27 December 2012 

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 of objective 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 under AC-120-408 using AC-120-40C as an 

alternate means of compliance. It was taken out of service 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 of this exemption will not affect the performance of this FSTD or its 

suitability to deliver positive training to aircrews. 

FlightSafety International currently operates ten (10) Embraer 145 FSTD's. All of these devices are 

qualified under the requirements of AC-120-408 using AC-120-40C as an alternate means of compliance 

and daily provide valuable training to regional jet pilots throughout the United States, making a significant 

contribution to aviation safety. 

The benefit of this exemption to the public as a whole would be substantial: 

• Over 244 airports are served SOLELY by regional airlines. Many of these are served by carriers 

flying the ERJ 145 from a fleet of 557+ ERJ 145 (and derivative) aircraft, which represents 50% of 

the 50 seat regional jet fleet 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 off completely. The economic impact of this 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 pilot that missed a hiring opportunity and thus source of 

income because the airline had no way to train them will continue to be a part of what we have 

seen in America over the last few years, the increase in number of people requiring government 

assistance to survive. 

• It is important to note that there are two new FAA factors that are driving training on all airline 

aircraft: the end of the 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 over 2012), 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 of those pilots will 

come from operators of the ERJ 145 fleet. Since many regional airlines have more than one fleet 

type it is possible that even if a pilot stays with the regional but moves to a different aircraft it 
would still drive a training event (or 2) on the ERJ 145 as pilots shift positions due to seniority. 

Since the ERJ 145 is a large part of the regional airline fleet these new demands are already 

driving a huge amount of training on that aircraft. 

• Currently there are only 13 operating ERJ 145 simulators in North America and they simply 

cannot handle the required volume of training. 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 of safety 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 under AC-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 of this 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