Southern AeroMedical Institute SAMI 1698W. Hibiscus Blvd

; 1 Melbourne, Florida 32901 Phone: 321-676-3200 www.sami-aeromedical.com Contact: Dr. Paul Buza drbuza@gmail.com 

## HAE Exemption Request Request for Exemption Ruling 61.31 (g) (2)
Purpose forthe Relief Request/Equal Level ofSafety We are seeking relief from 14 CFR Part 61, 61.31 (g) (2) which requires, in pertinent part, High Altitude Endorsement (HAE) training be conducted in a " pressurized aircraft, or in a flight simulator or flight training device that is representative of a pressurized aircraft". Due to the unique configuration of our Garmin simulation ( which represents theTBM 850 cockpit) with Zodiac Aerospace oxygen masks within the high altitude chamber some aspects ofthe simulator are difficultto incorporate. However, it is our contention that the fundamental principles of the requirement to use a pressurized aircraft, flight simulator orflight training device that is representative of a pressurized aircraft for HAE training remain intact with minor variations to accommodate the unique and beneficial physiological training afforded by the high altitude chamber. In addition tothe "type specific" protocolsthat must be accomplished for cabin depressurization emergency procedures is the added benefit ofa true reduction in cabin pressure to also teach the signs and symptoms of hypoxia as it relates to their instruments and mask systems. Hence, this HAE exemption maintains current standards while enhancing pilotskills to demonstrate their procedures in atrue hypoxic environment. The primary purpose to seek this relief is to further enhance and reinforce the training objective as to the dangers of cabin depressurization. By utilizing a type specific trainer that is matched with a true reduction in cabin pressure achieves a model that would occur during a real emergency. Current HAE training is conducted in normal sea level environments where oxygen levels are normal and only a 

### simulation ofdecompression/lowoxygen environment is possible. In an actual decompression eventthe pilots will perform theiremergency procedures in the lowoxygen environment.This exemption seeks to further augment the existing training by demonstrating proficiency 

### "at altitude" as well as at sea level. By learning the physiological effects of hypoxia which is "highly recommended" by the FAA (Advisory C:ircular AC 61-107 (B), paragraph 2-7) while engaged in mandatory type specific HAE training maintains and augments further the fundamental principles of the high altitude endorsement which is to be "representative of the aircraft". The simulation device set-up is such that the pilot will demonstrate proficiency in mask donning followed by proper communications and emergency descent procedures. Our set-up meets the intent of the rule and, consequently, an equal level of safety. The addition of

1exposure and practice in a low oxygen environment increases pilot knowledge on his or her specific signs and symptoms of hypoxia, and ultimately increasing safety.



### Benefit to the Public Fatalities associated with cabin depressurization remains problematic within the industry. The primary benefit to the public is the enhancement of pilot training to improve aviation safety. The provision of type specific HAE training with the high altitude chamber improves the current training standards to further enhance learning ofthe dangers of hypoxia and the need for early intervention and utilization of the high altitude emergency protocols. The additional emphasis of "slow onset hypoxia" training in addition to the rapid or explosive models adds training benefit to the "insidious" nature of a slow cabin depressurization. Review offatal accidents associated with cabin depressurization since 1999 finds that most were related to "slow onset hypoxia" and hence the need to further augment training to address this issue. Enhancing pilot training leads to reduced risks of incidents and accident tothe flying public. The exemption would also allow easier access to the pilot community to achieve their training in a timely and cost efficient manner. The pilot would not only be able to satisfy the mandatory HAE requirement but simultaneously receive the high altitude chamber certificate (TKG1) as well. Although strongly recommended the majority of the pilot community has not undergone high altitude chamber training

.This exemption accomplishes both training modalities in a single session thereby increasing the number of pilotswho can access this training in a timely and cost effective manner. We now have a new generation of pilots in training that have not had the benefit of hypoxia training compared to prior generations. Such training would provide not only an equal level of safety, but an enhanced level of safety to the current HAE standards with the added safety benefit of true physiological training. This added safety benefit is a benefit tothe public. 

## Summary and Additional Comments (TKG3)

Primary Objective The primary object is to comply with the existing HAE requirements with the seamless integration of physiological training to achieve an enhanced "representation ofthe aircraft". Further integration ofthe "Scenario Based Physiological Training" module 

### (Appendix 1) within the course requirements further enhances the HAE training as tothe dangers of incapacitation from acabin depressurization.



### Introduction The Southern AeroMedical Institute (SAMI) has acquired a Garmin 1000 simulation device (which represents the TBM 850 cockpit) with Zodiac Aerospace quick don mask system for the purpose to provide the High Altitude Endorsement (HAE) 

### (Appendix 2).Given our location in central Florida where


### 2there are a large number of commercial pilots in training which will allow easier access to obtain the HAE training. SAMI seeks the capabilityto offer HAE certification by utilizingthe successful integration of the 3 panel Garmin 1000 simulation device with Zodiac Aerospace quick don masks within a high altitude chamber to achieve a model that is "representative of the aircraft". Traditional altitude chamber training is not mandatory but "highly recommended" 

### (Appendix 3). This exemption seeks to fuse both models ofthe HAE training along with the strongly recommended altitude chamber program into a single module that represents a more precise training environment. Scenario based principles are also included to recreate an accurate depressurization event that is "representative of the aircraft". Given the challenge to accomplish such a representation there are some limitations to the simulation device in keeping with HAE requirements. Hence, the need for the exemption. However, pilots training on the Garmin1000/Zodiac Mask systems will experience a true reduction in cabin pressure while demonstrating proficiencythat is required forthe HAE emergency protocols.



### Scenario Based Training Further incorporated into this module is the FAA FITS accepted "Scenario Based Physiological Training" module which we authored in 2008 and have currently provided this training to 2800 pilots. Our objective is to integrate these principles seamlessly with the fundamental principles of the HAE requirement. The trainee must engage in a flight plan 

### (Appendix 4) whereby a simulated and "true" decompression occurs. Several scenarios are provided to match the flight profiles most encountered by the pilot depending upon their experience and type of aircraft that they fly. An example would be an experienced Phenom 300 pilot who flies out ofAspen and the scenario is a failure of pressurization on ascent while solving an ACAS alert related to the right engine. While achieving simulated cruise altitude with the Garmin simulation device an unbeknownst new way point is instructed by ATC. The altitude in the chamber is matched to the simulated flight plan and the scenario includes a "failure of pressurization on the ascent". Here the pilot begins to experience the signs and symptoms of hypoxia at which point the alerts and alarms are engaged. The pilot at this point demonstrates his proficiency consistent with the HAE requirements. Another example would be a TBM 900 at cruise altitude of31K near Teterboro with very heavy traffic and inclement weather. Given the different scenarios the fundamental premise ofthe HAE training is to achieve an accurate representation ofatrue physiological decompression while engaging the Garmin 1000 which is representative of the TBM-850 aircraft. This module allows for creativity to create custom scenarios that closely match the pilot's flying profile. Another example is CRM based training where the crew members flytogether and train as a crew. Here the crew member not only learns his or her unique hypoxia profile but can also recognize hypoxia with the corresponding crew member further increasing situational awareness. There is even training for "companions" in general aviation that flies together such as spouses. Proficiency is demonstrated by donning of the mask followed by proper communications and emergency descent procedures. Our current configuration meets this requirement.



### 3

### The Importance ofTrapped Gas Phenomenon Learning the importance oftrapped gases can only be accomplished within a high altitude chamber. As the cabin altitude rises the volume of a gas expands. Here the pilots learn that during a cabin depressurization that he or she will note frequent ear popping, abdominal bloating and cooling ofthe cabin temperature even before thefirst symptom of hypoxia ensues. This valuable teaching point in and of itself increases situational awareness as to the reduction in cabin pressure resulting in earlier intervention before fixation ensues. Anothervaluable teaching point related totrapped gas phenomena is where the pilot learns the importance of middle ear equalization during his emergency descent not only for his crew but passengers as well. Middle ear equalization with the mask on is taught while performing an emergency descent in keeping with HAE training.


### Flight Performance Video Video recording of the flight performance allows detailed analysis of the HAE training experience 

### (Appendix 5). The subtle changes associated with hypoxia such as entering an incorrect heading or waypoint clearly shows the mental impairment ofthe pilot who otherwise feels in control. This can be easily seen on the PFD/MFD displays. For example, a heading of 270 issued by ATC but resulting in the pilot entering 280 can be easily seen. Other changes include the slowing of speech and reaction times while engaging the flight plan. The video serves as a powerful teaching tool during the post-flight debriefing and can also be used for recurrent training.



### The Importance ofRecognizing Fixation One of the primary objectives is to teach the dangers of fixation which is associated with hypoxia. The slower the onset of hypoxia the greater the fixation. While engaging the scenario based flight plan with "live"ATC communications 

### (Appendix 6) the pilot must demonstrate proficiency of his aircraft and maintain situational awareness at all times. He or she also learns how the neurocognitive impairment develops in an insidious manner making the interaction with the Garmin 1000 difficult. This is an essential teaching point as many pilots will begin to fixate and not be aware ofthe mistakes that are being made. At that point a cabin depressurization alarm is activated whereby the pilot must don his quick don mask with 1 hand in 5 seconds followed by an emergency descent in communication with ATC. 

### Oxygen Saturation Awareness Incorporated within the Scenario Based Training is physiological monitoring of the pilot's oxygen saturation profile. Worn on the wrist in a non-cumbersome fashion the oxygen saturation profiles are collected for each pilot. This data is uploaded and a report is provided to the pilot as part ofthe training 

### (Appendix 7). This emphasizes how lowthe oxygen availability is during a decompression. As important,


### 4it also emphasizes how quickly oxygen saturations normalized once the mask has been donned. On average the oxygen saturation will normalize in 1 minute. If a pilot continues to appear hypoxic after 1 minute duringthe emergency descentthe crewshould checkto make sure the mask is properlyfitted.


### Corporate and Pilot Response to the Program The feedback from experienced corporate pilots has been remarkable. Already accustomed to the HAE requirement and many who have been trained at FAA and Air Force Chamber programs appreciate the realistic scenario ofthis program. The "walkaway" message accomplished with the current curriculum is how insidious hypoxia can be and hence the need for improved situational awareness and the importance of early donning of the oxygen mask in the event of a cabin depressurization. Due to the positive feedback from the pilots the corporate response has also been encouraging. 

### As a result, Daher Socata has made the training available with the purchase of each new aircraft. The formal announcement was made July 20, 2015 at Oshkosh: http:Uwww.aopa.org/News-and-Yideo/AIINews/2015/July/20/Daher-offering-high-altitude-training?WT.mc id=150723speciai&WT.mc sect=osh Additional support by Embraer, Piper Meridian, Eclipse, Cessna 421, Twin Commanders (TKG4) and others have supportedthedevelopment ofthis program.

5

### Appendix 1 FAA FITS Scenario Based Physiological Training

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### 6Appendix 2 Garmin 1000Simulator/ZodiacAerospace Eros Series 10Masks

Appendix3 High Altitude Chamber Aircraft Configuration

7Appendix4 Flight Plan

Appendix5 Performance Review Video



### 8Appendix6 Scenario Based Flight Plan With 11UveATC11



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## ATC SCRIPT: HYPOXIC G-1000 SIMULATION

-Aircraft shouldbe addressedbytheirindividual call signs ifthey areknown. -Plan on communicationsbeingmadeeveryminute unless otherwise specified. -Numbersinbrackets representthe aircrafts anticipated simulation altitude. (not chamber altitude.)

TBM 1Miami center, Flyheading 090, climb andmaintain 9000 ft [5000 ft; ] TBM 1Leftheading 360,Altimeter 31.87 [7000 ft; ] TBM 1Left heading270, climb andmaintain 13, 000 ft [9000 ft;] TBM 1Leftheading260 [11,000 ft;] TBM 1Rightheading 190,climb andmaintainFlightlevell90 [13,000 ft] TBM 1Leftheading 180[15,000 ft;] TBM 1Indent (immediately aftertheirresponse) TBM 1Rightheading 260 [17,000 ft;] Pilotsare expectedto resetaltimetersettingupon crossingFL 180 TBM 1, Rightheading280 Squawk3428 [19,000 ft;] TBM 1 sayaltitude andheading 

### (iftheydidnotresetaltimeter) TBM 1 check altitude 

### (iftheydon't realize that they forgot to resetaltimeter) TBM 1check altimeter setting 

### (iftheystilldon't realize thatthey forgot to resetaltimeter) TBM 1Leftheading210, climb andmaintainFlightlevel 210 TBM 1Rightheading280, descend andmaintainFlightlevel200 TBM 1, restricted airspace activatednorth ofQUAZR,proceedimmediately directto ALLSO descend andMaintainFL 180. (Commence Symptom check) Thefollowing commentarycan beinterjectedbetween above communication. Cessna 738FC Miami center, descend and maintain 9000 ft, proceed directto YEHAW. Bombardier l right heading 220 Embraer 2 ident 

### 10Appendix 7 Oxygen Saturation Awareness

; ' i' i



### 11