P.O. Box 619119 2929 West Airfield Drive DFWAirport, Texas USA 76261 -9119 Tel 1 -972 -456 -8000 Fax 1 -972 -456 -8383 www.cae.com October 20, 2011 U.S. Department of Transportation Docket Operations, M - 30 West Building Ground Floor, Room W1 2 - 140 1200 New Jersey Avenue, SE Washington, DC 20590 CAE SimuFlite , Inc

. respectfully requests an exemption to FAR Part 91.9 and 91.531(a) (1) and (2) of Title 14 of the Code of Federal Regulations for operators of Cessna Citation models 500, 550, S550, 552 and 560, and aircraft modified by S ierra ST C’s to permit certain qualified pilots operating a Sierra modified Cessna Citation Model 500 series airplane (Serial Nos. 0001 through 0418 only) equipped with supplemental type certificate (STC) No. SA8176SWor STC No. SA09377SC and either STC No. SA2172N M, STC No. SA645NW , or STC No. ST09559AC to operate those aircraft without a pilot who is designated as second in command (SIC). Specifically, below are the exact requirements this exemption is requested for:

• FAR Part 91.9(a) provides that no personal may operate a civil aircraft without com plying with the operating lim itations specified in the approved Airplane Flight Manual and placards or as otherwise prescribed by t he certificating authority of the country of registry.

• FAR Part 91.531(a)(1) provides that no person may o perate a large airplane (greater than 12,500 pounds maxim um certificated take-off weight), without a pilot who is designated as second in command (SIC).

• FAR part 91.531(a)(2) provides that no person may o perate a turbojet- powered mu lti engine airplane for which two pilots are required under the type certification requirements for that airplane without a pilot who is designated as a second in command (SIC). Granting CAE SimuFlite Inc’s petition request will allow authorizations currently existing under a Cessna, Shannon or Sierra exemption to continue to be useful to Cessna owners after the Cessna, Shannon and Sierra exemptions expire early in 2010. More specifically, the granting of this petition will allow currently eligible Citation Model 500 series aircraft owners/operators to continue to operate at a significantly reduced expense. Safety would not be adversely affected, as the current mi nim um requirements to operate under the exemptions in effect today will still be met as follows: Each pilot conducti ng single- pilot operations mu st – a. Before operations, complete a single- pilot training program approved by the FAA’s General Aviation and Commercial Division AFS - 800, 800 Independence Avenue, SW ., W ashington, DC 20591;P.O. Box 619119 2929 West Airfield Drive DFWAirport, Texas USA 76261 -9119 Tel 1 -972 -456 -8000 Fax 1 -972 -456 -8383 www.cae.com b. Hold an airline transport pilot certificate with a CE - 500 type rating or commercial pilot certificate with an airplane instrument rating and a CE - 500 typ e rating; c. Have logged at least 1,000 hours total pilot flight time, including at least 50 hours flight time at night, 75 hours instrument flight tim e, 40 hours of instrument flight time in actual instrument meteorological conditions, and 500 hours as pilot in command (PIC) or second in command (SIC), or a combination of both, in turbine- powered airplanes; d. Not perform any

c ircling instrument approaches to mi nim um s of l ess than 200 feet and 1 mi le above the published mi nim um s until completing at least 100 hours of single- pilot flight experience in CE - 500 airplanes; e. Not perform any

straight- in instrument approaches to mi nim um s of less than 100 feet and 1⁄2 mi le above the published mi nim um s until completion of at least 100 hours of single- pilot flight experience in CE - 500 airplanes; f. Use a boom microphone; and g. Have a fully functioning autopilot controllable about three axes that is capable of approach coupling. I appreciate yo ur consideration of our request and look forward to yo ur response. Please, contact me if you require any additional information or clarification. Sincerely,

Steve Hall CAE Regulatory Com pliance P.O. Box 619119 2929 W. Airfield Drive DFWAirport, TX 75261 Ph one : (972) 456 - 8381