September 14, 2011

Docket Management Facility US Department of Transportation 1200 New Jersey Ave. SE Washington, DC 20590

Ladies/Gentlemen:

Pursuant to 14 CFR Part 11.63 (Petition for Ex emption), American Airlines petitions the Administrator for an exemption from 14 CFR Part 60.17(d) to permit an upgrade in qualification for American Airline’s B757 #2 Level C, FAA ID #389, Flight Simulation Training Device (FSTD) to Level D, after sa tisfactory evaluation of the Level D capable visual system, and for FSTD to remain gra ndfathered under Advisory Circular (AC) 120- 40B Qualification Test Guide (QTG) criteria.

SECTIONS OF THE FAR AFFECTED :

14 CFR Part 60.17(d) (Previously qualified FSTDs):

" Except as provided in paragraph (e) of this section, any change in FSTD qualification level initiated on or after October 30, 2007 re quires an evaluation for initial qualification in accordance with this part."

NATURE AND EXTENT OF RELIEF REQUESTED :

This petition seeks relief from 14 CFR Part 60.17(d) upon replacement of the visual and projection system and subsequent satisfactory evaluation of the Level D capable system by the FAA National Simulator Program Office (NSP) . American Airlines petitions to permit American Airlines B757 #2, FAA ID #389, FSTD be qualified to Level D and for the FSTD to remain under its initial QTG criteri a described by AC 120-40B. (The section does not permit an upgrade qualification to Level D unless the FSTD is evaluated under Part 60 QTG criteria).

SUPPORTIVE INFORMATION :

• Background :

The original purpose of 14 CFR Part 60.17(d) was to prevent a grandfathered FSTD from undergoing a software and/or hardware update and having it subsequently qualified to aAmerican Airlines Petition for Exemption 14 (CFR Part 60.17(d)) Page 2 higher training level than it had before under th e old qualification QTG criteria rather than the current Part 60 QTG criteria.

American Airlines B757 #2 Level C, FAA ID #389 and B757 #1 Level D FAA ID #324 are sister FSTDs. Both were built by the same simulator manufacturer. Identical flight, engine, sound, and motion buffet Level D data packages were incorporated. Identical hardware including weather radar, motion plat form, flight controls, and visual display systems were installed during simulator manuf acture. To reduce costs, a less capable visual generation system was installed for B757 #2. To achieve Level D, a SPX500 (day, dusk, night) was installed on B757 #1. B757 #2 received a Level C, SPX200 (dusk, night) system. The intention was to replace the B757 #2 SPX200 with a Level D capable system at a later date and to upgrade to Level D.

This year a decision was made to replace bot h visual systems with the Rockewll Collins EP1000, Level D capable visual system. At the end of this year both FSTDs will be identical in all aspects and meet Level D qualification under AC 120-40B QTG criteria. B757 #2 will remain Level C qualified without this exemption. B757 #1, an identical simulator will remain qualified to Level D.

American Airlines believes identical FSTDs should be qualified to the same Level D under

AC 120-40B.

• Justification :

1. Hardware: including motion platform and sound system have been identical since initial qualifications.

2. Weather radar simulation on primary instrument displays have been identical since initial qualifications.

3. Software: including aircraft manufactur ers’ flight and engine performance have been identical since initial qualifications.

4. All Level D QTG qualification tests, including sound and motion buffets have been completed and validated since initial qualifications.

5. Level D QTG tests, other than visual tests, have been accomplished quarterly for both FSTDs since initial qualifications.

6. FAA NSP inspectors have annually reviewed Level D QTG qualification tests for both FSTDs since initial qualifications.

7. Rockwell Collins EP1000 visual, projection, and display systems meet Level D qualification standards and are identical for both FSTDs.

8. Permit crew scheduling of FSTDs more efficiently.American Airlines Petition for Exemption 14 (CFR Part 60.17(d)) Page 3 9. Additional training program credits.

10. Additional customer training opportunities.

11. Realize higher FSTD lease fees.

12. Higher FSTD resell value.

PUBLIC INTEREST :

• Granting of this petition for exemption to 14 CFR Part 60.17(d) would allow:

1. Training department cost savings both in crew scheduling efficiency and higher FSTD lease fees. All financial improvements aid the overall financial health of the airline and directly influence the price of air travel by the public.

2. Does not add additional time/effort to annual FAA NSP inspections.

NO ADVERSE EFFECT ON SAFETY :

• The granting and use of this exemption would have no adverse effect on safety

because:

1. The current training program already u tilizes an identical FSTD qualified to

Level D.

2. This would allow for more standardiza tion within the training program by using common visual models and scenarios within a common qualification.

• This exemption proposal focuses on the st andardization of the training program by bringing like FSTDs to the same highest qualif ication level which presently exists in the training program. The exemption will provi de an equivalent level of safety as provided by the Level D qualified FSTD currently in the program.

• A summary of this petition is attached as required by 14 CFR Part 11.81(f).American Airlines Petition for Exemption 14 (CFR Part 60.17(d)) Page 4 Sincerely,

Christopher K. Broom Managing Director Flight Training American Airlines Flight Academy

P.O.Box 619617 MD 863 DFW Airport, TX 75261-9617

cc: Don Braun (AAL POI – AMR CMO)

AttachmentAmerican Airlines Petition for Exemption 14 (CFR Part 60.17(d)) Page 5 ATTACHMENT: American Airlines Petition for Grant of Exemption (14 CFR Part 60.17(d))

SUMMARY

American Airlines' (AAL) Petition for exemption to 14 CFR Part 60.17(d).

American Airlines petitions for an exemp tion from Section 14 CFR Part 60.17(d) to permit American Airlines to upgrade the qua lification for American Airlines’s B757 #2 Level C, FAA #389 Flight Simulation Trai ning Device (FSTD) to Level D, after satisfactory evaluation of the Level D capable visual system, and to remain grandfathered under AC 120-40B, as provi ded by 14 CFR Part 60.17(a). This will bring the FSTD to same qualification level as the like American Airlines’s B757 #1 Level D, FAA #324, currently grandfathe red under AC 120-40B as provided by 14 CFR Part 60.17(a). Both FSTDs will be exac tly alike, in every way, after completion of the visual upgrade.