800 Independence Ave, SW Washington DC 20591

December 12, 2016

Exemption No. 10518C Regulatory Docket No. FAA-2011-0814

Mr. Itash Samani CAE, Inc.

P.O. Box 619119

2929 W. Airfield Drive DFW Airport, Texas 75261

Dear Mr. Samani:

This letter is to inform you that the FAA has initiated an amendment to Exemption No. 10518, as amended. It explains the basis for our decision, describes its effect, and lists the

conditions and limitations. The FAA has modifi ed the conditions and limitations associated with this exemption as detailed below.

The Basis for Our Decision

By letter dated April 23, 2016, the FAA grante d CAE’s petition to extend Exemption No. 10518, as amended. That exemption from part 60, Appendix C, Table C2A, paragraph 4.b.1, 4.b.2, and 4.b.3 of Title 14, Code of Federal Regulations (14 CFR) allows a geometric error between the image generator eye point and the pilot eye point up to 10° for the AgustaWestland AW-139, Sikorsky S-76C++, Sikorsky S-92, AgustaWestland AW-189, Eurocopter EC-225, Sikors ky UH-60L, Sikorsky UH-60M, Be ll B-407, Bell B-429, and Bell B-525 Level D Full Flight Simulators (FFS).

Since issuing that grant of ex emption, the FAA realized that it failed to address CAE’s

request 1 that the following platforms be added to the applicability of the exemption:

1. AgustaWestland AW-109

2. AgustaWestland AW-169

3. Bell B-412

4. Eurocopter EC-135

1 CAE requested that FAA expand relief to encompass these platforms in its January 12, 2016 petition for

extension.2

5. Eurocopter EC-145

6. Sikorsky S-70i

7. Boeing CH-47

8. AgustaWestland AW-101

The FAA has reviewed the petitioner’s request to add these platforms to the exemption along with the safety analysis supporting the initial grant of exemption and finds that extending the exemption to devices representi ng other helicopter makes and models would maintain a level of safety equivalent to th e regulation. While the ove rall parallax/geometric error is defined, in part, by the aircraft speci fic cockpit structure and layout, the actual aircraft make and model being represented in the simulator is immate rial as long as the overall parallax/geometric error works out to less than 10 degrees. Accordingly, the FAA has updated Conditions and Limitation No. 1 of this exemption to include the additional helicopter makes and models as id entified by the petitioner.

In issuing Exemption 10518B, the FAA found that the original exemption allowing up to 12 degrees of parallax/geome tric error needed to be reduced to 10 degrees.

The factors leading to the decisi on to use the 10 degree limit are:

1. The FAA National Simulator Program (NSP) review of an AW-139 showed that the larger angle of geometric error was unaccep table to both the NSP Inspector as well as other subject matter expe rt pilots. After CAE rewo rked the cockpit layout, a measured offset of 9.75 degrees was achie ved, and this was found to be generally acceptable. Even so, a restriction was adde d to the Statement of Qualification (SOQ)

at the time of the initial evaluation:

Visual eye point parallax error was meas ured 9.75 degrees at a point center of the two pilots. Complications occur during two pilot coordinated crew operations when the eye point is not selected to the center position. Multi

Crew Pilot tasks are not authorized when the eye position is selected for one of the pilot positions which creates an ex cessive parallax for the other pilot.

2. International Civil Aviation Organizati on (ICAO) 9625 Volume II – Helicopters, First Edition 2012 also specifies a maximum limit of 20 degrees for a pilot not flying, and recommends that for two-pilot tr aining, the design eye point be centrally located thereby providing both pilots with a less than or equal to 10 degree offset.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the reque sted extension of, and amendment to, the exemption would not set a precedent, and a ny delay in acting on th is petition would be

detrimental to CAE.

Our Decision The FAA has determined that the ju stification for the issuance of Exemption No. 10518, as amended, remains valid w ith respect to this exemption and is in the public interest. Therefor e, under the authority provided by 49 U.S.C. §§ 106(f), 401133

and 44701, which the FAA Administrator has dele gated to me, CAE, In c. is granted an extension to Exemption No. 10518, as amended from part 60, Appendix C, Table C2A, paragraph 4.b.1, 4.b.2, and 4.b.3 that allows a geom etric error between the image generator eye point and the pilot eye point up to 10° for the AgustaWestland AW-101, AgustaWestland AW-109, AgustaWestland AW-139, AgustaWestland AW-169, AgustaWestland AW-189, Bell B-407, Bell B- 412, Bell B-429, Bell B-525, Boeing CH-47, Eurocopter EC-135, Eurocopter EC-145, Euro copter EC-225, Sikorsky S-70i, Sikorsky S76C++, Sikorsky S-92, Sikorsky UH-60L; and Sikor sky UH-60M Level D FFS. . This grant exempts CAE from the part 60, continuous fiel d-of-view tests as stated in Table C2A paragraph 4.b.1, 4.b.2, and 4.b.3 to the extent necessary to allow CAE to obtain FAA qualification of the applicable Flight Si mulation Training Devices (FSTDs) to the qualification level requested for any helicopte r FSTDs manufactured by CAE, subject to the following conditions and limitations.

Conditions and Limitations

1. This exemption applies to the following helicopter makes and models:

a. AgustaWestland AW-101;

b. AgustaWestland AW-109;

c. AgustaWestland AW-139;

d. AgustaWestland AW-169;

e. AgustaWestland AW-189;

f. Bell B-407;

g. Bell B-412;

h. Bell B-429;

i. Bell B-525; j. Boeing CH-47;

k. Eurocopter EC-135;

l. Eurocopter EC-145;

m. Eurocopter EC-225;

n. Sikorsky S-70i;

o. Sikorsky S-76C++;

p. Sikorsky S-92;

q. Sikorsky UH-60L; and

r. Sikorsky UH-60M

2. The training implications of a visual im age parallax offset will remain the same regardless of the specific he licopter being simulated.

3. A geometric error of no greater than 10 degr ees (per pilot flying) is allowed subject to evaluation by a National Simulator Program (NSP) Aviation Safety Inspector by conducting ground and flight maneuvers to valid ate the geometric/parallax error does not negatively affect qualified traini ng, testing, or checking tasks.

4. If the objective/subj ective testing is successful, the NSP Inspector will make a recommendation to the National Simulator Program Manager (NSPM) for final approval.4

Any training maneuver found to not be subjectively acceptable due to geometric/parallax error will be task restricted on the FSTD’s Statement of Qualification (SOQ) as determ ined appropriate by the NSPM.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 10518, as amended, to April 30, 2018 unless sooner superseded or rescinded.

Any FSTDs previously qualifie d under earlier versions of this exemption retain the qualification status under which they were qua lified, providing a copy of the exemption in effect at the time of qualification is retained within the Master Qualification Test Guide for

that device.

Sincerely,

/s/ John Barbagallo Deputy Director, Flight Standards Service