-APARTMENT OF 

Flight Training International, Inc. (FTI) iHK!^?ORTATlON ^ 

•:;'ETOPERMiOMS 

November 24, 2010 ^m HO^'^ 2 b A 10- 38 

To: U.S. Department of Transportation Via Federal Express and 

Docket Operations First Class Postal Mail 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

ATTN: Raymond Towles 

Acting Director, Flight Standards Service (AFS-10) 

Federal Aviation Administration 

From: Flight Training International, Inc. 

3401 Quebec Street, Suite #1950 

Denver, CO 80207 

800-233-0050 / 303-329-631 l/ac5/w/7e 

RE: Petition for Reconsideration 

Exemption No. 10146 

Regulatory Docket No. FAA-2010-0836 

Dear Sirs: 

Flight Training International, Inc. requests this office submit the enclosed Petition for 

Reconsideration of the FAA Letter of Denial dated September 28, 2010. 

Please contact me or the following individual if you have further questions: 

Chuck Hagan 

Training Center Manager 

Flight Training International, Inc. 

chagan(a),ftiratings .com 

800-233-0050 office / 303-329-6311 facsimile 

Very truly yours. 

-Kid^^y^ k [^i^lMrM'ii'd,~> ^•^^J 

George Smith 

President, Flight Training International, Inc. 

gsmith(a),ftiratings.com 

Enclosures: Petition for Reconsideration 

5976353V. 1 135599/00004 
Flight Training International, Inc. (FTI) 

November 24, 2010 

To: U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

ATTN: Mr. Raymond Towles 

Acting Director, Flight Standards Service (AFS-10) 

Federal Aviation Administration 

From: Flight Training International, Inc. 

3401 Quebec Street, Suite #1950 

Denver, CO 80207 

800-233-0050 

303-329-631 l/ac5/w//e 

RE: Petition for Reconsideration 

Exemption No. 10146 

Regulatory Docket No. FAA-2010-0836 

Dear Mr. Towles: 

Flight Training International, Inc. ("FTI") wishes to petition the FAA for reconsideration 

of its September 28, 2010 denial of FTI's Petition for Exemption from certain provisions of 14 

C.F.R. § 142.53(b). FTI respectfully submits this Petition for Reconsideration pursuant to 

14 C.F.R. § 11.101(b), in that FTI believes the FAA made important factual errors in its denial of 

FTI's original petition. 

FAA Basis for Denial 

The FAA beised its denial of FTI's Petition for Exemption on its previous Denial of 

Exemption No. 7418 (January 11, 2001) claiming that such denial was "similar in all material 

respects" to those presented in FTI's Petition.' 

' This pre-9-11 denial was issued at a time when the granting of permission for admission to the flight deck 

pursuant to 14 C.F.R. § 121.547 (required for line observation or flight observation as a means to satisfy 

§ 142.53(b)) was far more lenient than it is in post 9-11 operations. 

5976320V. 1 135599/00004 
U.S. Department of Transportation 

November 24, 2010 

Page 2 

Factual Errors in FAA's Basis for Decision 

The FAA's reliance on the 2001 Denial of Exemption fails to take into account the 

radical improvements in aircraft simulators since 2001 and the resulting replication of the actual 

flying environment experienced in line operations. 

FTI uses only Level C and D simulators. The improved levels of visual depictions, 

motion and sound in these simulators results in strikingly realistic replication of actual flight 

operations. For instance, FTI has the capability of replicating de-icing procedures through the 

use of enhanced visual depictions (snow) and the sound of de-icing application (simulated with 

the sound of rain). Additionally, because of the advancement in airport modeling and 

lighting/signage in Level C and D simulators, FTI has the capability to replicate operations under 

Surface Movement Guidance & Control System ("SMGCS") in a startingly realistic manner. 

These improvements in aircraft simulators since 2001 have resulted in far more realistic 

operations consistent with the actual flying environment. 

In fact, today's simulators are so realistic that pilots are not required to perform landings 

in the aircraft prior to certification. More often than not, a pilot's first landing in an actual 

aircraft will be in an aircraft full of passengers. 

Additionally, Denial of Exemption No. 7418 was based in part on the belief that 14 

C.F.R. § 142.53(b) provided exposure to Land and Hole Short Operations ("LAHSO") and 

procedures for reducing runway incursions.'^ (Denial of Exemption No. 7418 at 3.) The Level C 

and D simulators FTI uses in its training provide sophisticated airport models including realistic 

lighting/signage and air traffic controller phraseology/scripting that allows realistic training in 

both LAHSO and the prevention of runway incursions by developing multiple training scenarios. 

For the reasons stated above, FTI respectfully requests that the Administrator 

acknowledge that advancements in aircraft simulators in visual depiction, sound and motion have 

progressed so far that the "realism" of the simulation has reached a level where it is possible to 

nearly replicate the actual flying environment. Therefore, use of the aircraft simulator as an 

alternative means of compliance with § 142.53(b) should be allowed. 

Therefore, FTI respectfully requests that that FAA reconsider its denial of FTI's Petition 

for Exemption and grant FTI exemption from 14 C.F.R. §142.53(b)(l), 142.53(b)(2)(i) and 

142.53(b)(3)(i). 

^ It is important to note that the FAA does not require that LAHSO and prevention of runway incursions be 

included in approved Part 142 training programs. Individual certificated operators may request that these training 

scenarios be covered, but they are not part of any FAA program requirements. 

5976320V. 1 135599/00004