April 12, 2016

Mr . David King AW609 Chief Engineer AgustaWestland

3050 Red Lion Road Philadelphia, PA 19114

Dear Mr. King:

This is in response to your August 5, 2015 letter posted to public Docket No. FAA

- 2015

- 4800 petitioning the Federal Aviation A dministration (FAA) to add § 60.38 of Title 14, Code of Federal Regulations (14 CFR) to designate applicable F light S imulation T raining D evice (FSTD) qualification standards representing aircraft class that are not covered in other

sections of this rule

.

The FAA has reviewed AgustaWestland’s petition for rulemaking and the information provided. In the petition, you point ed out that p art 142 requirements state that an FSTD used

in an FAA

- approved training program must be qualified under part 60

. H owever
, p art 60 does not adequately address special classes of aircraft such as the tilt rotor. Furthermore, the deviation authority in § 60.15(c), which authorizes the Administrator to consider deviations from the part 60 Q ualification Performa nce Standards (Q P S) , does not cover instances where an FSTD evaluation standard for a special class of aircraft is not defined in the part 60 QPS

.

You propose adding the following section to the main requirement section of part 60:

§ 60.38 Designation of applicable FSTD qualification standards representing aircraft

class that are not covered in other sections of this rule.

(a). For special classes of aircraft (e.g. p owered

- l ift, tiltrotors, gliders, airships, and other nonconventional aircraft) for which FSTD qualification st andards have not been issued under this part, the applicable requirements will be the portions

of those other FSTD qualification standards contained in Appendix A, B, C, or D of this part found by the FAA to be appropriate for the aircraft and applicable

t o a specific type design or such criteria as the FAA may find provide an equivalent level of safety.2 (b). For FSTDs qualified under this section, the standards used to initially evaluate and qualify the FSTD will become the permanent qualification basis of the FSTD and recorded in the FSTD's Master Qualification Test Guide (MQTG).

(c). The evaluation and qualification of an FSTD that represent an aircraft whose category and class has not been addressed in other appendices of this rule may be evaluated and qualified utilizing alternate means of compliance.

(d). The alternate means of compliance standards for qualification of the FSTD will be developed by the sponsor and approved by the FAA N ational S imulator

P rogram M anager (NSPM)

.

The FAA has a priority list for rulema king that addresses many issues crucial to the safety of the aviation community and the traveling public. The FAA must prioritize its limited rulemaking resources to provide the greatest safety benefit to the aviation system as a whole.

The FAA has determ ined this proposed change to have merit as a reasonable accommodation allowing FSTDs for nonconventional aircraft (i.e. those aircraft not fitting within the existing QPS appendices of p art 60) to receive qualification in a timely manner while ensuring

suf ficient testing is accomplished to qualify the device.

For the reasons above, the FAA will consider this during prioritization of future rulemaking projects

.

Sincerely,

/s/

Dale Bouffiou Deputy Director, Office of Rulemaking