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 Exemption), 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 satisfactory evaluation of the Level D capable 

visual system, and for FSTD to remain grandfathered 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 requires 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 criteria 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 a 
American Airlines Petition for Exemption 14 (CFR Part 60.17(d))  Page 2 

higher training level than it had before under the 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 platform, flight controls, and visual display 

systems were installed during simulator manufacture. 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 both 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 manufacturers’ 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 utilizes an identical FSTD qualified to 

Level D. 

2. This would allow for more standardization within the training program by using 

common visual models and scenarios within a common qualification. 

• This exemption proposal focuses on the standardization of the training program by 

bringing like FSTDs to the same highest qualification level which presently exists in 

the training program. The exemption will provide 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) 

Attachment 
American 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 exemption from Section 14 CFR Part 60.17(d) to 

permit American Airlines to upgrade the qualification for American Airlines’s B757 #2 

Level C, FAA #389 Flight Simulation Training Device (FSTD) to Level D, after 

satisfactory evaluation of the Level D capable visual system, and to remain 

grandfathered under AC 120-40B, as provided 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 grandfathered under AC 120-40B as provided by 14 

CFR Part 60.17(a). Both FSTDs will be exactly alike, in every way, after completion 

of the visual upgrade.