27 December2012
FlightSafety International hereby seeks an exemption as allowed by 14 CFR Part 11 

### § 11.15. Specifically, we seek exemption from the requirements of 14 CFR Part 60, 

### § 60
.17 (c) (ii)
. This section requires, for FSTD's whose qualification is not restored for two (2) years or more, that the qualification basis (in terms ofobjective tests and subjective tests) for there-qualification will be those standards in effect and current at the time of re-qualification application. FlightSafety International proposes tore-qualify an Embraer 145 FSTD, formerly qualified by the FAA and assigned FAA ID #635. This FSTD was originally qualified underAC-120-408 using AC-120-40C as an alternate means ofcompliance
. It was taken out ofservice in October, 2008
. The FSTD has been in controlled storage for longer than the two (2) year period allowed under§ 60.17 (c)
. Our petition for exemption requests that we be allowed to re-qualify the FSTD under the qualification basis to which it was originally qualified
. The approval ofthis exemption will not affect the performance ofthis FSTD or its suitability to deliver positive training to aircrews
. FlightSafety International currently operates ten (10) Embraer 145 FSTD's. All ofthese devices are qualified underthe requirements ofAC-120-408 using AC-120-40C as an alternate means ofcompliance and daily provide valuable training to regional jet pilots throughout the United States, making a significant contribution to aviation safety
. The benefit ofthis exemption to the public as a whole would be substantial:
• Over244 airports are served SOLELY by regional airlines. Many ofthese are served by carriers flying the ERJ 145 from a fleet of557+ ERJ 145 (and derivative) aircraft, which represents 50% of the 50 seat regional jetfleet flown in the USA today. These aircraft are crewed by an average of 10 pilots per aircraft so there are over 5,570 pilots that require training in ERJ 145 simulators
. They generally participate in more than one training event per year, increasing the need for qualified FSTD's
. • Unless there are enough simulators to train pilots to fly these aircraft, airlines will simply not have enough pilots to fly the aircraft. When that happens cities all across North America will see service reduced or even cut offcompletely. The economic impact ofthis unfortunate consequence is huge not only for the city and its local industry but for worldwide trade as products and people can no longer move easily to places they are needed. • There are additional economic consequences as less hiring means more unemployment, with all its documented effects on our overall economy. The ERJ 145 is an "entry level" aircraft in the pilot hiring stream
. A family that has a pilotthat missed a hiring opportunity and thus source of income because the airline had no way to train them will continue to be a part ofwhat we have seen in America overthe lastfew years,the increase in number of people requiring government assistance to survive
. • It is important to note that there are two new FAAfactors that are driving training on all airline aircraft: the end ofthe Age 65 rule effect on pilots required in the industry (increasing retirement related new hires by close to 3,000 additional new hires in 2013 over2012), and new Flight and 

### Duty Time rules that will require airlines to hire an additional5% to 15% more pilots in 2013. Additionally, since the regional airline is the resource major airlines look to for hiring pilots, when a major airline hires it will cause a pilot to leave that regional airline
. Many ofthose pilots will come from operators ofthe ERJ 145 fleet. Since many regional airlines have more than one fleet type it is possible that even ifa pilot stays with the regional but moves to a different aircraft itwould still drive a training event (or2) on the ERJ 145 as pilots shift positions due to seniority. Since the ERJ 145 is a large part ofthe regional airline fleet these new demands are already driving a huge amount oftraining on that aircraft
. • Currently there are only 13 operating ERJ 145 simulators in North America and they simply cannot handle the required volume oftraining
. Allowing FlightSafety this exemption will increase the training resources to at least help in avoiding the consequences documented above
. The FAA does a cosUbenefit study on any new rule; however, this issue was simply not envisioned when Part 60 was written
. No one could have predicted the changes in circumstances that would suddenly drive training demand to new levels as they are now. Our request would certainly have qualified as a reasonable action under such a study. This exemption will provide a level ofsafety at least equal to the existing rule as our current fleet of Embraer 145 FSTD's are all qualified to the same standard, AC-120-408 using AC-120-40C as an alternate means of compliance. In brief, FlightSafety International petitions the FAA to allow re-qualification of Embraer 145 FSTD formerly identified as FAA ID #635 underAC-120-408 using AC-120-40C as an alternate means of compliance
. The exemption would allow FlightSafety International to meet the current training requirements for regional airline pilots
. It will enhance public safety by providing pilots the training necessary to operate their aircraft in a safe, effective manner. It would also allow the use ofthis FSTD in regional airlines' Safety Management Systems and thereby further increase the level of safety for the public. Respectfully submitted , 

# IJ/
.. Steven W. Krull Simulation Standards Manager FlightSafety International, Inc
. 9720 E. Central Avenue, Wichita, KS 67206