September 19, 2014

US Department of Transportation

Docket Operations

West Building Ground Floor

Room W-12-140

1200 New Jersey Avenue, SE

Washington, DC 20590

RE: Docket FAA2014-0387 Supplemental information

 Purchase of a Level C turbine device

Dear Sir or Madam:

US Aviation Group LLC, d/b/a US Aviation Academy has been assigned Docket 

# FAA2014-0387 as a result of our previous Exemption application on May 21, 2014.

The exemption, if granted, would allow Chinese nationals employed by Chinese Part 121 

carriers that graduated from various US Aviation Academy programs to take the FAA 

ATP (121) written knowledge test without meeting the requirements of 14 CFR part 

61.35(a)(2) and 14 CFR Part 61.156(b).

In further support of that Exemption request, US Aviation Group LLC has entered 

into a contract with Aeronautical Systems Engineering, Inc (ASE), a Florida based 

simulator manufacturer, to acquire a new 14 CFR Part 60 approved Full Flight Simulator 

built to Level C qualifications to further enhance the training conducted for Chinese 

nationals employed by Chinese Part 121 air carriers. The device is scheduled for delivery

and 14 CFR Part 60 certification in the second quarter of 2015. It will be a “change out” 

device with dual certification as a Beechcraft King Air 350 and Beechcraft King Air 

C90A.

ASE is a well known and proven supplier of this type of equipment and the work 

is well underway over the past several months to produce the device on schedule. We 

fully expect an on time delivery of the device.
As pointed out in our original Exemption request, 14 CFR Part 61.156(b) requires 

the FSTD to represent a turbine aircraft with a take-off weight of at least 40,000 pounds. 

Neither model of King Air represented by the device being purchased represents an 

aircraft that meets that weight requirement. As a result, even with this added purchase, 

US Aviation still needs an Exemption to the regulations already sited. US Aviation 

Academy does not believe that the training value is in the weight of the aircraft as much 

as it is in the avionics, systems, and level of training scenarios that can be conducted in 

such a device in a high level of controlled safety.

IMPACT ON FLIGHT SAFETY

The addition of the Level C Full Flight Simulator will allow training in a turbine 

aircraft that replicates the training aircraft available in the FAA Approved flight training 

programs used in the Chinese training programs at this time by the Academy. Currently

all Chinese cadets train for 20 hours in a King Air aircraft as the final course at the 

Academy. Once the device is installed and approved, the CAAC will allow 10 of the 20 

hours to be conducted in a Level C King Air flight simulator.

High risk training that is currently conducted in the actual aircraft can then be 

conducted safely in the Level C flight simulator. In addition, many training events that 

could never be safely conducted or actually practiced in the real aircraft can be conducted 

easily in the flight simulator without danger to crew, equipment, or the general public as 

a whole. The increased intensity of training will produce a more proficient pilot with a 

better foundation of knowledge and experience to prepare them as they move into their 

roles as first offices in heavier turbine equipment with their respective airlines.

IMPACT ON THE GENERAL PUBLIC (14 CFR Part 11.71(a) (4))

At the present time, many of our Chinese airline customers are pulling their ATP 

training from all United States training providers since their cadets can not complete the 

FFS requirements of the new regulations that went into effect on August 1, 2014 as a 

perquisite of the ATP multi crew written knowledge test.

Officials from the CAAC have traveled to Washington and have met with the 

FAA to outline the impact of the change in policy on their cadets training in the United 

States.

SUMMARY

US Aviation Group, LLC, is committed to providing a high quality US based 

training environment for Chinese national airline customers in a cost effective manner 

that allows the regulatory requirements of both countries to be met. The addition of a 
high quality Part 60 Level C Beechcraft King Air device in the immediate future will not 

meet the 40,000 weight requirement of 14 CFR Part 61.156(b), but it will meet the intent 

of the regulation by exposing all cadets to effective training in a Level C turbine aircraft. 

The King Air was selected because it represents the actual aircraft currently being used 

by US Aviation Group, LLC in the FAA Approved Turbine Transition flight course in 

use already by US Aviation Academy. All cadets complete the flight course after 

completing the FAA Approved 40 hour ATP and 130 hour Turbine Transition courses.

We sincerely believe that our request, when approved, will serve all parties best 

interests, and still meet all of the intended regulations and safety concerns.

Respectfully submitted as additional information,

Ray Heyde

Vice President, General Manager

US Aviation Academy

4850 Spartan Drive

Denton, TX 76207

rheyde@usaviationacademy.com

940-383-2484

www.usaviationacademy.com