to operate 

under this exemption outside the United States, it must make a request to the FAA in 

accordance with requirements of 14 CFR 11.83.” SimCom therefore specifically 

requests that single pilot operations be authorized under the exemption, to include 

Canada, Mexico and the Commonwealth of the Bahamas. SimCom further states that 

the basis for the request stems from customer requests that they are frequent operators 

to and from these countries, all of which are in close proximity to the United States. 

SimCom also states that it has officially changed its name and has been issued a revised 

training certificate under the name SimCom International, Inc. dba SimCom Aviation 

Training Orlando effective October 23, 2015. 

The FAA’s analysis is as follows:

The FAA granted SimCom a short term exemption (No. 7487N), which was valid until 

October 31, 2016, in order to further review your requested amendment of Condition and 

Limitation No. 23 that would allow single pilot operations under the terms of the exemption 

outside the United States. 

Although the requested extension and amendment of Exemption No. 7487, as amended, was 

submitted in a timely manner, that exemption expired on October 31, 2016. Therefore, we are 

issuing SimCom a new exemption, with amended conditions and limitations. 

The FAA determined that it is reasonable to amend Condition and Limitation No. 23 to allow 

a pilot to operate the CE-500 as a single pilot under the terms and conditions of this 

exemption outside the United States if the airplane operator obtains permission from the 

sovereign state. Consistent with § 11.83, the FAA has filed a difference with the International 

Civil Aviation Organization (ICAO) because exercise of this exemption outside the United 

States is not be consistent with ICAO standards.1

 

1

 Annex 6, chapter 9, 9.1 (composition of the flightcrew) states: 

9.1.1 The number and composition of the flight crew shall not be less than that specified in the operations 

manual. The flight crews shall include flight crew members in addition to the minimum numbers specified in the 
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Condition and Limitation No. 7a has also been amended to include a Level C or D full flight 

simulator use allowance in Condition and Limitation No. 7b. 

Conditions and Limitations Nos. 9 and 10 listed order has changed and includes a terminology 

change to reflect “full flight simulator” instead of “simulator.” 

The FAA’s Decision 

The FAA has determined that good cause exists for waiving the requirement for Federal 

Register publication because the exemption, if granted, would not set a precedent, and any 

delay in acting on this petition would be detrimental to SimCom.

In consideration of the foregoing, I find that a grant of exemption 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, I grant SimCom International, Inc. dba SimCom 

Aviation Training Orlando (SimCom) an exemption, to allow SimCom to train, test, and 

approve pilots (under its 14 CFR part 142 training center certificate, V61X042K) to operate 

certain Cessna CE-500 series aircraft without a pilot who is designated as second-incommand (SIC), subject to the conditions and limitations listed below. 

 

Conditions and Limitations 

1. This exemption applies to pilots operating Cessna Citation model 500, 550, S550, 

552, and 560 airplanes who have successfully completed SimCom’s approved 

single-pilot authorization course and complied with all of the terms of this 

exemption. 

2. This exemption is effective for the conduct of the required training and checking 

only if SimCom’s CE-500 single-pilot training program receives and maintains 

approval under part 142 from the FAA Flight Standards District Office (FSDO) that 

has jurisdictional authority over the SimCom’s part 142 training center certificate. 

3. This exemption is effective only if it is listed in SimCom’s training specifications, 

paragraph A005. 

4. Any flight operated using the privileges of this exemption may be conducted under 

part 91 only. 

5. Each pilot conducting single-pilot operations under the terms of this exemption 

must— 

 

flight manual or other documents associated with the certificate of airworthiness, when necessitated by 

considerations related to the type of aeroplane used, the type of operation involved and the duration of flight 

between points where flight crews are changed. 
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a. Complete SimCom’s FAA-approved part 142 CE-500 single-pilot curriculum 

before conducting such operations; 

b. Hold an airline transport pilot certificate with a CE-500 type rating or a 

commercial pilot certificate with an airplane instrument rating and CE-500 

type rating before entering SimCom’s part 142 CE-500 single-pilot 

curriculum; 

c. Have logged at least 1,000 hours of total pilot flight time, including at least 50 

hours of night flight time; 75 hours of instrument flight time, 40 hours of 

which are in actual instrument meteorological conditions; and 500 hours as 

pilot in command (PIC), SIC, or both, in turbine-powered airplanes; 

d. Not perform any circling instrument approaches to minimums of less than 200 

feet and 1 mile above the published minimums until after completing 100 

hours of single-pilot flight experience in CE-500 series airplanes; 

e. Not perform any straight-in instrument approaches to minimums of less than 

100 feet and one-half statute mile visibility above the published minimums 

until after completing 100 hours of single-pilot flight experience in CE-500 

series airplanes; 

f. Use a boom microphone; and 

g. Use a fully functioning autopilot that is controllable about three axes and 

capable of approach coupling. 

6. The CE-500 single-pilot initial authorization and authorization renewal curriculum 

must include–– 

a. Ground instruction appropriate to the CE-500 airplane given by a SimCom part 

142 instructor (designated in accordance with SimCom’s approved procedures) 

that covers at least the following aeronautical knowledge areas: 

i. Safe and efficient operation of airplanes; 

ii. Weight and balance computations; 

iii. Use of performance charts; 

iv. Significance and effects of exceeding airplane performance 

limitations; 

v. Principles and functions of airplane systems; 

vi. Maneuvers, procedures, and emergency operations; and 

vii. Night and high-altitude operations. 
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b. Flight instruction appropriate to the CE-500 airplane given by a SimCom part 

142 instructor (designated in accordance with SimCom’s approved procedures) 

that covers at least the following areas of operation: 

i. Preflight preparation; 

ii. Preflight inspection and procedures; 

iii. Taxiing; 

iv. Normal and crosswind takeoffs and departures; 

v. In-flight maneuvers including configuration changes, approaches to 

stalls, and steep turns; 

vi. Simulated powerplant failure (actual powerplant failure if 

accomplished in a full flight simulator); 

vii. Instrument procedures; 

viii. Precision and nonprecision approaches; 

ix. Missed approaches; 

x. Landings and approaches to landings; 

xi. Normal and crosswind landings; 

xii. Landing with a simulated powerplant failure (actual powerplant 

failure if accomplished in a full flight simulator); 

xiii. Normal and abnormal procedures; 

xiv. Emergency procedures; and 

xv. Post-flight procedures. 

7. The instruction required in Condition No. 6b may be completed in an approved full 

flight simulator, qualified as–– 

a. A Level A, B, C, or D full flight simulator, provided the applicant satisfactorily 

accomplishes as part of the training program the following in-flight maneuvers 

and procedures as sole manipulator of the controls in a CE-500 series airplane: 

i. Exterior preflight inspection; 

ii. Taxiing; 

iii. Normal and crosswind takeoffs (minimum of three); 

iv. Normal and crosswind approaches and landings (minimum of three); 

v. Landing from a precision approach; 

vi. Missed approach; 

vii. Approach and landing with a simulated powerplant failure; 

viii. Normal approach and landing; 

ix. Landing from a circling approach; and 

x. Landing from a no flap or nonstandard flap approach; or 

b. A Level C or D full flight simulator provided the applicant has performed at 

least three takeoffs and three landings to a full stop as the sole manipulator of 

the flight controls in the CE-500 series airplane within the preceding 90 days. 
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8. An applicant seeking to obtain or renew a single-pilot authorization under this 

exemption must–– 

a. Satisfactorily complete SimCom’s FAA-approved part 142 single-pilot 

curriculum; 

b. Satisfactorily complete the curriculum’s required qualification module, 

consisting of a stand-alone proficiency check in either a CE-500 series 

airplane, an appropriately qualified and approved full flight simulator, or a 

combination thereof; 

c. Satisfactorily complete this proficiency check— 

i. Within 30 days of completing the training; and 

ii. Under the supervision of an appropriately rated FAA inspector or 

SimCom training center evaluator (TCE) who is qualified and 

authorized to conduct either § 61.58 proficiency checks or type rating 

practical tests in CE-500 series full flight simulators or airplanes, as 

appropriate. 

d. Satisfactorily complete all tasks listed in the Airline Transport Pilot and 

Aircraft Type Rating Practical Test Standards that are required for an initial 

CE-500 type rating; and 

e. Satisfactorily perform all maneuvers and procedures as a single pilot during the 

entire proficiency check. Training to proficiency during the check is not 

permitted, and failure of any maneuver will result in failure of the proficiency 

check. 

9. The circling approach requirement must be accomplished in an airplane or in a full 

flight simulator that is qualified and approved in SimCom’s training specifications 

for the circling approach task. 

10. Until the circling approach task has been satisfactorily demonstrated in an airplane 

or in a full flight simulator qualified for the circling approach task to an FAA 

inspector or FAA-designated examiner–– 

a. The applicant’s records will be annotated with the statement, “Demonstration 

of circling approach was not accomplished”; and 

b. The applicant must not perform circling approaches as the PIC when weather 

conditions are less than the weather minimums for visual flight rules. 

 

11. A person who previously has received a single-pilot authorization in a Cessna 

Citation model 500, 550, S550, 552, or 560 airplane must complete SimCom’s 
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FAA-approved part 142 single-pilot differences training course to obtain a singlepilot authorization for a different Cessna Citation model. 

12. All flight training conducted in accordance with this exemption must be given by a 

flight instructor employed by SimCom who also meets the requirements of 

Condition and Limitation No. 5(a), (b), and (c) of this exemption. 

13. A person seeking to obtain a single-pilot authorization must satisfactorily complete 

ground and flight training through SimCom’s FAA-approved part 142 single-pilot 

curriculum and must receive training on the differences between the Cessna 

Citation model represented by the simulator used for training and checking and the 

Cessna Citation model for which single-pilot authorization is requested. 

14. A single-pilot authorization will be valid for 12 calendar months. A person who 

renews a single-pilot authorization in the calendar month before or after the 

calendar month in which it is due is considered to have renewed the single-pilot 

authorization when due. 

15. Successful completion of the proficiency check used in SimCom’s FAA-approved 

part 142 single-pilot initial authorization and authorization renewal training 

curriculum identified in Condition No. 8 satisfies the requirements of the PIC 

proficiency check required by 14 CFR § 61.58. 

16. Each CE-500 series airplane operated under this exemption must have the 

following equipment installed and operational: 

a. An autopilot with approach coupling capability; 

b. A flight director system; 

c. A boom microphone; and 

d. A transponder “ident” switch on the pilot’s control wheel. 

17. Each person must carry a copy of this exemption and a record from SimCom 

documenting compliance with its training and checking conditions aboard the 

airplane when he or she is operating under the terms of this exemption. 

18. Upon request, SimCom must provide any representative of the FAA Administrator 

with an analysis of training and checking operations conducted under this 

exemption with respect to program failure rates, extra training time required, 

accident and incident data, and any known problem areas. 
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19. SimCom must maintain records and make them available, when requested, to any 

representative of the FAA Administrator. These records must include all 

information required by § 142.73 and— 

a. The dates of training enrollment and completion for each trainee who enrolls in 

a SimCom single-pilot curriculum; 

b. The name and number of additional training hours needed by those applicant 

who requires more flight training than prescribed in the SimCom’s CE-500 

single-pilot curriculum in order to pass the initial authorization or authorization 

renewal; 

c. The name of each pilot who failed to complete SimCom’s Cessna CE-500 

single-pilot curriculum satisfactorily or withdrew from the course and the 

reason(s) for the withdrawal; and 

d. The name, certificate number, and address of each person who is authorized to 

operate under this exemption. 

20. No person may provide training nor may any person receive training while 

passengers are aboard any aircraft operating for the purpose of meeting the training 

or checking requirements of this exemption. 

21. This exemption is valid only for aircraft configured for operation by a single pilot 

seated in the left pilot seat. The privileges of this exemption are prohibited for any 

aircraft with the landing gear lever positioned anywhere to the right of the center of 

the aircraft. 

22. The approved training curriculum authorized by this exemption may not be 

conducted under any business name other than SimCom International, Inc. dba 

SimCom Aviation Training Orlando. 

23. This exemption is not valid for operations outside the United States, except when 

the operator receives authorization from the appropriate civil aviation authority of 

the sovereign nation in which the operator intends to operate. SimCom must 

explain this obligation to any pilot who completes its approved single-pilot 

authorization course. A copy of this exemption must be provided to the sovereign 

nation upon request. 

24. The FAA reserves the right to withdraw this grant of exemption at any time if the 

 Administrator determines that SimCom has failed to adhere to the conditions 

 and limitations of this exemption. 
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This exemption terminates on November 30, 2018, unless sooner superseded or rescinded. 

Issued in Washington, D.C., on November 14, 2016. 

/s/ 

John S. Duncan 

Director, Flight Standards Service