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PraUSH 

Grapevine Training Center 

February 3,2010 

FAA-AFS-800 

The Rules Docket, AGC-10 

800 Independence Avenue S.W. ' 

Washington, DC 20591 

Subject: Request for amendment to PrestoSIM Exemption 9843 

Dear Sir/ Madame, 

There seems to be some question within the industry as to whether or not CE-500 

series aircraft with various FAA Approved STC's can be flown single pilot under the 

single pilot Exemptions issued by your office. As a result, PrestoSIM would like to make 

the following petitions to formally clarify the situation under Exemption 9843. In 

addition, PrestoSIM would like to request two additional language changes within the 

Exemption for added clarification. 

PrestoSIM, Inc. would like to formally petition the following four amendments to 

the 9843 Exemption: 

Petition 1: 

On behalf of PrestoSIM Inc., I would like to petition for the inclusion of all 

Cessna Citation model 500 series airplanes operated under any FAA Approved STC that 

does not change the model designation on the airworthiness certificate or data plate of the 

individual aircraft. This would include various performance enhancements and avionics 

upgrades that have been added to many of the older units. 

This request is for clarification purposes only since the above listed aircraft are 

already a subset of the currently approved CE-500 series models in Exemption 9843. 

We do not believe that there are any changes in the conditions and reasons 

relative to public interest and this petition provides an equivalent level of safety that was 

the basis for granting the original exemption. 

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Petition 2: 

On behalf of PrestoSIM Inc., I would like to petition for the inclusion of Cessna 

Citation model 500 series airplanes (Serial numbers 001 through 0418) equipped with 

supplemental type certificate (STC) no. SA8176SW, or STC no. SA09377SC, and either 

STC no. SA2172NM, STC no. SA645NW, or STC no. ST09559AC to be included in our 

currently approved Exemption 9843 allowing single pilot operations in the CE-500 series 

aircraft. 

This request is for added clarification purposes only since the above listed aircraft 

are already a subset of the currently approved CE-500 models in Exemption 9843 and the 

listed STC's are also currently approved under Exemption 5517K held by Sierra 

Industries. 

We do not believe that there are any changes in the conditions and reasons 

relative to public interest and this petition provides an equivalent level of safety that was 

the basis for granting the original exemption. 

Petition 3: 

On behalf of PrestoSIM Inc., 1 would like to petition for the inclusion of 

additional language in Paragraph (6)(b) that would allow for the 3 takeofl'and 3 landings 

to be included as part of an approved 14 CFR Part 142 course that meets the requirements 

of the 9843 Exemption. 

PrestoSIM requests that Paragraph 6(b) have language added that "The 3 takeoffs 

and 3 landings within the preceding 90 days in the aircraft are not required when the 

applicant is enrolled in an approved 14 CFR Pan 142 course that satisfies the recent flight 

experience requirements of 14 CFR Part 61.57 as part of the approved course. " In 

addition to operating approved flight simulators, PrestoSIM is authorized to conduct 

training, testing, and/or checking in a CE-500 series aircraft under 14 CFR Part 142 by 

paragraph A003 (Aircraft Authorization) of the FAA Approved Training Specifications. 

PrestoSIM believes that this change could be a significant cost savings to the 

applicant and that both sate and effective training would still take place. 

We do not believe that there are any changes in the conditions and reasons 

relative to public interest and this petition provides an equivalent level of safety that was 

the basis for granting the original exemption. 

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Petition 4: 

On behalf of PrestoSIM, Inc., I would like to petition, for clarification purposes, 

that Paragraph 4(f) and Paragraph 13(c) be amended to state "Use a boom microphone,'or 

headset with attached microphone: and". 

This request is based on the fact that some earlier Citation models had a "boom 

microphone" option and that option is not available on later models covered by the 9843 

Exemption. In addition, it is generally assumed and accepted that the intent is for the 

pilot not to use a hand held microphone during single pilot operations and that a fiill 

headset would satisfy the intent of the limitation. 

We do not believe that there are any changes in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original 

exemptions. 

PrestoSIM feels that all of these requests fall within the general interest of the 

public and provide an equivalent level of safety. We request that each of these petitions 

be considered independent of the others. 

Respectfially submitted. 

Ray Heyde 

Vice President 

PrestoSIM, Inc 

1000 Nolen Drive, Suite 400 

Grapevine, TX 76051 

Email: rhevde(a).prestosim.com 

Telephone: 817.488.4870 

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