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 modified the conditions and limitations associated 

with this exemption as detailed below. 

The Basis for Our Decision 

By letter dated April 23, 2016, the FAA granted 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, Sikorsky UH-60L, Sikorsky UH-60M, Bell B-407, Bell B-429, and Bell 

B-525 Level D Full Flight Simulators (FFS). 

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

request1

 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 representing other helicopter makes and models would 

maintain a level of safety equivalent to the regulation. While the overall parallax/geometric 

error is defined, in part, by the aircraft specific cockpit structure and layout, the actual 

aircraft make and model being represented in the simulator is immaterial 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 identified by the petitioner. 

In issuing Exemption 10518B, the FAA found that the original exemption allowing up to 12 

degrees of parallax/geometric error needed to be reduced to 10 degrees. 

The factors leading to the decision 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 unacceptable to both the NSP Inspector as well 

as other subject matter expert pilots. After CAE reworked the cockpit layout, a 

measured offset of 9.75 degrees was achieved, and this was found to be generally 

acceptable. Even so, a restriction was added to the Statement of Qualification (SOQ) 

at the time of the initial evaluation: 

Visual eye point parallax error was measured 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 excessive parallax for the other pilot. 

2. International Civil Aviation Organization (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 training, 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 requested extension of, and amendment to, the 

exemption would not set a precedent, and any delay in acting on this petition would be 

detrimental to CAE. 

Our Decision The FAA has determined that the justification for the issuance of 

Exemption No. 10518, as amended, remains valid with respect to this exemption and is in 

the public interest. Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113 
3

and 44701, which the FAA Administrator has delegated to me, CAE, Inc. 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 geometric 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, Eurocopter EC-225, Sikorsky S-70i, Sikorsky S76C++, Sikorsky S-92, Sikorsky UH-60L; and Sikorsky UH-60M Level D FFS. . This grant 

exempts CAE from the part 60, continuous field-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 Simulation Training Devices (FSTDs) to the 

qualification level requested for any helicopter 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 image parallax offset will remain the same 

regardless of the specific helicopter being simulated. 

3. A geometric error of no greater than 10 degrees (per pilot flying) is allowed subject 

to evaluation by a National Simulator Program (NSP) Aviation Safety Inspector by 

conducting ground and flight maneuvers to validate the geometric/parallax error does 

not negatively affect qualified training, testing, or checking tasks. 

4. If the objective/subjective 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 determined 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 qualified under earlier versions of this exemption retain the 

qualification status under which they were qualified, 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