CAE SimuFlite PO Box 619119 2929 W Airfield Drive DFW Airport, TX 75261

United States

CAE Inc. Confidential and/or Proprietary Informatio n 

### July 25, 2011

Docket Management Facility US Department of Transportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W12-140 Washington, DC 20590

Sent By Facsimile & Email

Dear Sir/Madam:

RE: Petition for Exemption to 14 CFR Part-60 Table C2A, Paragraph 4.b.1, 4.b.2, and 4.b.3.



### CAE Inc. respectfully submits this request for an e xemption with respect to the requirement for a tolerance of 14 Code of Federal Regulations P art 60 Table C2A, paragraphs 4.b.1, 4.b.2, and 4.b.3 which requires a geometric error b etween the image generator eye point and the pilot eye point to be less than 8°.

The enclosure to this letter provides the details o f the petition, in accordance with Title 14 CFR section 11.81. The following summary is prov ided for the Federal Register in accordance with 14 CFR §11.81(f):

“CAE Inc. respectfully submits the following reques t for an exemption to the tolerance requirements of 14 CFR Part 60, Continuous Field-of -View tests as stated in Table C2A paragraphs 4.b.1, 4.b.2 and 4.b.3. CAE seeks exempt ion to extend the requirement for the geometric error between the Image Generator eye point and the pilot eye point from ‘8° or less’ to ‘12° or less’ .”

I trust that this correspondence will be to your sa tisfaction, and it satisfies the requirements of 14 CFR §60.5; should you have any questions or requ ire additional information please do not hesitate to contact the undersigned by email Itash.Samani@cae.com or telephone at (972) 456-8078.

Thank you for your consideration of this request.

Sincerely,

___________________________ Itash Samani, Head of Global FSTD Regulations

Cc: Mr. Stephane Clement, Director Regulatory Affai rs Page 2 of 5 July 25, 2011

CAE Inc. Confidential and/or Proprietary Informatio n This petition contains the following elements:

• Introduction (Extent of Relief) • Background on 14 CFR Part 60 • Statement of Public Interest • Statement of no Adverse Effect on Safety • Conclusion

The extent of relief CAE seeks, and the reason CAE seeks the relief

14 CFR Part 60, objective test for demonstration of the Continuous Field-Of-View (Test Entry No’s: 4.b.1; 4.b.2; and 4.b.3) requires that “Any geometr ic error between the Image Generator eye point and the pilot eye point must be 8° or less.”

The Helicopter International Working Group (H-IWG) performing the work under the auspices of the Royal Aeronautical Society (RAeS) which is currentl y working on the development of the standards for the ICAO 9625 Revision 3 has reviewed the acceptabl e tolerance for this error to be 12°.

CAE’s own technical and training analysis supports the H-IWG position and therefore under the provisions set forth in Title 14 Code of Federal Re gulations (14 CFR) §11.81, CAE petitions the FAA to grant exemption from the tolerance requireme nt of 8°. In accordance with §11.81 (c), the extent of relief sought via this petition is limite d to extending the tolerance beyond “8° or less” to “12° or less”.

As required by §11.81(d) and 11.81(e), it will be s hown in the following technical assessment that granting of this petition for exemption will not ad versely affect safety, and is in the "Public Interest."

Per §11.81(h), CAE requests the privileges of this exemption be extended outside the United States. FAA has Bilateral Aviation Safety Agreement s with a number of countries and a number of CAE simulators have been qualified under the BAS A Flight Standards Agreements, Simulator Implementation Procedures (SIP). This extension of privileges is therefore necessary for operations based within foreign countries for equip ment which has been qualified under FAA 14 CFR Part 60 and in use under an FAA approved traini ng program or for operations having bilateral agreements with the United States accepti ng FAA 14 CFR Part 60 as their standard for the qualification of Flight Simulation Training Equ ipment.

Background on the Geometry Error Requirement of 14 CFR Part 60

The change from the FAA Advisory Circular 120-63 st andard to the 14 CFR Part 60 regulations for the qualification and use of Flight Simulation Training Devices with regards to helicopter simulators included the removal of the requirement for collima ted display systems for rotorcraft simulators along with the addition of a requirement for a maximum al lowable geometric error. The relevant sections of both documents, as they apply to Level D simulators , are as follows:

AC120-63, Appendix 1, Paragraph 4.d Continuous minimum collimated (or equivalent) visua l field of view of 180 degrees horizontal and 60 degrees vertical available to each pilot. In addition, operational chin windows representative of those found in the helicopter mod el simulated are required.

Part 60, Table C2A, Paragraph 4.b.3 Continuous field-of-view of at least 176° horizonta l and 56° vertical field-of-view for each pilot simultaneously. Any geometric error between the Image Generator eye point and the pilot eye point must be 8° or less

. Note: This requirement did not exist in the previous FAA AC120-63 standard nor do es it exist in the current JAR/EASA FSTD-H. Page 3 of 5 July 25, 2011

CAE Inc. Confidential and/or Proprietary Informatio n The effect of these changes is to eliminate the req uirement for collimation (allowing use of direct projection/dome displays) while limiting the allowa ble angular error seen by the pilot(s) that results from the removal of the collimation.

Parallax Error

The angular error in a dome display is a function o f the distance between the design eyepoint (DEP, the position for which the system geometry has been optimized) and the pilot eyepoint as well as the distance from these eyepoint‘s to the dome surface. The error is also a function of which point in the field of view (FOV) is being tested, and the modele d distance to the point of the scene in view, but assuming an eyepoint that is roughly centered fore/ aft and up/down relative to the center of curvature of the dome the point of maximum error is generally fo r distant objects straight ahead of the eyepoint. T he diagram below shows the error assuming that the DEP was selected to be the midway point between the PEP and CPEP rather than being located at the P EP or CPEP. Of course, it is always possible to compute the distortion from the PEP (effectively mo ving the DEP to overlay the PEP position), and hence have zero error from the PEP, but this roughl y doubles the error from the CPEP.

For the situation shown in the diagram the error ca n be computed as:

error=atan(eyepoint_offset/dome_radius)

Alternately, the maximum allowable lateral eyepoint offset for a given allowed error and dome radius can be computed as:

eyepoint_offset = dome_radius * tan(error) Page 4 of 5 July 25, 2011

CAE Inc. Confidential and/or Proprietary Informatio n The second formula is useful for determining which helicopter models can be supported by a given dome configuration. The resulting values are shown in the table below for a range of radii and allowab le errors. It should be noted that moving the cockpit relative to the dome center provides the potential for increasing the distance from the eyepoint to the do me, and can therefore provide some flexibility in t he maximum eyepoint offset that can be supported for a given allowable error and dome radius, but the table still provides useful guidelines for suitable display system configurations.

Error Radius Radius Eyepoint offset degrees Feet Metres Inches mm 8 8 2.44 13.49 343 8 9 2.74 15.18 386 8 10 3.05 16.86 428 8 11 3.35 18.55 471 8 12 3.66 20.24 514 8 13 3.96 21.92 557 8 14 4.27 23.61 600 8 15 4.57 25.30 643

10 8 2.44 16.93 430 10 9 2.74 19.04 484 10 10 3.05 21.16 537 10 11 3.35 23.28 591 10 12 3.66 25.39 645 10 13 3.96 27.51 699 10 14 4.27 29.62 752 10 15 4.57 31.74 806

12 8 2.44 20.41 518 12 9 2.74 22.96 583 12 10 3.05 25.51 648 12 11 3.35 28.06 713 12 12 3.66 30.61 777 12 13 3.96 33.16 842 12 14 4.27 35.71 907 12 15 4.57 38.26 972

These values can be compared to the lateral eyepoin t offsets of typical helicopter types

AIRCRAFT TYPE Eyepoint Offset Eyepoint Offset

mm CH53G 24 610 UD-1D, AB205 22 559 LYNX RBL 18.5 / LBL 17.52 RBL 470/ LBL 445 BELL 412 22 559

CH47 RBL 22 / LBL 21 RBL 559 / LBL 533 MERLIN 23.62 600

PUMA RBL 19.3 / LBL 19.7 RBL 490 / LBL 500

S76 RBL 18 / LBL 17 RBL 457 / LBL 432 UH- 24 610 Page 5 of 5 July 25, 2011

CAE Inc. Confidential and/or Proprietary Informatio n 60/Blackhawk

TH-57 RBL 14.21 / LBL 11.21 RBL 361 / LBL 285

TH-67 RBL 14.21 / LBL 11.21 RBL 361 / LBL 285

OH-58 RBL 14.21 / LBL 11.21 RBL 361 / LBL 285 AH/MH-6 13.4 340 A109 13.2 335 AB139 21.7 550 H92 22.0 559 EC135 15.4 390 NH90 24.8 630 EC175 22 559

How our request would benefit the public as a whole

The FAA clearly recognized the benefits of direct p rojections systems to allow for more cost effective solutions to building rotary wing FSTDs and with th is in mind the consideration that larger domes are inherently more expensive to build (larger/heavier designs in turn driving motion system requirements, more and/or brighter projectors required to meet br ightness requirements) and to operate (larger facil ity requirements). It is therefore inherently preferabl e to use smaller domes where possible. Therefore th is provides for the more cost effective build of these FSTDs, while still maintaining the high standards required performing the necessary training, and the public as a whole benefits from the fact that more crews are able to complete such training due to aff ordability.

Statement of no Adverse Effect on Safety

There is no adverse effect on safety. The grant of exemption will allow for the most cost effective build of Flight Simulation Training Devices and the refore can only help towards better safety. Experiments performed by the RAeS IWG support the v iew that the expected errors, limited to 12° do not adversely affect the performance of maneuvers b y either pilot.

Conclusion:

The grant of this exemption is in the public intere st, it will allow the FAA to align the requirement for the geometric error to the standard recommended by the industry and global regulatory bodies participating in the RAeS IWG and will help towards reducing the cost of developing rotary wing simulators, which can only further help towards an improvement in the safety levels for rotary wing operations.