European Aviation Safety Agency
Notice of Proposed Amendment 2017-13
Update of flight simulation training devices requirements
Upset prevention and recovery training, FSTD inspector competencies
framework, training matrix
RMT.0196
EXECUTIVE SUMMARY
Rulemaking task (RMT).0196 ‘Update of flight simulation training devices requirements’ has been divided into three work
packages (WP1, WP2, and WP3). According to Rulemaking Programme (RMP) 2017-2021, the related documents are
planned to be published between 2017 and 2019, in order to complete the modernisation of the certifications
specifications (CSs) and acceptable means of compliance/guidance material (AMC/GM) on flight simulation training
devices (FSTDs). The objective of this NPA (WP1) is to update CS-FSTD(A), as well as AMC/GM to Annex I (Part-FCL) and
Annex VI (Part-ARA) to Regulation (EU) No 1178/2011 (the ‘Aircrew Regulation’), to reflect the technological
advancements in the field of FSTDs whilst ensuring that FSTD provisions and AMC/GM are fully in line with the current
and proposed new training requirements and AMC/GM for flight crew (FC). Furthermore, it aims at supporting the
competent authorities (CAs), FSTD operators, and training organisations, by providing a competencies framework for
FSTD inspectors as well as guidance for the use of each type of FSTD based on the training need.
This NPA proposes to:
— increase the fidelity of the provisions in order to support the approach-to-stall training, as well as of the new upset
prevention and recovery training (UPRT) requirements as proposed by Opinion 06/2017 (RMT.0581);
— increase the fidelity of the simulation of the engine and airframe icing effects;
— develop and deploy an instructor operating station (IOS) feedback tool;
— introduce an FSTD inspector competencies framework; and
— introduce guidance on the additional (non-mandatory) capability of each FSTD to assist stakeholders in defining
the use of the appropriate FSTDs to support the training course syllabus as well as the CA in performing the
evaluation.
Additionally, the NPA proposes the option to qualify FFSs for the post-stall regime based on a special evaluation. These
optional fidelity and testing requirements, based on Federal Aviation Administration (FAA) 14 CFR Part 60, Change 2,
would support FSTD operators having dual-qualified devices (both FAA- and EASA-qualified).
Action area: Human factors and competence of personnel
Affected rules: CS-FSTD(A);
AMC/GM to Part-FCL;
AMC/GM to Part-ARA
Affected stakeholders: CAs, training organisations (approved training organisations (ATOs) and declared training organisations
(DTOs)), FSTD operators, air operator certificate (AOC) holders, pilots, instructors, examiners, FSTD
manufacturers, and aeroplane original-equipment manufacturers (OEMs)
Driver: Safety Rulemaking group: Yes
Impact assessment: Full Rulemaking Procedure: Standard
14.07.2016 25.7.2017 2017/Q4
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Table of contents
Table of contents
1. About this NPA ..................................................................................................................................... 3
1.1. How this NPA was developed ...................................................................................................................3
1.2. How to comment on this NPA...................................................................................................................3
1.3. The next steps ...........................................................................................................................................3
2. In summary — why and what ............................................................................................................... 4
2.1. Why we need to change the rules — issue/rationale...............................................................................4
2.2. What we want to achieve — objectives ...................................................................................................9
2.3. How we want to achieve it — overview of the proposals ......................................................................10
2.3.1. UPRT.................................................................................................................................................11
2.3.2. FSTD inspector competencies framework .......................................................................................12
2.3.3. Training tasks VS FSTD .....................................................................................................................13
2.4. What are the expected benefits and drawbacks of the proposals .........................................................13
3. Proposed amendments and rationale in detail .................................................................................... 15
3.1. Draft certification specifications (Draft EASA decision) ..........................................................................15
3.1.1. CS-FSTD(A) — Book 1 .......................................................................................................................15
3.1.2. CS-FSTD(A) — Book 2 .......................................................................................................................33
3.2. Draft AMC/GM (draft EASA Decision) .....................................................................................................73
3.2.1 AMC/GM to Part-FCL .......................................................................................................................73
3.2.2 AMC/GM to Part-ARA ......................................................................................................................84
4. Impact assessment (IA) ....................................................................................................................... 96
4.1. What is the issue .....................................................................................................................................96
4.1.1. Safety risk assessment .....................................................................................................................97
4.1.2. Who is affected ................................................................................................................................97
4.1.3. How could the issue/problem evolve ..............................................................................................97
4.2. What we want to achieve — objectives .................................................................................................98
4.3. How it could be achieved — options ......................................................................................................98
4.4. Methodology and data............................................................................................................................99
4.4.1. Data collection ...............................................................................................................................100
4.4.2. Methodology applied.....................................................................................................................100
4.5. What are the impacts............................................................................................................................102
4.5.1. Safety impact .................................................................................................................................102
4.5.2. Environmental impact ...................................................................................................................103
4.5.3. Social impact ..................................................................................................................................103
4.5.4. Economic impact............................................................................................................................104
4.5.5. General Aviation (GA) and proportionality ....................................................................................112
4.6. Conclusion .............................................................................................................................................113
5. Proposed actions to support implementation.................................................................................... 115
6. References ....................................................................................................................................... 116
6.1. Affected regulations..............................................................................................................................116
6.2. Affected decisions .................................................................................................................................116
6.3. Other reference documents .................................................................................................................116
7. Appendices ...................................................................................................................................... 118
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1. About this NPA
1. About this NPA
1.1. How this NPA was developed
The European Aviation Safety Agency (EASA) developed this NPA in line with Regulation (EC)
No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This
rulemaking activity is included in the EASA 5-year Rulemaking Programme3 under rulemaking task
(RMT).0196. The text of this NPA has been developed by EASA based on the input of Rulemaking Group
(RMG) RMT.0196 for WP1. It is hereby submitted to all interested parties4 for consultation.
1.2. How to comment on this NPA
Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/5.
The deadline for submission of comments is 25 September 2017.
1.3. The next steps
Following the closing of the public commenting period, EASA will review all comments.
Based on the comments received, EASA will develop a decision issuing the related CSs (CS-FSTD(A)) and
amending the AMC/GM to Part-FCL and Part-ARA.
The comments received and the EASA responses will be reflected in a comment-response document
(CRD). The CRD will be annexed to the decision.
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of
civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC,
Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216).
2
EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a
process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision
No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of
opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management-
board/decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3
http://easa.europa.eu/rulemaking/annual-programme-and-planning.php
4
In accordance with Article 52 of Regulation (EC) No 216/2008 and Articles 6(3) and (7) of the Rulemaking Procedure.
5
In case of technical problems, please contact the CRT webmaster (
[email protected]).
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2. In summary — why and what
2. In summary — why and what
2.1. Why we need to change the rules — issue/rationale
The European Plan for Aviation Safety (EPAS) 2016-2020 highlights the importance of training tools
modernisation to cope with new technologies and updated training methodologies. It also underlines
the need for aviation personnel to take advantage of the safety opportunities presented by new
technologies. RMT.0196 is one of the safety-driven rulemaking tasks related to human factors (HF) and
competence of personnel.
The driver of EPAS 2016-2020 is the commitment to improve safety. EPAS is the documented output of
an evidence-based proactive approach to safety risks, provides the reader with an overview of the risks
of the aviation safety system, and establishes safety priorities in the European Union (EU).
Furthermore, it supports safety management at EU level by complementing existing regulations and
safety investigations.
Related safety issues
The following safety recommendations (SRs) addressed to EASA through aircraft accident investigation
reports, published by the designated safety investigation authority of the Member States (MSs) (please
refer to Regulation (EU) No 996/20106), are considered in this RMT. New SRs related to this task may
be also taken into consideration during its development.
6
Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and
prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L 295, 12.11.2010, p. 35)
(http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1479716039678&uri=CELEX:32010R0996).
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2. In summary — why and what
Table 1 — SRs
SR Summary of the SR Accident/ Aircraft type Date of Location of How RMT.0196 has addressed this SR
number text incident and accident accident
registration
7
FRAN- The BEA recommends Accident AIRBUS-A330 1.6.2009 En route EASA has addressed this SR by providing the following:
2012-045 that EASA modifies the F-GZCP between Rio (a) means to evaluate the fidelity of the high-altitude
(BEA) basis of the regulations de Janeiro approach-to-the-stall simulation and of the instructor’s
in order to ensure and Paris feedback tools in order to facilitate enhanced training in
better fidelity for this area and give better feedback on the realism of the
simulators in exercise; and
reproducing realistic
(b) means to evaluate the fidelity of icing simulation in order
scenarios of abnormal
to enhance training in this area; whilst not directly linked
situations.
to this SR, EASA has evidence through occurrence reports
that this is a safety risk. In addition, EASA aims at aligning
with FAA 14 CFR Part-60, Change 2.
This was done in close coordination with RMG RMT.0581 to
ensure that FSTDs provide optimum fidelity to support new
training requirements in case these abnormal situations occur.
9
RUSF- IAC recommends EASA Accident ATR-ATR72 2.4.2012 Roschino EASA and RMG RMT.0581 pointed out that from a training
2013-002 and other simulator VP-BYZ (Tyumen) perspective, it is not realistic to train for ‘unexpected’ or
8
(AIB ) certification authorities Airport ‘sudden’ stalls.
to consider the In relation to a (type-specific) recovery from a stall, the
possibility to add into assessment of, as well as the comments received on
the simulator NPA 2015-13 also indicated concerns over potential negative
data-package the transfer of training when using a full-flight simulator (FFS).
capability to simulate
For the above reasons, RMT.0196 concentrated only on
7
Bureau d'Enquêtes et d`Analyses.
8
Accident Investigation Board.
9
Interstate Aviation Committee
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2. In summary — why and what
an unexpected or improving fidelity to support training up to the stall (approach
sudden aircraft stall at to stall).
any stage of flight.
SPAN- It is recommended that Accident DOUGLAS- 20.8.2008 Madrid- EASA and RMG RMT.0581 pointed out that from a training
2011-020 […] EASA establish DC9 Barajas perspective, it is not possible to simulate ‘sustained take-off’
10
(CIAIAC ) requirements for flight EC-HFP Airport stalls. Such dynamic stall simulations are not realistic and are
simulators so as to likely to lead to negative training and negative transfer of
allow simulator training training.
to cover sustained With reference to Section 2.3.4 of Opinion 06/2017 , in
11
takeoff stalls that relation to a (type-specific) recovery from a stall, the
reproduce situations assessment of, as well as the comments received on
that could exceed the NPA 2015-13 also indicated concerns over potential negative
flight envelope limits. transfer of training when using an FFS.
(REC 20/11)
For the above reasons, experts from RMG RMT.0196 consider
that no change to CS-FSTD(A) is necessary.
FRAN- […] EASA evaluate the Accident Piper PA31T 28.10.2011 Toulouse- This SR has been addressed by the following RMTs:
2016-006 possibility of developing OE-FKG Blagnac — RMT.0188 (FCL.002)
(BEA) an alternative Airport
Appendix 9 has been amended and new AMC created to
programme for
explain the evaluation procedures.
complex
— RMT.0196
high-performance
single-pilot aeroplanes GM1 Appendix 9 to Part-FCL is proposed to be amended
for which there is no to support the proposed changes to CS-FSTD(A).
adequate flight FTD1, FTD2/FNPTII MCC requirements in combination
simulator, for example with aeroplane
by using a flight
simulator from a similar
aeroplane.
10
Comisión de Investigación de Accidentes e Incidentes de Aviación Civil.
11
https://www.easa.europa.eu/document-library/opinions/opinion-062017
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2. In summary — why and what
From 2012 to 2016, 19 accidents classified as loss of control in-flight (LoC-I)12 occurred worldwide
during commercial air transport (CAT) operations13. In 17 of those cases, the accidents were fatal. In
the same period, in 2 of the fatal accidents, the operators had an EASA air operator certificate (AOC).
There are several scenarios and many different factors leading or contributing to LoC-I. However, it is
unanimously acknowledged that the common safety barriers to prevent such a situation from
developing out of the initial upset are flight crew (FC) awareness and the close monitoring of the flight.
Both are critical factors in detecting in-flight deviations at an early stage to prevent the upset from
evolving to a LoC-I or in recovering from LoC-I itself. The analysis of accidents and serious incidents
shows that in many cases, flight crews are caught by surprise in the event of an upset or have
limitations and difficulties to detect the upset and the approach to stall. In certain cases, the flight crew
does not realise that the aeroplane is in an actual stall.
One of the most effective safety barriers in the aviation system is the training of the aviation
personnel, and of the flight crew in particular. Continuous training has been proven to be an effective
tool in refreshing the flight crew’s knowledge and in exposing them to abnormal situations in order to
keep them abreast of the necessary flying skills and of how to perform the relevant procedures. The
use of FSTDs provides a more realistic and at the same time safer exposure of the flight crew to
abnormal situations, and permits the recreation of a wider range of scenarios. However, current FSTDs
are not qualified to reproduce aeroplane behaviour in certain flight conditions, especially in those close
or even beyond the boundaries of the FSTD training envelope. For example, current qualification
provisions for FSTDs do not mandate the simulation of the approach to stall in all conditions, a full stall,
or the performance degradation caused by ice accretion on the aerodynamic surfaces of the aeroplane.
Apart from analysing the occurrences classified as LoC-I, another objective of the analysis was to
identify occurrences that are precursors to LoC-I (e.g. before the flight crew loses control of the
aeroplane). In order to assess the need to extend the current capabilities of the FSTDs, a review of the
LoC-I CAT aeroplane accidents and serious incidents worldwide between 2012 and 2016 was carried
out, revealing a total number of 58 occurrences. The review is based on the available investigation
reports or the safety review of the operator involved. The objective of the review is to assess whether
in the occurrence scenario, the training of the flight crew in an enhanced-capability FSTD would have
made any difference in the development of the occurrence. It is acknowledged that there are many
and complex factors affecting the development of an occurrence, especially in a LoC-I event. Among
those factors, the fidelity of the FSTD used by the flight crew for the type rating or refreshment
training may have a contribution. Within the scope of this NPA, however, it is considered sufficient to
assess the contribution of the FSTD only in the potential unfolding of the occurrence.
The review focuses on two stages of the upset, the approach to stall and the full stall. In addition, it
considers the scenario of ice accretion affecting the aerodynamic performance of the aeroplane. The
analysis assumes that flight crews involved in those occurrences were trained in a non-enhanced-
capability FSTD.
12
LoC-I in the CAST-ICAO Common Taxonomy Team (CICTT) taxonomy of occurrence categories means: the loss of aircraft control
while or deviation from intended flightpath inflight, being an extreme manifestation of a deviation from intended flightpath. The
phrase “loss of control” may cover only some of the cases during which an unintended deviation occurred. (Aviation Occurrence
Categories, Definitions and Usage Notes, October 2011.)
13
List of occurrences 2012-2016. Source: EASA Internal Occurrence Reporting System (IORS) repository.
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2. In summary — why and what
In 10 (4 fatal accidents, 6 serious incidents) out of the 58 cases reviewed (23 accidents, 21 fatal
accidents, 34 serious incidents) related to LoC-I (though, not necessarily categorised as such), it was
assessed that the training of the flight crew in an enhanced-capability FSTD would have provided
additional resources to the flight crew facilitating the detection firstly of the approach to stall and
secondly of the full stall. Therefore, the training of the flight crew in an enhanced-capability FSTD
would provide a clear safety benefit, especially with regard to the simulation of the icing conditions. In
6 out of the 10 cases, the operators had an EASA AOC; 2 were fatal accidents and the other 4 serious
incidents.
In 7 cases (1 fatal accident) out of this 10, accretion of ice modified the aerodynamic performance of
the aeroplane. In all these cases, the flight crew seemed to be surprised by the sudden manifestation
of the effect of icing, causing them difficulties to control the aeroplane. In this situation, the crew had
very little time to react and this led to an imminent LoC-I in all cases except one. 4 out of the 7 cases
were serious incidents with operators having an EASA AOC.
In the other 3 cases, the flight crew was unable to detect the approach to stall and later to exercise
efficient flight control to recover from the stall. In all cases, the clear indication of an imminent stall,
such as buffeting, did not trigger the correct fight crew reaction. However, it is acknowledged that in
those situations, the flight crew normally suffers a cognitive saturation14 that makes it difficult to
process sensory information. 2 cases out of these 3 were with operators having an EAS AOC and both
were fatal accidents.
International Civil Aviation Organization (ICAO) and third-countries references relevant to the
content of this RMT
References considered for alignment
— ICAO Doc 9625, ‘Manual of Criteria for the Qualification of Flight Simulation Training Devices’,
4th Edition, 2015;
— ICAO Doc 10011, ‘Manual on Aeroplane Upset Prevention and Recovery Training’, 1st Edition,
2014; and
— Federal Aviation Administration (FAA) 14 Code of Federal Regulations (CFR) Part 60, Flight
Simulation Training Device Initial and Continuing Qualification and Use, Change 2, effective as of
31 May 2016
References to differences
No references.
14
It is normal to experience cognitive saturation in an unexpected situation and it is the aim of the training to educate the flight crews
how to identify a situation at the earliest stage and how to postpone the point where cognitive saturation starts. RMT.0196 aims at
addressing these issues by increasing the fidelity of the FSTD training.
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2. In summary — why and what
2.2. What we want to achieve — objectives
The overall objectives of the EASA system are defined in Article 215 of the Basic Regulation. This
proposal will contribute to the achievement of the overall objectives by addressing the issues outlined
in Chapter 2 of this NPA.
A baseline definition for this RMT is that training needs trigger simulator requirements, therefore, the
current update of Part-FCL under the umbrella of Opinion 06/2017 (RMT.0581) dictates in certain areas
the direction taken by this RMT.
The specific objectives of this RMT as stated in the related Terms of Reference (ToR) RMT.0196,
Issue 1, are:
(a) to ensure that FSTDs better facilitate current and future training needs by establishing the
necessary simulation fidelity levels required to support training tasks;
(b) to ensure that CS-FSTD(A) paves the way for new technologies;
(c) to reinforce the level of safety by addressing the low FSTD fidelity or lack of ability of an FSTD to
conduct certain training tasks that may have contributed to previous incidents and accidents;
(d) to harmonise CS-FSTD(A) with elements of ICAO Doc 9625 (4th Edition) and FAA 14 CFR Part 60,
Change 2, as appropriate;
(e) to ensure consistent application of the relevant FSTD regulations when qualifying FSTDs; and
(f) to align CS-FSTD(A) to the outcome of RMT.0581 ‘Loss of Control Prevention and Recovery
Training’.
These objectives were addressed to the extent defined by the activities allocated to WP1 (please refer
to Section 2.3 below).
15
Article 2 — Objectives
1. The principal objective of this Regulation is to establish and maintain a high uniform level of civil aviation safety in Europe.
2. Additional objectives are, in the fields covered by this Regulation, as follows:
(a) to ensure a high uniform level of environmental protection;
(b) to facilitate the free movement of goods, persons and services;
(c) to promote cost-efficiency in the regulatory and certification processes and to avoid duplication at national and European
level;
(d) to assist Member States in fulfilling their obligations under the Chicago Convention, by providing a basis for a common
interpretation and uniform implementation of its provisions, and by ensuring that its provisions are duly taken into account
in this Regulation and in the rules drawn up for its implementation;
(e) to promote Community views regarding civil aviation safety standards and rules throughout the world by establishing
appropriate cooperation with third countries and international organisations;
(f) to provide a level playing field for all actors in the internal aviation market.
3. The means of achieving the objectives set out in paragraphs 1 and 2 shall be:
(a) the preparation, adoption and uniform application of all necessary acts;
(b) the recognition, without additional requirements, of certificates, licences, approvals or other documents granted to
products, personnel and organisations in accordance with this Regulation and its implementing rules;
(c) the establishment of an independent European Aviation Safety Agency (hereinafter referred to as the Agency);
(d) the uniform implementation of all necessary acts by the national aviation authorities and the Agency within their respective
areas of responsibility.
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2. In summary — why and what
Due to the complexity and volume of the FSTDs requirements update, RMG RMT.0196 decided to
divide the task into three different WPs starting with the most urgent issues. A full achievement of the
objectives is expected when the two subsequent WPs are also concluded.
Each WP will be concluded with a decision; those three decisions are planned to be published in three
consecutive years. For WP1, the Decision is expected to be published in 2017/Q4 and, subsequently,
for WP2 in 2018/Q4 and for WP3 in 2019/Q4. The following figure provides an overview of this RMT’s
deliverables:
2.3. How we want to achieve it — overview of the proposals
As a general rule, when possible, the proposed technical specifications of CS-FSTD(A) are aligned with
those of FAA 14 CFR Part 60, Change 2.
The aforementioned objectives are addressed through the following proposals of WP116:
— determine if the FFSs’ capability is appropriate to facilitate UPRT;
— create a definition of ‘validated training envelope (VTE)17’;
— provide guidance on instructor operating station (IOS) feedback tools, such as the interpretation
of the velocity versus load factor (V-n) and alpha/beta diagrams;
— review the FSTD inspector competencies framework;
— provide guidance on the use of an FSTD and its qualification level;
— ensure that a gap analysis between ICAO Doc 9625 (4th Edition) and CS-FSTD(A) is performed
(WP2);
— align CS-FSTD(A) elements already present in CS-SIMD, as one constituent of operational
suitability data (OSD), to avoid duplication of information (WP2);
16
Three of the activities contained in the related ToR RMT.0196, Issue 1, will be addressed through WP2, as indicated in the text.
17
This has been replaced by ‘FSTD training envelope’.
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2. In summary — why and what
— determine the use of special FSTDs for complex high-performance single-pilot aeroplane type
rating training and checking when no full FFS qualified in accordance with CS-FSTD(A) exists for
that type or is not readily available, and make proposals for amendments to the Aircrew
Regulation, as appropriate; in this context, the term ‘available’ also needs to be further
considered and defined (WP2); and
— in coordination with RMT.0379 ‘All-weather operations’ (AWO), determine the necessary
changes to CS-FSTD(A) to meet the AWO training needs.
The WP1 proposals were subdivided into three working areas, explained in the sections below:
— UPRT;
— FSTD inspector competencies framework; and
— guidance on FSTD-related training tasks.
2.3.1. UPRT
For UPRT, ToR RMT.0196, Issue 118, proposed the following activities:
— To determine if the FFSs’ capability is appropriate to facilitate UPRT.
The evaluation criteria contained in CS-FSTD(A) are intended to address specific training tasks
that require additional evaluation to ensure adequate FSTD fidelity.
The provisions of CS-FSTD(A), Appendix 9 to Part-FCL contain additional qualification criteria for
specific training tasks applicable only to those FSTDs utilised for obtaining training, testing or
checking credits within an EASA-approved flight training programme. In order for FSTD operators
to have additional qualification for the tasks described in Book 2 of CS-FSTD(A) (AMC/GM), they
must obtain a qualification certificate (QC). FSTDs that are found to meet the provisions of
Appendix 9 will have their QC amended to reflect the additional training tasks that the FSTD has
been qualified to conduct. The additional qualification provisions, as defined in Appendix 9, are
divided into the following categories as per training tasks:
Additional qualification provisions for post-stall training tasks: according to this proposal,
qualifying the FSTD for post-stall capability is not mandated. Thus, training at post-stall
stage is not mandated. However, it is still possible to demonstrate or provide training
post-stall as long as the training organisation ensures that the FFS is qualified in
accordance with CS-FSTD(A) (special evaluation), as well as to demonstrate to the
competent authority (CA) how the ATO mitigates any potential negative transfer of
training.
Additional qualification provisions for UPRT tasks: it is proposed to qualify FSTDs for UPRT
with defined IOS, as well as additional validation data provisions.
Additional qualification provisions for engine and airframe icing training tasks.
A further proposal is to modify objective test provisions based upon the guidance of FAA 14 CFR
Part 60, Change 2, on UPRT, stall and icing.
— To create a definition of ‘validated training envelope (VTE)’.
18
https://www.easa.europa.eu/document-library/terms-of-reference-and-group-compositions/tor-rmt0196
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2. In summary — why and what
RMG RMT.0196 decided to replace this term with ‘FSTD training envelope’ to harmonise
CS-FSTD(A) with FAA 14 CFR Part 60, Change 2;
— To provide guidance on instructor operating station (IOS) feedback tools such as for the
interpretation of the V-n and alpha/beta diagrams in order to facilitate enhanced training in this
area and provide better feedback on the realism of the exercise. Moreover, additional guidance
is provided to explain the use of IOS in facilitating UPRT;
— In coordination with RMT.0379 ‘AWO’, to determine the necessary changes to CS-FSTD(A) to
meet the AWO training needs. RMG RMT.0196 came to the conclusion that there is no need for
an update at this time (WP1).
The upcoming CS-FSTD(A), Issue 2, will have the following structure:
— Book 1 will include the amended provisions as per FAA 14 CFR Part 60, Change 2; and
— Book 2 will include 5 new AMCs, 1 new GM, a new definition of ‘high angle of attack’ modelling
and an explanation of ‘modelling continuity’ (in AMC9 FSTD(A).300(3)):
AMC9 FSTD(A).300 Guidance on upset, stall (including in icing conditions), and
qualification of FSTDs: new AMC with detailed information related to the new subjective
and objective training tests;
AMC10 FSTD(A).300 Guidance on high-angle-of-attack/stall model evaluation to
harmonise with FAA 14 CFR Part 60, Change 2;
AMC11 FSTD(A).300 Guidance on high-angle-of-attack/stall model evaluation and
approach to stall for qualified FSTDs to harmonise with FAA 14 CFR Part 60, Change 2;
AMC12 FSTD(A).300 Guidance on upset prevention and recovery training (UPRT) for the
FSTD standards table: new AMC with IOS requirements for UPRT;
GM12 FSTD(A).300 Additional guidance on upset prevention and recovery training
(UPRT) for the FSTD standards table; and
AMC13 FSTD(A).300 Guidance material for engine and airframe icing evaluation
provisions to harmonise with FAA 14 CFR Part 60, Change 2.
2.3.2. FSTD inspector competencies framework
ToR RMT.0196, Issue 1, envisages the revision of the FSTD inspector competencies framework. In
particular, it proposes to:
— amend the existing initial evaluation procedure for inspectors;
— establish for the first time the required competencies of an FSTD inspector;
— include the experience required both for a technical inspector and a flight inspector; and
— clarify the initial as well as the recurrent training criteria of FSTD inspectors.
The current CS-FSTD(A) does not have an adequate level of granularity in terms of the expected and
required FSTD inspectors qualification. The incorporation of AMC1 ARA.FSTD.101(a) FSTD inspector
competency and training, GM1 ARA.FSTD.101(a) FSTD inspector competency, and
GM2 ARA.FSTD.101(a) FSTD inspector training will facilitate the implementation of the applicable
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2. In summary — why and what
rules by the CAs. Furthermore, the new proposed AMC on the inspector competencies, as well as the
GM on how to acquire those competencies, will facilitate the FSTD industry, thereby meeting the level
playing field objective. Some aviation authorities have already implemented the training programme
described in the new GM, providing a positive feedback. It is acknowledged that FSTD inspectors have
a wide range of activities in various domains and, therefore, their competencies should cover this
range and domains. However, the new AMC/GM are not considered to create an additional burden for
the CAs.
2.3.3. Training tasks VS FSTD
— Provide guidance on the use of each device qualification level in relation to training, testing and
checking;
— Determine the use of other FSTDs for complex high-performance single-pilot aeroplane type
rating training and checking, when no FFS qualified in accordance with CS-FSTD(A) exists for that
type or is not readily available, and propose amendments to the Aircrew Regulation, as
appropriate; in this context, the term ‘available’ also needs to be further considered and defined
(WP2).
One of the activities of WP1 is to provide guidance on the use of each FSTD for training based on its
qualification level, and specifically, to:
— identify the FSTD credits for each initial-training licence or rating for fixed-wing and rotary-wing
aircraft; and
— for each initial-training licence or rating, define the suitability of the FSTD for training in each
task as partial, complete or none; when the task is partial, the task’s proportion or elements that
can be credited should be specified.
This guidance is expected to assist training providers in defining the use of appropriate FSTDs to
support the training course syllabus, as well as CA inspectors in evaluating the training programme and
the appropriate use of FSTDs, thus improving standardisation of both crediting and training.19
The related changes will be introduced into AMC/GM to Part-FCL through a new AMC.
2.4. What are the expected benefits and drawbacks of the proposals
The expected benefits and drawbacks of the proposal are summarised below. For the full impact
assessment of alternative options, please refer to Chapter 4.
The expected benefits of updating the FSTD provisions and requirements to better support enhanced
approach-to-stall training, as well as of developing and deploying IOS feedback tools, are the following:
— safety improvement, by further mitigating LOC-I;
— full implementation of UPRT provisions;
— gains for the pilots, by receiving better and more accurate training in higher-fidelity FSTDs;
— gains for the instructors, by improving their ability to provide more accurate feedback during
UPRT; and
19
During the NPA public consultation, EASA expects comments from training providers which might lead to further amendments to
the proposed text.
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2. In summary — why and what
— a cost-efficient framework: the affected stakeholders will not incur significant costs.
The aim is to align CS-FSTD(A) as well as AMC/GM with FAA 14 CFR Part 60, Change 2 requirements and
to update both Part-FCL and Part-ARA as per the ToR for RMT.0196, Issue 1, providing the different
possibilities:
— for FSTD operators, to be optionally qualified for the post-stall regime to reduce the burden
posed by having dual-qualified FSTDs; and
— for training providers, to be optionally qualified for the post-stall regime to be able to deliver
training under the post-stall regime, if desired.
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3. Proposed amendments and rationale in detail
3. Proposed amendments and rationale in detail
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
— deleted text is struck through;
— new or amended text is highlighted in grey;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
3.1. Draft certification specifications (Draft EASA decision)
3.1.1. CS-FSTD(A) — Book 1
1. Appendix 1 to CS FSTD(A).300 is amended as follows:
Draft resulting text
APPENDICES
Appendix 1 to CS FSTD(A).300 Flight Simulation Training Device Standards
[…]
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3. Proposed amendments and rationale in detail
FLIGHT SIMULATION TRAINING FFS LEVEL FTD FNPT LEVEL BITD COMPLIANCE
DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
1. General
a.1 A fully enclosed flight deck.
a.2 A cockpit/flight deck
sufficiently enclosed to exclude
distraction, which will replicate
that of the aeroplane or class
of aeroplane simulated.
a.3 Flight deck, a full scale replica Flight deck observer seats are not considered to be
of the aeroplane simulated. additional flight crew member duty stations and may be
Equipment for operation of the omitted.
cockpit windows shall be Bulkheads containing items such as switches, circuit
included in the FSTD, but the breakers, supplementary radio panels, etc. to which the
actual windows need not be flight crew may require access during any event after
operable. preflight cockpit preparation is complete are considered
The flight deck, for FSTD essential and may not be omitted.
purposes, consists of all that Bulkheads containing only items such as landing gear pin
space forward of a cross storage compartments, fire axes or extinguishers, spare
section of the fuselage at the light bulbs, aircraftaeroplane document pouches etc. are
most extreme aft setting of the not considered essential and may be omitted. Such items,
pilots’ seats. Additional or reasonable facsimile, shall still be available in the FSTD
required flight crew member but may be relocated to a suitable location as near as
duty stations and those practical to the original position. Fire axes and any similar
required bulkheads aft of the purpose instruments need only be represented in
pilot seats are also considered silhouette.
part of the flight deck and shall
replicate the aeroplane.
a.4 Direction of movement of
controls and switches identical
to that in the aeroplane.
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FLIGHT SIMULATION TRAINING FFS LEVEL FTD FNPT LEVEL BITD COMPLIANCE
DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
a.5 A full size panel of replicated The use of electronically displayed images with physical
system(s) which will have overlay incorporating operable switches, knobs, buttons
actuation of controls and replicating aeroplane instruments panels may be
switches that replicate those of acceptable to the competent authority.
the aeroplane simulated.
a.6 Cockpit/flight deck switches, For Multi-Crew Cooperation (MCC) qualification
instruments, equipment, panels, additional instrumentation and indicators may be
systems, primary and secondary required. See table at start of this Appendix.
flight controls sufficient for the For BITDs the switches and controls size and shape and their
training events to be location in the cockpit shall be representative.
accomplished shall be located in
a spatially correct flight deck area
and will operate as, and
represent those in, that
aeroplane or class of
aeroplane.
a.7 Crew members’ seats shall be
provided with sufficient
adjustment to allow the
occupant to achieve the design
eye reference position
appropriate to the aeroplane
or class of aeroplane and for
the visual system to be
installed to align with that eye
position.
b.1 Circuit breakers that affect
procedures and/or result in
observable cockpit indications
properly located and
functionally accurate.
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FLIGHT SIMULATION TRAINING FFS LEVEL FTD FNPT LEVEL BITD COMPLIANCE
DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
c.1 Flight dynamics model that For FTD levels 1 and 2 aerodynamic modelling sufficient
accounts for various to permit accurate systems operation and indication is
combinations of drag and acceptable.
thrust normally encountered in For FNPTs and BITDs class-specific modelling is
flight corresponding to actual acceptable.
flight conditions, including the
effect of change in aeroplane
attitude, sideslip, thrust, drag,
altitude, temperature, gross
weight, moments of inertia,
centre of gravity location, and
configuration.
d.1 All relevant instrument For FNPTs instrument indications sufficient for the training
indications involved in the events to be accomplished. Reference AMC3 FSTD(A).300.
simulation of the applicable For BITDs instrument indications sufficient for the training
aeroplane shall automatically events to be accomplished. Reference AMC4 FSTD(A).300.
respond to control movement
by a flight crew member or
induced disturbance to the
simulated aeroplane; e.g.,
turbulence or wind shear.
d.2 Lighting environment for For FTD level 2 lighting environment shall be as per
panels and instruments shall be aeroplane.
sufficient for the operation
being conducted.
d.3 Instrument indications respond
appropriately to icing effects.
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DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
e.1 Communications, navigation, For FTD 1 applies where the appropriate systems are
and caution and warning replicated.
equipment corresponding to
that installed in the applicant’s
aeroplane with operation
within the tolerances
prescribed for the applicable
airborne equipment.
e.2 Navigation equipment
corresponding to that of the
replicated aeroplane or class of
aeroplanes, with operation within
the tolerances prescribed for the
actual airborne equipment. This
shall include communication
equipment (interphone and
air/ground communications
systems).
e.3 Navigational data with the For FTD 1 applies where navigation equipment is
corresponding approach replicated.
facilities. Navigation aids For all FFSs and FTDs 2 where used for area or airfield
should be usable within range competence training or checking, navigation data should
without restriction. be updated within 28 days.
For FNPTs and BITDs complete navigational data for at
least five different European airports with corresponding
precision and non-precision approach procedures
including current updating within a period of three
months.
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FLIGHT SIMULATION TRAINING FFS LEVEL FTD FNPT LEVEL BITD COMPLIANCE
DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
f.1 In addition to the flight crew For FTDs and FNPT’s suitable seating arrangements for
member duty stations, three the instructor and examiner or competent authority’s
suitable seats for the inspector should be provided.
instructor, delegated examiner For BITDs suitable viewing arrangements for the
and competent authority instructor shall be provided.
inspector. The competent
authority shall consider options
to this standard based on
unique cockpit configurations.
These seats shall provide
adequate vision to the pilot’s
panel and forward windows.
Observer seats need not
represent those found in the
aeroplane but in the case of
FSTDs fitted with a motion
system, the seats shall be
adequately secured to the floor
of the FSTD, fitted with positive
restraint devices and be of
sufficient integrity to safely
restrain the occupant during
any known or predicted motion
system excursion.
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FLIGHT SIMULATION TRAINING FFS LEVEL FTD FNPT LEVEL BITD COMPLIANCE
DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
g.1 FSTD systems shall simulate For FTD level 1, applies where system is simulated. For
applicable aeroplane system FNPTs systems shall be operative to the extent that it shall
operation, both on the ground be possible to perform all normal, abnormal and emergency
and in flight. Systems shall be operations as may be appropriate to the aeroplane or class
operative to the extent that all of aeroplanes being simulated and as required for the
normal, abnormal, and training.
emergency operating
procedures can be
accomplished.
g.2 For aeroplanes equipped with a A statement of compliance (SOC) is required verifying
stick pusher system, control that the stick pusher system has been modelled,
forces, displacement, and programmed, and validated using the aeroplane
surface position of the manufacturer’s design data or other acceptable data
aeroplane correspond to those source. The SOC must address, at a minimum, the stick
of the aeroplane being pusher activation and cancellation logic as well as system
simulated. dynamics, control displacement and forces as a result of
the stick pusher activation.
h.1 Instructor controls shall enable Where applicable and as required for training the
the operator to control all following shall be available:
required system variables and — position and flight freeze;
insert abnormal or emergency
conditions into the aeroplane — a facility to enable the dynamic plotting of the flight
systems. path on approaches, commencing at the final
approach fix, including the vertical profile;
— hard copy of map and approach plot.
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DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
h.2 The FSTD must have a real-time This feedback tool must include the following:
feedback tool to notify the (a) FSTD validation envelope: this must be in form of an
instructor/evaluator whenever alpha/beta envelope (or equivalent method)
the FSTD training envelope or depicting the ‘confidence level’ of the aerodynamic
aeroplane operating limits model,. This ‘confidence level’ depending on the
have been exceeded. degree of flight validation or on the source of
Additionally, and optionally, a predictive methods. There must be a minimum of a
recording mechanism may be flaps-up and flaps-down envelope available.
utilised. (b) Flight control inputs: These must enable the
instructor and examiner to assess the pilot’s flight
control displacements and forces (including fly-by-
wire, as appropriate).
(c) Aeroplane operational limits: this must display the
aeroplane operating limits during the manoeuvre as
applicable for the configuration of the aeroplane.
An SOC is required that defines the source data used to
construct the FSTD validation envelope.
Please refer to AMC11 FSTD(A).300.
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DEVICE STANDARDS LEVEL
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h.3 Upset scenarios: when An SOC is required, to confirm that each upset prevention
equipped with instructor and recovery feature programmed at the IOS and the
operating station (IOS) associated training manoeuvre have been evaluated by a
selectable dynamic aeroplane suitably qualified pilot.
upsets, the IOS is to provide Please refer to AMC9 FSTD(A).300(a)(1).
guidance on the method used
to drive the FSTD into an upset
condition, including any
malfunction or degradation of
the FSTD’s functionality,
required to initiate the upset.
The unrealistic degradation of
simulator functionality (such as
degrading flight control
effectiveness) to drive an
aeroplane upset is generally
not acceptable unless used
purely as a tool for
repositioning the FSTD with the
pilot out of the loop.
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DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
i.1 Control forces and control For FTD level 2 control forces and control travel should
travel shall correspond to that correspond to that of the replicated aeroplane with
of the replicated aeroplane. CT&M. It is not intended that the device should be flown
Control forces shall react in the manually other than for short periods when the autopilot
same manner as in the is temporarily disengaged.
aeroplane under the same For FNPT level I and BITDs control forces and control
flight conditions. travel shall broadly correspond to that of the replicated
aeroplane or class of aeroplane. Control force changes
due to an increase/decrease in aircraftaeroplane speed
are not necessary.
In addition, for FNPT level II and MCC control forces and
control travels shall respond in the same manner under
the same flight conditions as in the aeroplane or class of
aeroplane being simulated.
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DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
j.1 Ground handling and Statement of compliance required. Tests required.
aerodynamic programming For level ‘A’ FFS, generic ground handling to the extent
shall include: that allows turns within the confines of the runway,
(1) Ground Effect. For adequate control on flare, touchdown and roll-out
example: round-out, flare, (including from a crosswind landing) only is acceptable.
and touchdown. This For FNPTs a generic ground handling model need only be
requires data on lift, drag, provided to enable representative flare and touch down
pitching moment, trim, effects.
and power ground effect.
(2) Ground reaction –
reaction of the aeroplane
upon contact with the
runway during landing to
include strut deflections,
tyre friction, side forces,
and other appropriate
data, such as weight and
speed, necessary to
identify the flight
condition and
configuration.
(3) Ground handling
characteristics – steering
inputs to include
crosswind, braking, thrust
reversing, deceleration
and turning radius.
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DEVICE STANDARDS LEVEL
A B C D 1 2 I II MCC
k.1 Wind shear models shall Tests required.
provide training in the specific
skills required for recognition
SeePlease refer to AMC1 FSTD(A).300, (b)(3) 2.g.
of wind shear phenomena and
execution of recovery
manoeuvres. Such models shall
be representative of measured
or accident derived winds, but
may include simplifications
which ensure repeatable
encounters. For example,
models may consist of
independent variable winds in
multiple simultaneous
components. Wind models
shall be available for the
following critical phases of
flight:
(1) Prior to take-off rotation
(2) At lift-off
(3) During initial climb
(4) Short final approach
[…]
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s.1 Aerodynamic modelling shall Statement of compliance require, to:
be provided. This shall — include Mach effect, aeroelastic representations, and
includes, for aeroplanes issued non-linearities due to sideslip; are normally included
an original type certificate in the FSTD aerodynamic model. The statement of
after June 1980, low altitude Compliance shall address each of these items.
level flight ground effect, Mach
— include Sseparate tests for thrust effects; and a
effect at high altitude, normal
statement of compliance are required.
and reverse dynamic thrust
effect on control surfaces, — determine that the combination of angle of attack
aeroelastic representations, and sideslip does not exceed the range of
and representations of non- flight-test-validated data or wind tunnel/analytical
linearities due to sideslip based data while performing the upset recovery
on aeroplane flight test data manoeuvre.
provided by the manufacturer. Please refer to AMC9 FSTD(A).300(a)(2).
s.2 The aerodynamic model has to An SOC is required.
incorporate an angle of attack Please refer to AMC9 FSTD(A).300(a)(3).
and sideslip range to support
the training tasks.
s.3 Applicable only for those FSTDs An SOC is required which describes the aerodynamic-
that are to be qualified for modelling methods, validation, as well and check of the
aerodynamic-stall training stall characteristics of the FSTD. The SOC has also to
tasks. include a verification that the FSTD has been evaluated by
The aerodynamic modelling has a subject-matter expert pilot acceptable to the
to support stall-recovery competent authority.
training tasks in the following Please refer to AMC10 FSTD(A).300.
flight conditions: Please refer to AMC9 FSTD(A).300(a)(4).
(a) stall entry at wing level Please refer to AMC1 FSTD(A).200 for clarification of the
(1g); ‘near performance limited condition’.
(b) stall entry into turning
flight of at least 25° bank
angle (accelerated stall);
(c) stall entry into a power-on
condition (required only
for propeller-driven
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aeroplanes); and
(d) aeroplane configurations
of second-segment climb,
high-altitude cruise (‘near
performance limited
condition’), and approach
or landing.
t.1 Modelling that includes the Statement of compliance required.
effects of airframe and engine Icing models must simulate the aerodynamic degradation
icing, where appropriate, on effects of ice accretion on the aeroplane-lifting surfaces,
the airframe, aerodynamics, including loss of lift, decrease in stall angle of attack,
and the engine(s). change in pitching moment, decrease in control
Icing-effects simulation models effectiveness, and changes in control forces in addition to
are only required for any overall increase in drag. Aeroplane systems (such as
aeroplanes authorised for the stall protection system and auto flight system (must
operation in icing conditions. respond properly to ice accretion, consistent with the
simulated aeroplane.
Aeroplane original-equipment manufacturer (OEM) data
or other acceptable analytical methods must be used to
develop ice accretion models. Acceptable analytical
methods may include wind tunnel analysis and/or
engineering analysis of the aerodynamic effects of icing
on the aeroplane-lifting surfaces coupled with tuning and
supplemental subjective assessment by a subject-matter
expert pilot.
An SOC is required shall describeing the effects that
provide training in the specific skills required for
recognition of icing phenomena and execution of
recovery. The SOC must describe the source data and any
analytical methods used to develop ice accretion models,
including a verification that these effects have been
tested.
Please refer to AMC12 FSTD(A).300.
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t.2 Modelling that includes the An SOC is required describing the effects that provide
effects of airframe and engine training in the specific skills for recognition of icing
icing. phenomena and execution of recovery.
Icing-effects simulation models
are only required for those
aeroplanes authorised for
operations in icing conditions.
[…]
2. Motion system
a.1 Motion cues as perceived by For FSTDs where motion systems are not specifically
the pilot shall be required, but have been added, they will be assessed to
representative of the ensure that they do not adversely affect the qualification
aeroplane, e.g. touchdown of the FSTD.
cues shall be a function of the Special consideration is given to the motion system response
simulated rate of descent. during upset prevention and recovery manoeuvres.
Notwithstanding the limitations of simulator motion, specific
emphasis has to be placed on tuning out objectionable
motion system responses.
b.1 A motion system shall: Statement of compliance required.
(1) provide sufficient cueing, Tests required.
which may be of a generic
nature to accomplish the
required tasks;
(2) have a minimum of 3
degrees of freedom (pitch,
roll & heave); and
(3) produce cues at least
equivalent to those of a
six-degrees-of-freedom
synergistic platform
motion system.
c.1 A means of recording the
motion response time as
required.
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d.1 Motion effects programming For level ‘A’ FFS: effects may be of a generic nature
shall include: sufficient to accomplish the required tasks.
(1) effects of runway rumble, If there are known flight conditions where buffet is the first
oleo deflections, indication of the stall, or where no stall buffet occurs, this
groundspeed, uneven characteristic should be included in the model.
runway, centreline lights
and taxiway
characteristics;
(2) buffets on the ground due
to spoiler/speedbrake
extension and thrust
reversal;
(3) bumps associated with the
landing gear;
(4) buffet during extension
and retraction of landing
gear;
(5) buffet in the air due to
flap and
spoiler/speedbrake
extension;
(6) approach to stall buffet
and stall buffet (where
applicable);
(7) touchdown cues for main
and nose gear;
(8) nose wheel scuffing;
(9) thrust effect with brakes
set;
(10) Mach and manoeuvre
buffet;
(11) tyre failure dynamics;
(12) engine malfunction and
engine damage; and
(13) tail and pod strike.
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[…]
4. Sound System
a.1 Significant flight deck sounds For FNPT level I and BITD engine sounds only need to be
which result from pilot actions available.
corresponding to those of the
aeroplane or class of
aeroplane.
b.1 Sound of precipitation, rain A Sstatement of compliance is required.
removal equipment and other Sounds have to be directionally representative.
significant aeroplane noises
For FSTDs qualified for full-stall training tasks, sounds
perceptible to the pilot during
associated with stall buffet have to be replicated, if
normal and abnormal
significant in the aeroplane.
operations and the sound of a
crash when the FSTD is landed
in excess of limitations.
c.1 Comparable amplitude and Tests required.
frequency of flight deck noises,
including engine and airframe
sounds. The sounds shall be
coordinated with the required
weather.
d.1 The volume control shall have
an indication of sound level
setting which meets all
qualification requirements.
Rationale
The FSTD provisions are updated for qualifying FSTDs Level C and D, by addressing the following:
— enhancement of stall characteristics (for those FSTDs to be qualified for aerodynamic-stall training tasks);
— aerodynamic modelling;
— UPRT (upset scenarios and IOS requirements);
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— icing effects; and
— motion cues and effects.
The proposed amendments to CS-FSTD(A) (Book 1) aim at aligning with the current regulatory text from FAA 14 CFR Part 60, Change 2.
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3.1.2. CS-FSTD(A) — Book 2
1. AMC1 FSTD(A).200 is amended as follows:
Draft resulting text
SUBPART B — TERMINOLOGY
AMC1 FSTD(A).200 Terminology and abbreviations
(a) Terminology
In addition to the principal terms defined in the requirement itself, additional terms used in the
context of CS-FSTD(A) and CS-FSTD(H) have the following meanings:
[…]
— ‘FSTD training envelope’ means high- and moderate-confidence regions of the FSTD
validation envelope.
[…]
— ‘High angle of attack’ means flying at an angle higher than in normal operation beyond the
first indication of stall or stall protection systems, whichever occurs first.
[…]
— ‘Near performance limited condition’ (when related to approach to stall or stall) means a
stall event occurring close to the lowest limit of the following:
maximum certified altitude (structural);
thrust-limited altitude; and
buffet- or manoeuvre-limited altitude.
Stall data above flight level (FL) 250 should generally be acceptable.
[…]
(b) Abbreviations
[…]
EVS = enhanced vision system
[…]
FMS = flight management system
[…]
GNSS = global navigation satellite system
[…]
HUGS = head-up guidance system
[…]
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MMO = maximum operating Mach
[…]
PBN = performance-based navigation
[…]
VMO = maximum operating limit airspeed
Rationale
This AMC has been updated to introduce definition of terms and abbreviations associated with UPRT,
high angle of attack, and stall.
2. AMC1 FSTD(A).300 is amended as follows:
Draft resulting text
SUBPART C — AEROPLANE FLIGHT SIMULATION TRAINING DEVICES
AMC1 FSTD(A).300 Qualification basis
(a) Introduction
(1) Purpose
[…]
(2) Background
(i) The availability of advanced technology has permitted greater use of FSTDs for
training, testing and checking of flight crew members. The complexity, costs and
operating environment of modern aeroplane also encourage broader use of advanced
simulation. FSTDs can provide more in-depth training than can be accomplished in
aeroplane and provide a safe and suitable learning environment. Fidelity of modern
FSTDs is sufficient to permit pilot assessment with the assurance that the observed
behaviour will transfer to the aeroplane. Fuel conservation and reduction in adverse
environmental effects are important by-products of FSTD use.
(ii) The methods, procedures, and testing criteria contained in this AMC are the result of
the experience and expertise of competent authorities, operators, and aeroplane and
FSTD manufacturers. From 1989 to 1992 a specially convened international working
group under the sponsorship of the Royal Aeronautical Society (RAeS) held several
meetings with the stated purpose of establishing common test criteria that would be
recognised internationally. The final RAeS document, entitled International Standards
for the Qualification of Airplane Flight Simulators, dated January 1992 (ISBN 0–
903409–98–4), was the core document used to establish these criteria and also the
ICAO Doc 9625 Manual of Criteria for the Qualification of Flight Simulators (1995 or as
amended). An international review under the co-chair of FAA and JAA during 2001
was the basis for a major modification of the ICAO Manual and for this CS.
[…]
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Table of FSTD Validation Tests
FLIGHT
TESTS TOLERANCE FSTD LEVEL COMMENTS
CONDITIONS
FFS FTD FNPT BITD
A B C D Init Rec I II MCC
For FNPT and BITD CT&M
should be used for initial
evaluations. The tolerances
should be applied for recurrent
evaluations (see
AMC1 FSTD(A).300 (a)(5)(iv)).
It is accepted that tests and
associated tolerances only
apply to a level 1 FTD if that
system or flight condition is
simulated.
1. PERFORMANCE
[…]
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2. HANDLING QUALITIES
a. STATIC CONTROL NOTE: Pitch, roll and yaw
CHECKS controller position vs. force
or time should be measured
at the control. An alternative
method is to instrument the
FSTD in an equivalent
manner to the flight test
aeroplane. The force and
position data from this
instrumentation should be
directly recorded and
matched to the aeroplane
data. Such a permanent
installation could be used
without any time for
installation of external
devices.
CCA: Testing of position
versus force is not applicable
if forces are generated solely
by use of aeroplane
hardware in the FSTD.
(1) Pitch controller ± 0.9 daN (2 lbs) Ground C Uninterrupted control sweep
position vs. breakout. T to stops. Should be validated
force and & (where possible) with inflight
± 2.2 daN (5 lbs) or ±
surface position M data from tests such as
10% force.
calibration. longitudinal static stability,
± 2º elevator angle stalls, etc.
Static and dynamic flight
control tests should be
accomplished at the same
feel or impact pressures.
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Column position ± 2.2 daN (5 lbs) Cruise or FNPT 1 and BITD: control
vs. force only. or ± 10% force. approach forces and travel should
broadly correspond to that of
the replicated class of
aeroplane.
[…]
(10) Stick pusher ± 10 % or ± 5 lb Ground or This test is intended to
system force (2.2 daN) flight validate the stick/column
calibration (if stick/column transient force resulting from
applicable) transient force a stick pusher system
activation.
This test may be conducted
in an on-ground condition
through stimulation of the
stall protection system in a
manner that generates a
stick pusher response
representative of an in-flight
condition.
Aeroplane manufacturer
design data may be utilised
as validation data, if
acceptable to the competent
authority.
The test provisions may be
met through column force
validation testing in
conjunction with the stall
characteristics test
(please refer to
AMC1 FSTD(A).300(2)(c)(8)).
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b. DYNAMIC Tests 2.b(1), 2.b(2), and
CONTROL CHECKS 2.b(3) are not applicable if
dynamic response is
generated solely by use of
aeroplane hardware in the
flight simulator. Power
setting may be that required
for level flight unless
otherwise specified.
(1) Pitch control. For underdamped Take-off, Data should be for normal
systems: cruise, and control displacements in
± 10% of time from landing both directions
90% of initial (approximately 25% to 50%
displacement (A d) to full throw or approximately
first zero crossing 25% to 50% of maximum
and allowable pitch controller
± 10(n+1)% of deflection for flight
period thereafter conditions limited by the
± 10% amplitude of manoeuvring load envelope).
first overshoot Tolerances apply against the
applied to all absolute values of each
overshoots greater period (considered
than 5% of initial independently).
displacement (A d). n = The sequential period of
± 1 overshoot (first a full oscillation.
significant Please rRefer to
overshoot should be AMC1 FSTD(A).300(b)(4)(i).
matched)
For overdamped
systems:
± 10% of time from
90% of initial
displacement (A d) to
10 % of initial
displacement (0·1
Ad).
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(2) Roll control. For underdamped Take-off, Data should be for normal
systems: cruise, and control displacement
± 10% of time from landing (approximately 25% to 50%
90% of initial of full throw or
displacement (A d) to approximately 25% to 50% of
first zero crossing maximum allowable roll
and controller deflection for
± 10(n+1)% of flight conditions limited by
period thereafter. the manoeuvring load
envelope).
± 10% amplitude of
first overshoot Please rRefer to
applied to all AMC1 FSTD(A).300(b)(4)(i).
overshoots greater
than 5% of initial
displacement (A d).
± 1 overshoot (first
significant
overshoot should be
matched)
For overdamped
systems:
± 10% of time from
90% of initial dis-
placement (A d) to
10 % of initial dis-
placement (0·1 A d).
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(3) Yaw control. For underdamped Take-off, Data should be for normal
systems: cruise, and displacement (approximately
± 10% of time from landing 25% to 50% of full throw).
90% of initial Please rRefer to
displacement (A d) to AMC1 FSTD(A).300(b)(4)(i).
first zero crossing
and
± 10(n+1)% of
period thereafter.
± 10% amplitude of
first overshoot
applied to all
overshoots greater
than 5% of initial
displacement (A d).
± 1 overshoot (first
significant
overshoot should be
matched)
For overdamped
systems:
± 10% of time from
90% of initial
displacement (A d) to
10 % of initial
displacement (0·1
Ad).
[…]
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c. LONGITUDINAL Power setting may be that
required for level flight
unless otherwise specified.
(1) Power change ± 3 kts airspeed Approach Power change from thrust for
dynamics. ± 30 m (100 ft) C approach or level flight to
altitude. T maximum continuous or go-
± 1.5º or ± 20% & around power. Time history
pitch angle M of uncontrolled free
response for a time
increment equal to at least 5
s before initiation of the
power change to completion
of the power change
+ 15 s.
CCA: Test in normal AND
non-normal control state.
Power change ± 2.2 daN (5 lbs) Approach For an FNPT I and a BITD the
force or ± 10% Force power change force test only
is acceptable.
[…]
(8a) Stall ± 3 kts airspeed for 2nd segment Wings-level 1 g stall entry
characteristics. initial buffet, stall climb, high with thrust at or near idle
warning, and stall altitude power. Time history data
speeds. cruise (near should be shown to include
For aeroplanes with performance full stall and initiation of
reversible flight limited recovery. Stall warning signal
control systems (for condition) should be recorded and
FS only): and approach should occur in the proper
or landing relation to stall. FSTDs for
± 10% or ± 2·2 daN
aeroplanes exhibiting a
(5 lb) column force
sudden pitch attitude change
(prior to g-break
or ‘g break’ should
only.)
demonstrate this
± 3 kt airspeed for
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stall warning and characteristic.
stall speeds. CCA: Test in normal AND
±2° angle of attack non-normal control state.
for the buffet FNPT and BITD: Test should
threshold of determine the actuation of
perception and for the stall warning device only.
the initial buffet
Please refer to
based upon the Nz
AMC9 FSTD(A).300(b)(1).
component.
CCA: test in normal and
Approach to stall:
non-normal control states.
±2.0° pitch angle;
In normal state, it is expected
±2.0° angle of that envelope protections
attack; and will take effect, and it may
±2.0° bank angle not be possible to reach the
Stall warning up to aerodynamic-stall condition.
stall: In these circumstances, it is
adequate to complete the
±2.0° pitch angle;
test until the envelope
±2.0° angle of protection is cancelled.
attack; and
In non-normal state, it is
correct trend and necessary to perform the test
magnitude for roll to the aerodynamic stall. It is
rate and yaw rate understood that flight test
Stall break and data may not be available
recovery: see and in this circumstance,
AMC10 FSTD(A).300 engineering validation data
Additionally, for may be used and the extent
those simulators of the test should be
with reversible flight adequate to allow training
control systems or through to recovery, in
equipped with stick accordance with the training
pusher systems: objectives. For safety of flight
considerations, the flight test
± 10% or ± 2·2 daN
data may be limited to the
(5 lb) stick/column
stall angle of attack, and the
force (prior to the
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stall angle of modelling beyond the stall
attack). angle of attack is limited to
continuity and completion of
recovery.
(8b) Approach-to-stall ±3 kt airspeed for 2nd segment Please refer to
characteristics stall-warning climb, high AMC9 FSTD(A).300(b)(2).
speeds. altitude CCA: test in normal and
±2.0° angle of attack cruise (near non-normal control states.
for initial buffet: performance
limited
±2.0° pitch angle;
condition)
±2.0° angle of and approach
attack; and or landing
±2.0° bank angle.
Additionally, for
those aeroplanes
with reversible flight
control systems:
±10 % or ±5 lb
(2.2 daN))
stick/column force.
(9) Phugoid ± 10% period. Cruise Test should include three full
dynamics. ± 10% time to ½ or cycles or that necessary to
double amplitude determine time to ½ or
double amplitude, whichever
or
is less.
± 0.02 of damping CCA: Test in non-normal
ratio. control state.
± 10% Period with Cruise Test should include at least
representative three full cycles.
damping Time history recommended.
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(10) Short period ± 1.5º pitch angle or Cruise CCA: Test in normal AND
dynamics. non-normal control state.
± 2º/s pitch rate.
± 0.1 g normal
acceleration.
d. LATERAL Power setting may be that
DIRECTIONAL required for level flight
unless otherwise specified.
(1) Minimum ± 3 kts airspeed Take-off or Minimum speed may be
control speed, landing C C defined by a performance or
air (VMCA or (whichever is T T control limit which prevents
VMCL), per most critical & & demonstration of VMC or VMCL
applicable in the M M in the conventional manner.
airworthiness aeroplane) Take-off thrust should be set
standard – or – on the operating engine(s).
Low speed Time history or snapshot
engine inoper- data may be used.
ative handling CCA: Test in normal OR non-
characteristics normal control state.
in the air.
FNPT and BITD: It is important
that there exists a realistic
speed relationship between
Vmca and Vs for all
configurations and in particular
the most critical full-power
engine-out take-off
configurations.
[…]
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(8) Steady state For a given rudder Approach or May be a series of snapshot
sideslip. position: landing tests using at least two
± 2º bank angle rudder positions (in each
direction for propeller driven
± 1º sideslip angle
aeroplanes) one of which
± 10% or should be near maximum
± 2º aileron allowable rudder.
± 10% or For FNPT and BITD a roll
± 5º spoiler or controller position tolerance
equivalent roll of ± 10% or ± 5º applies
controller position instead of the aileron
or force tolerance.
For FFSs For a BITD the force
representing tolerance should be CT&M.
aircraftaeroplane
with reversible flight
control systems:
±10% or ±1·3 daN (3
lb) wheel force
±10% or ±2·2 daN (5
lb) rudder pedal
force.
[…]
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f. GROUND EFFECT
(1) A Test to ± 1º elevator Landing Please rRefer to
demonstrate ± 0·5º stabilizer AMC1 FSTD(A).300(b)(4)(ii). A
ground effect. angle. rationale should be provided
with justification of results.
± 5% net thrust or
equivalent. CCA: Test in normal OR non-
normal control state.
± 1º AOA
± 1.5 m (5 ft) or
± 10% height
± 3 kts airspeed
± 1º pitch angle
[…]
i. ENGINE AND
AIRFRAME ICING
EFFECTS
(1) Engine and ± 3 kt airspeed. Take-off or Please refer to
airframe icing ± 0.5 m/s (100 ft/ approach or AMC9 FSTD(A).300(b)(3).
effects min) or ±5 % rate landing
Demonstration of climb, but not (one flight
(high angle of less than condition, two
attack) aeroplane tests: ice on and
performance ice off)
data.
3. MOTION SYSTEM
a. Frequency As specified by n/a Appropriate test to
response the applicant for demonstrate frequency
FFS qualification. response required. See also
AMC1 FSTD(A).300 (b)(4)(iii)(B)
[…]
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g. Characteristic None Ground and The recorded test results for
motion flight characteristic buffets should
vibrations allow the comparison of
relative amplitude versus
frequency.
For atmospheric disturbance
testing, general purpose
disturbance models that
approximate demonstrable
flight test data are acceptable.
Principally, the flight simulator
results should exhibit the
overall appearance and trends
of the aeroplane plots, with at
least some of the frequency
“spikes” being present within 1
or 2 Hz of the aeroplane data.
See AMC1 FSTD(A).300
(b)(4)(iii)(E).
The following tests
with recorded
results and an SOC
are required for
characteristic
motion vibrations,
which can be sensed
at the flight deck
where applicable by
aeroplane type:
(1) Thrust effects n/a Ground Test should be conducted at
with brakes set maximum possible thrust with
brakes set.
[…]
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(6) Stall buffet n/a Cruise (high Test required only for FSTDs
altitude), qualified for full stall training
second-segment tasks or for those aeroplanes
climb, and which exhibit stall buffet
approach or before the activation of the
landing. stall-warning system.
Tests must be conducted for
an angle of attack range
between the buffet threshold
of perception to the pilot and
the stall angle of attack.
Post-stall characteristics are
not required.
If stabilised flight data
between buffet threshold of
perception and stall angle of
attack are not available, PSD
analysis should be conducted
for a time span between initial
buffet and stall angle of attack.
(67) High speed or n/a Flight Test condition should be for
Mach buffet high speed manoeuvre
buffet/wind-up-turn or
alternatively Mach buffet.
(78) In-flight n/a Flight (clean Test should be conducted to
vibrations configuration) be representative of in-flight
vibrations for propeller driven
aeroplanes.
[…]
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Rationale
This ‘Table of FSTD Validation Tests’ is proposed to be updated to incorporate acceptable means to comply with objective provisions relating to stick
pusher, stall, approach-to-stall characteristics, engine and airframe icing effects, and stall buffet.
Draft rule text
Functions and subjective tests
TABLE OF FUNCTIONS AND SUBJECTIVE TESTS FFS FTD FNPT BITD
A B C D 1 2 I II MCC
a PREPARATION FOR FLIGHT
(1) Preflight. Accomplish a functions
check of all switches, indicators,
systems, and equipment at all crew
members’ and instructors’ stations
and determine that:
(a) the flight deck design and
functions are identical to that of the
aeroplane or class of aeroplane
simulated
(b) design and functions
represent those of the simulated
class of aeroplane
[…]
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f MANOEUVRES
(1)(a) High angle of attack, approach to
stalls, stall warning, and stall buffet,
(and g-break if applicable)(take-off,
cruise, approach, and landing
configuration) including reaction of
the autoflight system and stall
protection system
(1)(b) High angle of attack, approach to
stalls, stall warning, stall buffet and
stall (take-off, cruise, approach, and
landing configuration) including
reaction of the autoflight system and
stall protection system
(1)(c) Upset prevention and recovery
manoeuvre within the FSTD
validation envelope
(2) Flight envelope protection (high
angle of attack, bank limit,
overspeed, etc.)
(3) Turns with/without
speedbrake/spoilers deployed
(4) Normal and standard rate turns
(5) Steep turns
(6) Performance turn
(7) In-flight engine shutdown and
restart (assisted and windmill)
(8) Manoeuvring with one or more (2) (2)
engines inoperative, as appropriate
(9) Specific flight characteristics (e.g.
direct lift control)
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(10) Flight control system failures,
reconfiguration modes, manual
reversion and associated handling
(11) Other
[…]
n MOTION EFFECTS
[…]
(5) Buffet in the air due to flap and *
spoiler/speedbrake extension
and approach to stall buffett
(a) First perform an approach and
extend the flaps and slats,
especially with airspeeds
deliberately in excess of the
normal approach speeds. In
cruise configuration verify the
buffets associated with the
spoiler/speedbrake extension.
The above effects could also be
verified with different
combinations of
speedbrake/flap/gear settings
to assess the interaction
effects
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(6) Approach to stall buffet and stall
buffet (where applicable)
(a) Conduct an approach-to-stall
with engines at idle and a
deceleration of 1 kt/s. Check
that the motion cues of the
buffet, including the level of
buffet increase with decreasing
speed, are reasonably
representative of the actual
aeroplane
Note: For FSTDs qualified for full-stall
training tasks, modelling that
accounts for any increase in
buffet amplitude from the initial
buffet threshold of perception
to the critical angle of attack or
deterrent buffet as a function of
the angle of attack; the stall
buffet modelling should include
effects of Nz, as well as Nx and
Ny, if relevant.
[…]
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p SPECIAL EFFECTS
[…]
(2) Effects of Airframe and Engine Icing
(a) See Appendix 1 to
CS FSTD(A).300 1.t.1
Required only for those
aeroplanes authorised for
operations in known icing
conditions.
With the FSTD airborne,
autopilot on and auto-throttles
off, engine and aerofoil
anti-ice/de-ice systems
deactivated; activate icing
conditions at a rate that allows
monitoring of the FSTD and
systems’ response. Icing
recognition typically includes
airspeed decay, change in FSTD
pitch attitude, change in engine
performance indications (other
than due to airspeed changes),
and change in data from the
pitot/static system. Activate
heating, anti-ice, or de-ice
systems independently.
Recognition includes proper
effects of these systems,
eventually returning the
simulated aeroplane to normal
flight.
Please refer to
AMC12 FSTD(A).300.
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NOTE: For level ‘A’, an asterisk (*) denotes
that the appropriate effect is required to be
present.
NOTE: It is accepted that tests will only
apply to FTD level 1 if that system and flight
condition is simulated. It is intended that the
tests listed below should be conducted in
automatic flight. Where automatic flight is
not possible and pilot manual handling is
required, the FTD should be at least
controllable to permit the conduct of the
flight.
[…]
Rationale
This ‘Functions and subjective tests’ table is proposed to be updated to incorporate acceptable means to comply with functions and
subjective test provisions relating to high angle of attack, approach to stall, upset prevention and recovery manoeuvres within the FSTD
validation envelope, approach-to-stall buffet, stall buffet (where applicable), as well as effects of airframe and engine icing.
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3. Appendix 8 to AMC1 FSTD(A).300 is amended as follows:
Draft resulting text
Appendix 8 to AMC1 FSTD(A).300 General technical requirements for FSTD qualification levels
This appendix summarises the general technical requirements for full flight simulators level A, B, C
and D, flight training devices level 1 and 2, flight navigation procedures trainers level I, II and
IIMCC, and basic instrument training devices.
Table 1: General technical requirements for level A, B, C and D full flight simulators (FFS)
Qualification
General technical requirements
Level
A The lowest level of FFS technical complexity.
An enclosed full-scale replica of the aeroplane cockpit/flight deck including
simulation of all systems, instruments, navigational equipment, communications and
caution and warning systems.
An instructor’s station with seat should be provided. Seats for the flight crew
members and two seats for inspectors/observers should also be provided.
Control forces and displacement characteristics should correspond to that of the
replicated aeroplane and they should respond in the same manner as the aeroplane
under the same flight conditions.
The use of class specific data tailored to the specific aeroplane type with fidelity
sufficient to meet the objective tests, functions and subjective tests is allowed.
Generic ground effect and ground handling models are permitted.
Motion, visual and sound systems sufficient to support the training, testing and
checking credits sought are required.
The visual system should provide at least 45 degrees horizontal and 30 degrees
vertical field of view per pilot.
The response to control inputs should not be greater than 300 ms more than that
experienced on the aircraftaeroplane.
B As for level A plus:
Validation flight test data should be used as the basis for flight and performance and
systems characteristics.
Additionally ground handling and aerodynamics programming to include ground
effect reaction and handling characteristics should be derived from validation flight
test data.
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C The second highest level of FFS fidelity.
As for level B plus:
A daylight/twilight/night visual system is required with a continuous, cross-cockpit,
minimum collimated visual field of view providing each pilot with 180 degrees
horizontal and 40 degrees vertical field of view.
A six-degrees-of-freedom motion system should be provided.
The sound simulation should include the sounds of precipitation and other
significant aeroplane noises perceptible to the pilot and should be able to reproduce
the sounds of a crash landing.
The response to control inputs should not be greater than 150 ms more than that
experienced on the airplane.
Windshear simulation should be provided.
An upset prevention and recovery training (UPRT) instructor operating station (IOS)
feedback mechanism should be available.
D The highest level of FFS fidelity.
As for level C plus:
Extended set of sound and motion buffet tests.
[…]
Rationale
This Appendix proposes to add the provision on the UPRT instructor operating station (IOS)
feedback mechanism for Level C and D FSTDs in order to enable those FSTDs to support UPRT.
4. New AMC9 FSTD(A).300 is inserted as follows:
Draft resulting text
AMC9 FSTD(A).300 Guidance on upset, stall (including in icing conditions), and qualification of
FSTDs
(a) Flight Simulation Training Device Standards table of Appendix 1 to CS FSTD(A).300
(1) 1. General, h.3:
(i) a suitably qualified pilot should:
(A) hold a type rating qualification for the aeroplane being simulated;
(B) have first-hand experience in recovering upset situations on a real aeroplane;
and
(C) be familiar with the upset scenarios and associated recovery methods as well
as the cues necessary to accomplish the required training objectives;
(ii) the statement of compliance (SOC) should also confirm that for each upset scenario,
the recovery manoeuvre can be performed such that the FSTD does not exceed the
FSTD validation envelope, or when the envelope is exceeded, that the FSTD is within
the realms of confidence in the simulation accuracy;
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(iii) the unrealistic degradation of the FSTD functionality (such as degrading flight
control effectiveness) to drive an aeroplane upset is not acceptable unless used
purely as a tool for repositioning the FSTD with the pilot out of the loop; and
(iv) consideration should be given to flight-envelope-protected aeroplanes as artificially
positioning the aeroplane to a specified attitude may incorrectly initialise flight
control laws.
(2) 1. General, s.1:
(i) the FSTD should be evaluated for specific upset recovery manoeuvres; a minimum
set of manoeuvres:
(A) a nose-high wings level aeroplane upset;
(B) a nose-low aeroplane upset; and
(C) a high bank-angle aeroplane upset;
(ii) other upset recovery scenarios, as developed by the FSTD operator, should be
evaluated in the same manner; and
(iii) these evaluations should be made available to the instructor/evaluator.
(3) 1. General, s.2:
(i) for continuity purposes, the model should remain contiguous beyond the FSTD
training envelope to the extent to allow completion of the recovery training; and
(ii) where known limitations exist in the aerodynamic model for particular stall event
manoeuvres (such as aeroplane configuration, approach-to-stall entry methods, and
limited range for continuity of the modelling), these limitations should be declared
in the required SOC.
(4) 1. General, s.3:
(i) the aerodynamic-stall modelling should include degradation of the static/dynamic
lateral directional stability;
(ii) degradation in control response (pitch, roll, and yaw), uncommanded roll response
or roll-off requiring significant control deflection to counter;
(iii) apparent randomness or non-repeatability;
(iv) changes in pitch stability;
(v) Mach effects; and
(vi) stall buffet,
as appropriate to the aeroplane type;
(A) the model should be capable of capturing the variations seen in the stall
characteristics of the aeroplane (e.g. the presence or absence of a pitch
break, deterrent buffet, or other indications of a stall where present on the
aeroplane);
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(B) where known limitations exist in the aerodynamic model for particular stall
manoeuvres (such as aeroplane configuration and stall-entry methods), these
limitations must be declared in the required SOC;
(C) specific guidance should be available to the instructor which clearly
communicates the flight configurations and stall manoeuvres that have been
evaluated in the FSTD for use in training; and
(D) FSTDs qualified for full-stall training tasks must also meet the instructor
operating station (lOS) provisions for upset prevention and recovery training
(UPRT) tasks as described under 1. General, h.2 of the FSTD standards table.
(b) FSTD validation tests
(1) Stall characteristics test:
(i) Control inputs must be plotted and demonstrate correct trend and magnitude.
(ii) Each of the following stall entries must be demonstrated in at least one of the
three flight conditions:
(A) stall entry at wings level (1 g);
(B) stall entry in turning flight of at least 25° bank angle (accelerated stall); and
(C) stall entry in a power-on condition (required only for propeller-driven
aeroplanes).
(iii) The cruise flight condition must be conducted in a flaps-up (clean) configuration.
The second-segment climb flight condition must use a different flap setting than
for the approach or landing flight condition.
(iv) The stall warning signal and initial buffet, if applicable, must be recorded. Time
history data must be recorded for a full stall through recovery to normal flight.
The stall warning signal must occur in the proper relation to buffet/stall. FSTDs of
aeroplanes exhibiting a sudden pitch attitude change or ‘g break’ must
demonstrate this characteristic. FSTDs of aeroplanes exhibiting a roll-off or
loss-of-roll control authority must demonstrate this characteristic.
(v) Numerical tolerances are not applicable past the stall angle of attack, but must
demonstrate correct trend through recovery. Please refer to AMC10 FSTD(A).300
for additional information concerning data sources and required angle-of-attack
ranges.
(vi) For aeroplanes with stall envelope protection systems, the normal-mode testing is
only required at an angle-of-attack range necessary to demonstrate the correct
operation of the system. These tests may be used to satisfy the required (angle of
attack) flight manoeuvre and envelope protection tests of AMC1 FSTD(A).300.
Non-normal control states must be tested through stall identification and
recovery.
(vii) In instances where flight test validation data is limited due to safety-of-flight
considerations, engineering simulator validation data may be used in lieu of flight
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test validation data for angles of attack that exceed the activation of a stall
protection system or stick pusher system.
(viii) Buffet threshold of perception should be based on 0.03 g peak to peak normal
acceleration above the background noise at the pilot seat. Initial buffet to be
based on normal acceleration at the pilot seat with a larger peak to peak value
relative to buffet threshold of perception (some airframe manufacturers have
used 0.1 g peak to peak). Demonstrate correct trend in growth of buffet
amplitude from initial buffet to stall speed for normal and lateral acceleration.
(ix) The maximum buffet may be limited based on motion platform
capability/limitations or other simulator system limitations.
(x) Tests may be conducted at centres of gravity and weights typically required for
aeroplane certification stall testing.
(xii) This test is only for FSTDs qualified to conduct full-stall training tasks.
(xiii) Where approved engineering simulation validation is used, the reduced
engineering tolerances (as defined in Appendix 1 to AMC1.300(b)) do not apply.
(2) Approach-to-stall characteristics test:
(i) Control displacements and flight control surfaces must be plotted and
demonstrate correct trend and magnitude.
(ii) Each of the following stall entries must be demonstrated in at least one of the
three flight conditions:
(A) approach to stall entry at wings level (1 g);
(B) approach to stall entry in turning flight of at least 25° bank angle
(accelerated stall); and
(C) approach to stall entry in a power-on condition (required only for
propeller-driven aeroplanes).
(iii) The cruise flight condition must be conducted in a flaps-up (clean) configuration.
The second-segment climb flight condition must use a different flap setting than
for the approach or landing flight condition.
(iv) For computer-controlled aeroplanes (CCAs) with stall envelope protection
systems, the normal-mode testing is only required at an angle-of-attack range
necessary to demonstrate the correct operation of the system. These tests may be
used to satisfy the required (angle of attack) flight manoeuvre and envelope
protection tests of AMC1 FSTD(A).300(2)(h).
(3) Engine and airframe icing effects demonstration (high angle of attack):
(i) Time history of a full stall and of the initiation of the recovery: tests are intended to
demonstrate representative aerodynamic effects caused by in-flight ice accretion.
Flight test validation data is not required.
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(ii) Two tests are required, to demonstrate engine and airframe icing effects. One test
demonstrates the FSTDs baseline performance without ice accretion, and the second
test demonstrates the aerodynamic effects of ice accretion relative to the baseline
test.
(iii) The test must utilise the icing model(s) as described in the SOC required in Appendix 1
to CS FSTD(A).300 1.t.1. The test must include a rationale that describes the icing
effects being demonstrated. Icing effects may include, but are not limited to, the
following effects, as applicable to the particular aeroplane type:
(A) decrease in the stall angle of attack;
(B) changes in the pitching moment;
(C) decrease in control effectiveness;
(D) changes in control forces;
(E) increase in drag;
(F) change in stall buffet characteristics and threshold of perception; and
(G) engine effects (power reduction/variation, vibration, etc. where expected to be
present on the aeroplane in the ice accretion scenario being tested).
(iv) Tests are evaluated for representative effects on relevant aerodynamic and other
parameters, such as angle of attack, control inputs, and thrust/power settings.
Recorded parameters (in the validation test result) should include the following:
(A) altitude;
(B) airspeed;
(C) normal acceleration;
(D) engine power;
(E) angle of attack;
(F) pitch attitude;
(G) bank angle;
(H) flight control inputs; and
(I) stall warning and stall buffet onset.
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5. New AMC10 FSTD(A).300 is inserted as follows:
Draft resulting text
AMC10 FSTD(A).300 Guidance on high-angle-of-attack/stall model evaluation
(a) This AMC applies to all FSTDs used to satisfy training provisions for stall manoeuvres conducted
at angles of attack beyond the activation of the stall-warning system. This AMC is not applicable
to FSTDs only qualified for approach-to-stall manoeuvres where recovery is initiated at the first
indication of the stall. This AMC supplements the following:
(1) Appendix 1 to CS FSTD(A).300 Flight Simulation Training Device Standards;
(2) AMC1 FSTD(A).300(b)(3) Table of FSTD Validation Tests; and
(3) AMC1 FSTD(A).300(c) Functions and subjective tests.
(b) General provisions
The provisions for high-angle-of-attack modelling should be applied to evaluate the recognition
cues as well as performance and handling qualities of a developing stall through the stall
identification angle-of-attack and stall recovery. Strict time-history-based evaluations against
flight test data may not adequately validate the aerodynamic model in an unsteady and
potentially unstable flight regime, such as stalled flight. As a result, the objective testing
provisions of AMC1 FSTD(A).300 do not contain strict tolerances for any parameter at angles of
attack beyond the stall identification angle-of-attack. In lieu of mandating such objective
tolerances, an SOC should define the source data and methods used to develop the
aerodynamic-stall model.
(c) Fidelity provisions
The provisions for the evaluation of full-stall training manoeuvres should provide the following
levels of fidelity:
(1) aeroplane-type-specific recognition cues of the first indication of the stall (such as the
stall-warning system or aerodynamic stall buffet);
(2) aeroplane-type-specific recognition cues of an impending aerodynamic stall; and
(3) recognition cues and handling qualities from stall break through recovery which are
sufficiently representative of the aeroplane being simulated to allow successful
completion of the stall recovery training tasks.
For the purposes of stall manoeuvre evaluation, the term ‘representative’ is defined as a
level of fidelity that is type-specific of the simulated aeroplane to the extent that the
training objectives can be satisfactorily accomplished. Therefore, the term ‘representative’
in this AMC is specifically limited to the characteristics of the aerodynamic model in the
post-stall region. The description of this term is given to explain the intent of the model
rather than defining the meaning of the term ‘representative modelling’ which may be
described in other simulator definitions.
(d) SOC (aerodynamic model)
At a minimum, the following must be addressed in the SOC:
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(1) Source data and modelling methods
The SOC must identify the sources of data used to develop the aerodynamic model. These
data sources may be from the aeroplane original equipment manufacturer (OEM), the
original-FSTD manufacturer/data provider, or other data provider acceptable to the
competent authority. Of particular interest is a mapping of test points in the form of an
alpha/beta envelope plot for a minimum of flaps-up and flaps-down aeroplane
configurations. For the flight test data, a list of the types of manoeuvres used to define the
aerodynamic model for angle-of-attack ranges greater than the first indication of stall
must be provided per flap setting. Flight test reports, when available, describing stall
characteristics of the aeroplane type being modelled, issued by the OEM or flight test
pilot, can be referred to. In cases where it is impractical to develop and validate a stall
model with flight-test data (e.g. due to safety concerns involving the collection of
flight-test data past a certain angle of attack), the data provider is expected to make a
reasonable attempt to develop a stall model through the required angle-of-attack range
using analytical methods and empirical data (e.g. wind tunnel data).
(2) Validity range
The FSTD operator should declare the range of angle of attack and sideslip where the
aerodynamic model remains valid for training. Satisfactory aerodynamic-model fidelity
must be shown through stall recovery training tasks. For the purposes of determining this
validity range, the stall is defined as the angle of attack where the pilot is given a clear and
distinctive indication to ease any further increase in the angle of attack where one or
more of the following characteristics occur:
(i) no further increase in pitch occurs when the pitch control is held at the full aft stop
for two seconds, leading to an inability to arrest the descent rate;
(ii) an uncommanded nose-down pitch that cannot be readily arrested, which may be
accompanied by an uncommanded rolling motion;
(iii) buffeting of a magnitude and severity that is a strong and effective deterrent to a
further increase in the angle of attack;
(iv) activation of a stick pusher: for the validity range, the modelling continuity should
allow for an angle-of-attack range that is adequate to allow for the completion of
stall recovery; for pusher-equipped aeroplanes, this should be adequate to capture
any inappropriate action during the recovery procedure; and
(v) for aeroplanes equipped with a stall envelope protection system, the model should
allow training with the protection systems disabled or otherwise degraded (such as
a degraded flight control mode as a result of a pitot/static system failure).
(3) Model characteristics
Within the declared model validity range, the SOC must address, and the aerodynamic
model must incorporate, the following stall characteristics, where applicable by aeroplane
type:
(i) degradation of the static/dynamic lateral-directional stability;
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(ii) degradation in control response (pitch, roll, and yaw);
(iii) uncommanded roll acceleration or roll-off requiring significant control deflection to
counter;
(iv) apparent randomness or non-repeatability;
(v) changes in pitch stability;
(vi) stall hysteresis;
(vii) Mach effects;
(viii) stall buffet; and
(ix) angle-of-attack rate effects.
An overview of the methodology used to address these features must be provided.
(e) SOC (subject-matter expert (SME) pilot’s evaluation)
The operator must provide an SOC confirming that the simulation stall model has been
subjectively evaluated by an SME pilot knowledgeable of the aeroplane’s stall characteristics
(please refer to (d)(1) above).
The purpose is to ensure that the stall model has been sufficiently evaluated using those general
aeroplane configurations and stall entry methods that will likely be conducted in training.
In order to qualify as an acceptable SME to evaluate the stall model characteristics, the SME
must meet the following:
(1) have held or currently hold a type rating/qualification in the aeroplane being simulated;
(2) have direct experience in conducting stall manoeuvres in an aeroplane that shares the
same type rating as the make, model, and series of the simulated aeroplane; this stall
experience must include hands-on manipulation of the controls at angles of attack
sufficient to identify the stall (e.g. deterrent buffet, stick pusher activation, etc.) through
recovery to stable flight;
(3) where the SME’s stall experience is in an aeroplane of a different make, model, and series
within the same type rating, differences in aeroplane-specific stall recognition cues and
handling characteristics must be addressed using available documentation; this
documentation may include aeroplane operating manuals (OMs), aeroplane manufacturer
flight test reports, or other documentation that describes the stall characteristics of the
aeroplane; and
(4) be familiar with the intended stall training manoeuvres to be conducted in the FSTD (e.g.
general aeroplane configurations, stall entry methods, etc.) and the cues necessary to
accomplish the required training objectives.
This SOC will only be required at the time the FSTD is initially qualified for stall training tasks as
long as the FSTD’s stall model remains unmodified compared to what was originally evaluated
and qualified. Where an FSTD shares common aerodynamic and flight control models with those
of an engineering or development simulator, the competent authority will accept an SOC from
the aeroplane manufacturer or data provider confirming that the stall characteristics have been
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subjectively assessed by an SME pilot on the engineering/development simulator (please refer to
AMC1 FSTD(A).200 and AMC7 FSTD(A).300(b) for the description of an engineering/development
simulator).
An FSTD operator may submit a request to the competent authority for approval of a deviation
from the SME pilot’s experience provisions under this paragraph. This request for deviation must
include the following information:
(1) an assessment of pilot availability demonstrating that a suitably qualified pilot, meeting
the experience described in AMC10 FSTD(A).300(e), is not available; and
(2) alternative methods to subjectively evaluate the FSTD’s capability to provide the stall
recognition cues and handling characteristics needed to accomplish the training
objectives.
(f) SOC (subjective tests)
Test provisions
The necessity of subjective tests arises from the need to confirm that the simulation model has
been integrated correctly and performs as declared under (d) above. It is vital to examine, for
example, that the simulation validity range allows modelling continuity that is adequate to
allow for the completion of stall recovery.
Considerations on aeroplane certification flight test provisions
In aeroplane certification flight tests, there is no provision to go beyond the maximum
coefficient of lift (CL max), and the aeroplane is not to be held in full-stall condition, so this
provision should be applied in the same way during the simulator’s subjective evaluation.
The subjective tests of the simulation model should assess modelling continuity when slightly
increasing the angle of attack beyond CL max.
The increase in angle of attack beyond CL max should be limited to a value greater than the
maximum angle achieved two seconds after stall recognition, which is sufficient to allow a
proper recovery manoeuvre.
Stall recognition is defined as:
(1) no further increase in pitch when the pitch control is held on the aft stop for two seconds,
leading to an inability to arrest the descent rate;
(2) an uncommanded nose-down pitch that cannot be readily arrested, which may be
accompanied by an uncommanded rolling motion;
(3) buffeting of a magnitude and severity that is a strong and effective deterrent to a further
increase in the AOA; and
(4) activation of a stick pusher.
The handling provisions at low speed and maximum angle of attack cover aeroplanes with
protection. For pusher-equipped aeroplanes, this should be adequate to capture any
inappropriate pilot action during the recovery procedure.
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Where known limitations exist in the aerodynamic model for particular stall event manoeuvres
(such as aeroplane configuration, approach-to-stall entry methods, and limited range for
continuity of the modelling), these limitations must be declared in the required SOC.
6. New AMC11 FSTD(A).300 is inserted as follows:
Draft resulting text
AMC11 FSTD(A).300 Guidance on high angle of attack/stall model evaluation, and approach to stall
for qualified FSTDs
For FSTDs already qualified under CS-FSTD(A), it may not always be possible to provide the required
validation data for the new or revised objective test cases, to support the FSTD qualification for stall
and approach to stall. These validation tests have the following characteristics:
(a) Objective testing for stall characteristics (please refer to Table of FSTD Validation Tests, 2.c.(8a))
are only required for the (wings level) second-segment climb and approach or landing flight
conditions.
(b) For the testing of the high-altitude cruise and turning-flight stall conditions, these manoeuvres
may be subjectively evaluated by a qualified SME pilot and addressed in the required statement
of compliance (SOC); these tests should utilise the footprint method to document the SME
evaluation and this should be included in the approved master qualification test guide (MQTG).
To allow for any randomisation during recurrent testing, one should apply engineering
judgement to ensure that the key characteristics of the original SME assessment are maintained.
(c) Where existing flight test validation data in the FSTD’s MQTG is missing required parameters, or
is otherwise unsuitable to fully meet the objective testing provisions, the competent authority
may accept alternative sources of validation, including subjective validation by an SME pilot with
direct experience in the stall characteristics of the aeroplane.
(d) Objective testing for characteristic motion vibrations (please refer to Table of FSTD Validation
Tests, 3.g.(6)) is not required where the FSTD’s stall buffets have been subjectively evaluated by
an SME pilot. For previously qualified Level D FSTDs that currently have objective stall buffet
tests in their approved MQTG, the results of these existing tests must be provided to the
competent authority with the updated stall and stall buffet models in place.
(e) As described in AMC10 FSTD(A).300, the competent authority may accept an SOC from the data
provider, confirming that the stall characteristics have been subjectively evaluated by an SME
pilot on an engineering simulator or development simulator that is acceptable to the competent
authority. Where this evaluation takes place on an engineering or development simulator,
additional objective ‘proof-of-match’ testing for all flight conditions, as described in Tests
2.c.(8a) and 3.g.(6), is required to verify the implementation of the stall model and stall buffets
on the FSTD.
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7. New AMC12 FSTD(A).300 is inserted as follows:
Draft resulting text
AMC12 FSTD(A).300 Guidance on upset prevention and recovery training (UPRT) for the FSTD
standards table
(a) Background
(1) This AMC provides guidance on Appendix 1 to CS FSTD(A).300, namely on the following:
(i) 1. General:
(A) h.2 (IOS tools);
(B) h.3 (upset scenarios); and
(C) s.1 (aerodynamics); and
(ii) 2. Motion system, a.1.
(2) This AMC applies to all FSTDs used to satisfy training provisions for UPRT manoeuvres. For
the purposes of this AMC, an airplane upset (as defined in the ICAO Airplane Upset
Prevention & Recovery Training Aid (AUPRTA) Rev 3, February 2017) is an undesired
aeroplane state characterised by unintentional deviations from parameters experienced
during normal operations. An aeroplane upset may involve pitch and/or bank angle
deviations as well as inappropriate airspeeds for the given conditions.
(3) FSTDs used to conduct training manoeuvres where the FSTD is repositioned either into an
aeroplane upset condition or an artificial stimulus (such as weather phenomena or system
failures) that is intended to result in a flight crew entering an aeroplane upset condition
must be evaluated and qualified.
(b) FSTD standards provisions
(1) The provisions of Appendix 1 to CS FSTD(A).300 define three basic elements required for
qualifying an FSTD for UPRT manoeuvres:
(i) FSTD training envelope: see definition in AMC1 FSTD(A).200;
(ii) instructor feedback: provides the instructor/evaluator with a minimum set of
feedback tools to properly evaluate the trainee’s performance in accomplishing
a UPRT task; and
(iii) upset scenarios: where dynamic upset scenarios or aeroplane system
malfunctions are used to drive the FSTD into an aeroplane upset condition,
specific guidance must be available to the instructor on the IOS which describes
how the upset scenario is driven along with any malfunction or degradation in
FSTD functionality required to stimulate the upset.
(2) FSTD validation envelope
This envelope is defined by the following three subdivisions (see Appendix 3-D of ICAO
AUPRTA’).
(i) Flight-test-validated region
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This is the region of the flight envelope which has been validated with flight test
data, typically by comparing the performance of the FSTD against these flight
test data through tests incorporated in the QTG and other flight test data
utilised to further extend the model beyond the minimum provisions. Within
this region, there is high confidence that the FSTD responds similarly to the
aeroplane. Please note that this region is not strictly limited to what has been
tested in the QTG; as long as the aerodynamics mathematical model has been
conformed to the flight test results, that portion of the mathematical model is
considered to be within the flight-test-validated region.
(ii) Wind tunnel and/or analytical region
This is the region of the flight envelope for which the FSTD has not been
compared to flight test data, but for which there has been wind tunnel testi ng or
the use of other reliable predictive methods (typically by the aeroplane
manufacturer) to define the aerodynamic model. Any extensions to the
aerodynamic model which have been evaluated in accordance with the
definition of a representative stall model (as described in AMC10 FSTD(A).300)
must be clearly indicated. Within this region, there is moderate confidence that
the FSTD will respond in a similar way as the aeroplane.
(iii) Extrapolated region
This is the region extrapolated beyond the flight-test-validated and wind
tunnel/analytical regions. The extrapolation may be a linear one, a holding of
the last value before the extrapolation began, or some other set of values.
Whether this extrapolated data is provided by the aeroplane or FSTD
manufacturer, it is a ‘best estimation’ only. Within this region, there is low
confidence that the FSTD will respond in a similar way as the aeroplane.
(c) IOS feedback mechanism
(1) For the instructor/evaluator to provide feedback to the student during the upset
prevention and recovery manoeuvre training, additional information must be accessible
which indicates the fidelity of the simulation, the magnitude of the trainee’s flight control
inputs, as well as the aeroplane operational limits that could potentially affect the
successful completion of the manoeuvre(s). At a minimum, the following must be
available to the instructor/evaluator:
(i) FSTD validation envelope
The FSTD must employ a method to display the FSTD’s expected fidelity with
respect to the FSTD validation envelope. This may be displayed as an angle of
attack vs sideslip (alpha/beta) envelope cross-plot on the IOS or other
alternative method to clearly convey the FSTD’s fidelity level during the
manoeuvre. The cross-plot or other alternative method must display the
relevant validity regions for flaps-up and flaps-down at a minimum. This
validation envelope must be derived by the aerodynamic-data provider, or using
information and data sources provided by the aerodynamic-data provider
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(ii) Flight control inputs
The FSTD must employ a method for the instructor/evaluator to assess the
trainee’s flight control inputs during the upset recovery manoeuvre. Additional
parameters, such as cockpit control forces (forces applied by the pilot to the
controls) and the flight control law mode for fly-by-wire aeroplanes, must be
portrayed in this feedback mechanism as well). For passive side-sticks, whose
displacement is the flight control input, the force applied by the pilot to the
controls does not need to be displayed. This tool must include a time history or
other equivalent method of recording flight control positions.
(iii) Aeroplane operational limits
The FSTD must employ a method to provide the instructor/evaluator with
real-time information concerning the aeroplane operating limits. The simulated
aeroplane’s parameters must be displayed dynamically in real-time and
provided in a time history or equivalent format. At a minimum, the following
parameters must be available to the instructor:
(A) airspeed and airspeed limits, including the stall speed and maximum
operating limit airspeed (VMO)/maximum operating Mach (MMO);
(B) load factor and operational load factor limits; and
(C) angle of attack and stall identification angle-of-attack (please refer to
AMC10 FSTD(A).300(d)(2) for additional information on the definition of
the stall identification angle-of-attack); this parameter may be displayed
in conjunction with the FSTD validation envelope.
(2) Optionally, a recorded feedback mechanism is available to the instructor/evaluator.
8. New GM12 FSTD(A).300 is inserted as follows:
Draft resulting text
GM12 FSTD(A).300 Additional guidance on upset prevention and recovery training (UPRT) for the
FSTD standards table
(a) Introduction
The FSTD should be provided with information pertaining to the aeroplane parameters as
described in AMC12 FSTD(A).300. This AMC details some of the performance provisions for these
features.
The objective of IOS feedback during UPRT exercises is to provide the instructor with the ability
to assess the timely and proper control action, including sequence, to complete the recovery in a
safe manner.
(b) Background
IOS feedback, which may also be via a separate mobile device, is used to monitor and debrief the
crew regarding UPRT exercises, to verify that proper control activity was executed. The
instructor should have the necessary information to clearly establish if the recovery was
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completed in the FSTD training envelope (please refer to AMC12 FSTD(A).300), and take any
necessary action to complete the training.
The FSTD should include tools for the instructor to be able to immediately debrief the pilots after
the training event.
(c) IOS parameters
The tool should normally display:
(1) Control inputs, including:
(i) pitch,
(ii) roll,
(iii) rudder,
(iv) throttles,
(v) flaps, and
(vi) speed brakes/spoilers.
Time history of control inputs
In order to ascertain that the control inputs are applied in a correct, timely and smooth
manner, the display should indicate these at a sampling frequency rate that is sufficiently
high to prevent from missing possible abrupt pilot action. This may be limited to the
debrief mode following the execution of the exercise or individual manoeuvre.
(2) Primary flight display, including:
(i) pitch attitude,
(ii) roll attitude,
(iii) turn/sideslip,
(iv) indicated airspeed,
(v) stall-warning speed/stall buffet speed,
(vi) VMO/MMO,
(vii) altitude,
(viii) rate of climb,
(ix) autopilot status, and
(x) auto-throttle status.
(3) Angle of attack.
(4) Angle of sideslip.
(5) G-loading.
The limitations of (3), (4), and (5) shall also be indicated, as follows:
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One method is the simultaneous depiction of angle-of-attack vs angle-of-sideslip and the
corresponding FSTD validation envelope.
A presentation of the G-loading as function of the current airspeed and flight configuration
The V-n diagram indicates the limitations of the aeroplane under given conditions. It displays the
flight envelope as function of the airspeed versus G-loading. It shows the lower airspeed limits
by means of a parabolic line. The intersection of this line with the 1.0-g horizontal line
corresponds to the stall speed at 1 g. The regions above the 2.5-g upper limit (maximum design
limit) to the right of VNE and below the – 1.0-g lower limit are the structural exceedance limits
and should be avoided. The shape of the V-n diagram depends on the aeroplane itself, its
configuration, as well as the environmental and flight conditions.
Figure 1 —V-n diagram (example)
Legend to Figure 1:
VS1 = clean stall speed at 1 g
VA = design manoeuvre speed
VNE = never-exceed speed
9. New AMC13 FSTD(A).300 is inserted as follows:
Draft resulting text
AMC13 FSTD(A).300 Guidance material for engine and airframe icing evaluation provisions
(a) Applicability
This AMC applies to all FSTDs used to satisfy training provisions for engine and airframe icing.
New general provisions as well as objective provisions for FSTD qualification have been
developed in order to define aeroplane-specific icing models that support training objectives for
the recognition of, and recovery from, an in-flight ice accretion event.
(b) General provisions
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The following elements should be considered when developing the qualified ice accretion
models for use in FSTD training:
(1) icing models must be able to train the specific skills required for the recognition of ice
accumulation and for generating the required response;
(2) icing models must contain aeroplane-specific recognition cues as determined through data
supplied by an aeroplane original-equipment manufacturer (OEM) or through other
suitable analytical methods; and
(3) at least one qualified icing model must be objectively tested to demonstrate that it has
been implemented correctly and that it generates the correct cues as necessary for
training.
(c) Statement of compliance (SOC)
The SOC described in Appendix 1 to CS FSTD(A).300 1.t.1. must contain the following information
to support FSTD qualification of aeroplane-specific icing models:
(1) A description of expected aeroplane-specific recognition cues and degradation effects due
to a typical in-flight icing encounter.
Typical cues may include loss of lift, decrease in stall angle of attack, changes in pitching
moment, decrease in control effectiveness, and changes in control forces in addition to
any overall increase in drag. This description must be based on relevant data source, such
as aeroplane OEM-supplied data, accident/incident data, or other acceptable data
sources. Where a particular airframe has demonstrated vulnerabilities to a specific type of
ice accretion (due to accident/incident history), which requires specific training (such as
supercooled large-droplet icing or tailplane icing), ice accretion models must be developed
that address those training provisions.
(2) A description of the data sources used to develop the qualified ice accretion models.
Acceptable data sources may be, but are not limited to, flight test data, aeroplane
certification data, aeroplane OEM engineering simulation data, or other analytical
methods based on established engineering principles.
(d) Objective demonstration testing
The purpose of the objective demonstration test is to demonstrate that the ice accretion
models, as described in the SOC, have been correctly implemented and demonstrate the proper
cues and effects, as defined in the approved data sources. At least one ice accretion model must
be selected for testing and included in the master qualification test guide (MQTG). Two tests are
required to demonstrate engine and airframe icing effects. One test demonstrates the FSTDs
baseline performance without icing, and the second test demonstrates the aerodynamic effects
of ice accretion relative to the baseline test.
(1) Recorded parameters: in each of the two required MQTG cases, a time-history recording
of the following parameters should be made:
(i) altitude;
(ii) airspeed;
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(iii) normal acceleration;
(iv) engine power/settings;
(v) angle of attack/pitch attitude;
(vi) bank angle;
(vii) flight control inputs;
(viii) stall warning and stall buffet onset; and
(ix) other parameters necessary to demonstrate the effects of ice accretion.
(2) Demonstration manoeuvre: the FSTD operator must select an ice accretion model, as
identified in the SOC for testing. The selected manoeuvre must demonstrate the effects of
ice accretion at high angles of attack from a trimmed condition through approach to stall
and ‘full’ stall, as compared to a baseline (no ice build-up) test. The ice accretion models
must demonstrate the cues necessary to recognise the onset of ice accretion on the
airframe, lifting surfaces, and engines, and provide a representative degradation in
performance and handling qualities to the extent that a recovery can be executed. Typical
recognition cues that may be present depending on the simulated aeroplane include:
(i) decrease in stall angle of attack;
(ii) increase in stall speed;
(iii) increase in stall buffet threshold of perception speed;
(iv) changes in pitching moment;
(v) changes in stall buffet characteristics;
(vi) changes in control effectiveness or control forces; and
(vii) engine effects (power variation, vibration, etc.).;
The demonstration test may be conducted by initialising and maintaining a fixed amount of ice
accretion throughout the manoeuvre in order to consistently evaluate the aerodynamic effects.
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3.2. Draft AMC/GM (draft EASA Decision)
3.2.1 AMC/GM to Part-FCL
1. New GM1 Appendix 9 to Part-FCL is inserted as follows:
Draft resulting text
GM1 Appendix 9 to Part-FCL
Aeroplane FSTD training credits
EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
Flight FFS Level C,
Instruction Solo BIT FNPT II FFS Level FFS Level CG, interim FFS Level
AIRCREW/AIROPS reference s Dual SPIC (PIC) D FNPT I FNPT II MCC FTD 1 FTD 2 A/AG B/BG C D/DG
Type of Training
LAPL(A)
Modular FCL.115 30 15 NO 6 NO NO NO NO NO NO NO NO NO NO
PPL(A)
YES
Modular FCL.210.A 45 25 NO 10 (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5)
CPL(A) modular
Instrument flight YES
instruction Appendix 3, Part E 10 10 NO NO (5) YES (5) YES (5) YES (5) NO YES (5) YES (5) YES (5) YES (5) YES (5)
CPL(A) integrated
Instrument flight Appendix 3, Part D to Annex
instruction 1 10 10 NO NO NO YES (5) YES (5) YES (5) NO YES (5) YES (5) YES (5) YES (5) YES (5)
CPL/IR(A) integrated
Instrument rating
training FCL.315 50 50 20 NO NO YES (25) Yes (40) YES (40) NO YES (40) YES (40) NO NO NO
ATPL(A)
Integrated FCL.515 + Appendix 3
(instrument training) Subpart A 50 50 20 NO NO YES (25) YES (40) YES (40) NO YES (40) YES (40) YES (40) YES (40) YES (40)
Integrated (MCC FCL.515 + Appendix 3
training) Subpart A 15 15 NO NO NO NO NO YES (15) NO NO YES (15) YES (15) YES (15) YES (15)
MPL integrated
FCL.410.A + Appendix 5 to
Phase 1 Annex 1 YES YES NO NO NO NO NO NO NO NO
FCL.410.A + Appendix 5 to
Phase 2 Annex 1 NO NO NO YES NO NO NO NO NO NO
FCL.410.A + Appendix 5 to
Phase 3 Annex 1 NO NO NO NO NO NO NO YES YES YES
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
Flight FFS Level C,
Instruction Solo BIT FNPT II FFS Level FFS Level CG, interim FFS Level
AIRCREW/AIROPS reference s Dual SPIC (PIC) D FNPT I FNPT II MCC FTD 1 FTD 2 A/AG B/BG C D/DG
Type of Training
FCL.410.A + Appendix 5 to
Phase 4 Annex1 NO NO NO NO NO NO NO NO YES YES
Class Rating(A)
TMG (extension to
LAPL(A)) FCL.725.A 3 3 NO NO NO NO NO NO NO NO NO NO NO NO
SEP (Land) FCL.725.A NO NO NO NO NO NO NO NO NO NO NO NO
10, 8 if
10, 8 if SEP SEP
(Land) (Land)
SEP (Sea) FCL.725.A rated rated NO NO NO NO NO NO NO NO NO NO NO NO
MEP (Land) FCL.725.A 6 6 NO NO NO NO NO NO NO NO NO NO NO NO
10, 8 if 10, 8 if
MEP MEP
(Land) (Land)
MEP (Sea) FCL.725.A rated rated NO NO NO NO NO NO NO NO NO NO NO NO
SET FCL.725.A
MET FCL.725.A
Type Rating
FCL.725.A + AMC2
Type Rating Course SP ORA.ATO.125(j) NO NO NO NO YES YES YES YES YES YES
MPA 32
Type Rating Course FCL.725.A + AMC2 hours/16
MP ORA.ATO.125(j) using an FFS NO NO NO NO PARTIALLY PARTIALLY PARTIALLY YES YES YES
MPA 32
ZFT Type Rating hours/16
Course FCL.730.A using an FFS NO NO NO NO PARTIALLY PARTIALLY NO NO YES YES
Recency of
Experience
Recent Experience FCL.060(b) NO NO NO NO NO NO NO NO NO NO NO YES YES YES
Operator Recurrent
Training
Route/Area/ AMC1
Aerodrome ORO.FC.105(b)(2);(c)(a),(2)(ii)
Knowledge + (c)(2) NO NO NO NO NO YES* YES YES YES YES
AMC 1 ORO.FC.115(a)(1) +
CRM Training (a)(4) NO NO NO NO NO YES* YES YES YES YES
Command Course ORO.FC.205 NO NO NO NO NO NO PARTIALLY YES YES YES
Operator Conversion
ZFTT (6 circling
patterns) ORO.FC.220(e)(2) NO NO NO NO NO NO NO NO YES YES
Operator Conversion
Training and AMC 1 OROR.FC.220(a)(iii) +
Checking (d)(4) NO NO NO NO NO PARTIALLY PARTIALLY PARTIALLY YES YES
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
Flight FFS Level C,
Instruction Solo BIT FNPT II FFS Level FFS Level CG, interim FFS Level
AIRCREW/AIROPS reference s Dual SPIC (PIC) D FNPT I FNPT II MCC FTD 1 FTD 2 A/AG B/BG C D/DG
Type of Training
Upset Prevention
Training AMC2 ORO.FC.220&230(a) NO NO NO NO NO YES YES YES YES YES
Upset Recovery
Training AMC2 ORO.FC.220&230(b) NO NO NO NO NO NO NO YES* YES YES
Recurrent Training
and Checking ORO.FC.230(f) NO NO NO NO NO PARTIALLY YES YES YES
Instrument Rating
FCL. 615 + Appendix 6,
IR-SE Subpart A 50 50 NO NO NO 20 35 35 NO NO 35 35 35 35
FCL. 615 + Appendix 6,
IR-ME Subpart A 55 55 NO NO NO 25 40 40 NO NO 40 40 40 40
IR-SE (A) to IR-ME Appendix 6, Subpart A.9 5 5 NO NO NO NO 3 3 NO NO 3 3 3 3
IR-SE (A)/IR-ME
revalidation FCL.625.A IR(A) NO NO YES (2) YES (2) NO NO YES (2) YES (2) YES (2) YES (2)
IR(H) to IR-SE Appendix 6, Subpart A.10.2 10 10 NO NO NO YES* YES* YES* NO NO
IR(H) to IR-ME Appendix 6, Subpart A.10.2 10 10 NO NO NO YES* YES* YES* NO NO
EIR (SE) FCL.825(c) 15 15 NO NO NO NO NO NO NO NO NO NO NO NO
16, 4 of
them
16, 4 of with an
them with MEP
an MEP aeroplan
EIR (ME) FCL.825(c) aeroplane e NO NO NO NO NO NO NO NO NO NO NO NO
EIR (SE-ME)
revalidation FCL.825(g) NO NO NO NO NO NO NO NO NO NO NO NO
FCL. 615 + Appendix 6,
CB-IR-SE Subpart Aa 40 40 NO NO NO 10 25 25 NO NO YES YES YES YES
FCL. 615 + Appendix 6,
CB-IR ME Subpart Aa 45 45 NO NO NO YES YES YES NO NO YES YES YES YES
Multi-Crew
Cooperation
MCC modular course FCL.735.A 20 20 NO NO NO NO NO 20 NO NO 20 20 20 20
Instructor Training
FI FCL.930.FI FI(b)(3) 30 25 NO NO NO YES YES YES NO YES YES YES YES YES
FCL.930.CRI CRI +
CRI SE AMC1 FCL.930.CRI CRI(c) 3 3 NO NO NO NO NO NO NO NO YES YES YES YES
FCL.930.CRI CRI +
CRI ME AMC1 FCL.930.CRI CRI(c) 5 5 NO NO NO NO NO NO NO NO YES YES YES YES
10, 5 if 10, 5 if
IRI FCL.930.IRI IRI(3)(i) FI (A) FI (A) NO NO NO YES YES YES NO YES YES YES YES YES
FCL.930.MCCI MCCI + AMC
MCCI (A) 1 FCL.930.MCCI MCCI 3 3 NO NO NO NO NO YES NO YES YES YES YES YES
MPL instructor FCL.925(b)(1) NO NO NO NO NO NO NO YES (1*) YES TES YES YES
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
Flight FFS Level C,
Instruction Solo BIT FNPT II FFS Level FFS Level CG, interim FFS Level
AIRCREW/AIROPS reference s Dual SPIC (PIC) D FNPT I FNPT II MCC FTD 1 FTD 2 A/AG B/BG C D/DG
Type of Training
1 hour air
exercise +
MPL Instructor 1 simulator
Revalidation FCL.925(c)(1) session NO NO NO NO NO YES NO YES (1*) YES YES YES YES
STI (A) FCL.930.STI STI 3 3 NO NO NO NO YES YES NO YES YES YES YES YES
SFI (A) FCL.930.SFI SFI 32 + 10 3 2 + 10 NO NO NO NO NO NO NO PARTIALLY PARTIALLY YES YES YES
TRI SP (A) FCL.930.TRI TRI 5 5 NO NO NO NO NO NO NO YES (1*) YES YES YES YES
TRI MP (A) FCL.930.TRI TRI 10 10 NO NO NO NO NO NO NO YES (1*) PARTIALLY YES YES YES
Examiner Training
FCL.1000 + FCL.1015 + 2 skills
FE (A) AMC1.FCL.1015 tests NO NO NO NO NO NO NO NO NO NO NO NO NO
FCL.1000 + FCL.1015 + 2 skills
CRE (A) AMC1.FCL.1015 tests NO NO NO NO PARTIALLY PARTIALLY PARTIALLY NO NO PARTIALLY PARTIALLY PARTIALLY PARTIALLY
FCL.1000 + FCL.1015 + 2 skills
IRE (A) AMC1.FCL.1015 tests NO NO NO NO PARTIALLY PARTIALLY PARTIALLY NO NO PARTIALLY PARTIALLY PARTIALLY PARTIALLY
FCL.1000 + FCL.1015 + 2 skills
SFE (A) AMC1.FCL.1015 tests NO NO NO NO NO NO NO NO YES (1*) YES YES YES YES
FCL.1000 + FCL.1015 + 2 skills
TRE SP (A) AMC1.FCL.1015 tests NO NO NO NO NO NO NO NO YES (1*) YES YES YES YES
FCL.1000 + FCL.1015 + 2 skills
TRE MP (A) AMC1.FCL.1015 tests NO NO NO NO NO NO NO NO YES (1*) YES YES YES YES
FCL.1000 + FCL.1015 + 2 skills
FIE (A) AMC1.FCL.1015 tests NO NO NO NO NO NO NO NO NO NO NO NO NO
(*) combination of FNPT and aeroplane for a total of 10 hours
(1*) if fitted with a visual system
(2) yes, for each alternate proficiency check
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Helicopter FSTD training credits
EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
LAPL (H)
FCL.11O.H.
Modular LAPL (H) 40 20 NO 10 NO NO NO NO NO NO NO NO NO NO NO NO NO NO
PPL (H)
Visual/Basi
c FCL.210.H YES
Instrument PPL (H) 45 25 NO 10 (5) YES (5) YES (5) YES (5) YES (5) NO NO NO NO NO YES (5) YES (5) YES (5) YES (5)
CPL (H)
modular 30 30
FCL.315 +
Appendix 3
Visual Subpart
Training K(8) 20 NO NO NO YES (5) YES (5) YES (5) YES (5) NO YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5)
FCL.315 +
Appendix 3
Basic Subpart YES
Instrument K(8) 10 NO NO (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5)
CPL (H)
Integrated 135 85 40 15
FCL.315 +
Appendix 3
Visual Subpart YES YES YES
Training J(8) 75 35 15 NO (20) YES (20) YES (20) YES (20) NO (25) YES (25) (25) YES (25) YES (30) YES (30) YES (30) YES (30)
FCL.315 +
Appendix 3
Basic Subpart YES
Instrument J(8) 10 NO NO (5) YES (5) YES (5) YES (5) YES (5) NO YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5)
CPL/IR (H)
Integrated 180 125 40 15
Visual
Training FCL.315 +
including Appendix 3
ME T/R Subpart YES YES YES
Training I(8) 75 NO (20) YES (20) YES (20) YES (20) NO (25) YES (25) (25) YES (25) YES (30) YES (30) YES (30) YES (30)
FCL.315 +
Instrument Appendix 3
Rating Subpart YES YES YES YES
Training I(8) 50 20 NO (10) (20) YES (20) YES (20) YES (20) NO (20) YES (20) (20) YES (20) YES (20) YES (20) YES (20) YES (20)
ATP/IR (H)
Integrated 195 140 40 15
Visual
Training FCL.515 +
including Appendix 3
ME T/R Subpart F YES YES YES
Training 8) 75 NO (20) YES (20) YES (20) YES (20) NO (25) YES (25) (25) YES (25) YES (25) YES (25) YES (30) YES (30)
Instrument FCL.515 +
Rating Appendix 3 YES YES YES YES
Training Subpart F(8) 50 (10) (20) YES (20) YES (20) YES (20) NO (20) YES (20) (20) YES (20) YES (20) YES (20) YES (20) YES (20)
Integrated FCL.515 +
(MCC Appendix 3 15 NO NO NO NO YES (15) NO YES (15) NO NO YES (15) NO YES (15) YES (15) YES (15) YES (15) YES (15)
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
Training) Subpart F
(8)
ATP
(H)/VFR
Integrated 150 95 40 15
FCL.515 +
Visual Appendix 3 YES(20 YES(25
Training Subpart G 75 NO ) YES(20) YES(20) YES(20) NO YES(25) YES(25) ) YES(25) YES(30) YES(30) YES(30) YES(30)
Basic FCL.515 +
Instrument Appendix 3 YES
Instruction Subpart G 10 NO NO (5) YES(5) YES(5) YES(5) YES(5) NO YES(5) YES(5) YES(5) YES(5) YES(5) YES(5) YES(5) YES(5)
FCL.515 +
MCC/VFR Appendix 3
training Subpart G 10 NO NO NO NO YES(10) NO YES(10) NO NO YES(10) NO YES(10) YES(10) YES(10) YES(10) YES(10)
Type Rating
Initial Issue
(Minimum
Flight
Instruction
excluding
Skill Test)
AMC2
FCL.725(a)(c 5 on
SEP(H) or ) helicopter 5 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
AMC2 2 on
FCL.725(a)(c helicopter
SEP(H) or ) + 4 on FFS 6 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (4) YES (4)
AMC2 4 on
FCL.725(a)(c helicopter
SEP(H) ) + 2 on FTD 6 NO NO NO NO NO NO NO NO YES (2) YES (2) YES (2) YE S(2) NO NO NO NO
SET(H)
under AMC2
3175-kg FCL.725(a)(c 5 on
MTOM or ) helicopter 5 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
SET (H)
under AMC2 2 on
3175-kg FCL.725(a)(c helicopter
MTOM or ) + 4 on FFS 6 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (4) YES (4)
SET (H)
under AMC2 4 on
3175- kg FCL.725(a)(c helicopter
MTOM ) + 2 on FTD 6 NO NO NO NO NO NO NO NO YES (2) YES (2) YES (2) YES (2) NO NO NO NO
SET (H) at
or over AMC2
3175-kg FCL.725(a)(c 8 on
MTOM or ) helicopter 8 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
SET (H) at
or over AMC2 2 on
3175- kg FCL.725(a)(c helicopter
MTOM or ) + 8 on FFS 10 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (8) YES (8)
SET (H) at
or over AMC2 4 on
3175- kg FCL.725(a)(c helicopter
MTOM ) + 6 on FTD 10 NO NO NO NO NO NO NO NO YES (6) YES (6) YES (6) YES (6) NO NO NO NO
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
SPH MET
(H) CS and AMC2
FAR 27 and FCL.725(a)(c 8 on
29 or ) helicopter 8 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
SPH MET
(H) CS and AMC2 2 on
FAR 27 and FCL.725(a)(c helicopter
29 or ) + 8 on FFS 10 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (8) YES (8)
SPH MET
(H) CS and AMC2 4 on
FAR 27 and FCL.725(a)(c helicopter
29 ) + 6 on FTD 10 NO NO NO NO NO NO NO NO YES (6) YES (6) YES (6) YES (6) NO NO NO NO
AMC2
FCL.725(a)(c 10 on
MPH or ) helicopter 10 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
AMC2 2 on
FCL.725(a)(c helicopter
MPH or ) + 10 on FFS 12 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (10) YES (10)
AMC2 4 on
FCL.725(a)(c helicopter
MPH ) + 8 on FTD 12 NO NO NO NO NO NO NO NO YES (8) YES (8) YES (8) YES (8) NO NO NO NO
Additional
Types
(Minimum
Flight
Instruction
excluding
Skill Test)
SEP (H) to
SEP (H)
within
AMC1
FCL.740.H(a)(3 AMC2 2 on
) or FCL.725(a)(d) helicopter 2 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
SEP (H) to
SEP (H)
within
AMC1 1 on
FCL.740.H(a)(3 AMC2 helicopter
) or FCL.725(a)(d) + 2 on FFS 3 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (2) YES (2)
SEP (H) to
SEP (H)
within
AMC1 1 on
FCL.740.H(a)(3 AMC2 helicopter
) FCL.725(a)(d) + 3 on FTD 4 NO NO NO NO NO NO NO NO YES (3) YES (3) YES (3) YES (3) NO NO NO NO
SEP (H) to
SEP (H) not
included in
AMC1
FCL.740.H(a)(3 AMC2 5 on
) or FCL.725(a)(d) helicopter 5 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
SEP (H) to AMC2 1 on
SEP (H) not FCL.725(a)(d) helicopter 6 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (5) YES (5)
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
included in + 5 on FFS
AMC1
FCL.740.H(a)(3
) or
SEP (H) to
SEP (H) not
included in
AMC1 2 on
FCL.740.H(a)(3 AMC2 helicopter
) FCL.725(a)(d) + 3 on FTD 5 NO NO NO NO NO NO NO NO YES (3) YES (3) YES (3) YES (3) NO NO NO NO
SET (H) to AMC2 2 on
SET (H) or FCL.725(a)(d) helicopter 2 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
1 on
SET (H) to AMC2 helicopter
SET (H) or FCL.725(a)(d) + 2 on FFS 3 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (2) YES (2)
1 on
SET (H) to AMC2 helicopter
SET (H) FCL.725(a)(d) + 3 on FTD 4 NO NO NO NO NO NO NO NO YES (3) YES (3) YES (3) YES (3) NO NO NO NO
MET (H) to AMC2 3 on
MET (H) or FCL.725(a)(d) helicopter 3 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
1 on
MET (H) to AMC2 helicopter
MET (H) or FCL.725(a)(d) + 3 on FFS 4 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (3) YES (3)
2 on
MET (H) to AMC2 helicopter
MET (H) FCL.725(a)(d) + 3 on FTD 5 NO NO NO NO NO NO NO NO YES (3) YES (3) YES (3) YES (3) NO NO NO NO
MPH to AMC2 5 on
MPH or FCL.725(a)(d) helicopter 5 NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO
1 on
MPH to AMC2 helicopter
MPH or FCL.725(a)(d) + 5 on FFS 6 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (5) YES (5)
2 on
MPH to AMC2 helicopter
MPH FCL.725(a)(d) + 5 on FTD 7 NO NO NO NO NO NO NO NO YES (5) YES (5) YES (5) YES (5) NO NO NO NO
Extension
of
privileges
on same TR
from SPH
to MPH, or
from MPH AMC2 2 on N
to SPH or FCL.725(a)(d) helicopter 2 NO NO O NO NO NO NO NO NO NO NO NO NO NO NO NO NO
Extension
of
privileges
on same TR
from SPH
to MPH, or 1 on
from MPH AMC2 helicopter
to SPH FCL.725(a)(d) + 2 on FFS 3 NO NO NO NO NO NO NO NO NO NO NO NO NO NO YES (2) YES (2)
Recency of
Experience
Recent FCL.060(b)(1 3 T/O
Experience ) and (b)(2) NO NO NO -3 NO NO NO NO NO NO NO NO NO NO NO YES YES YES
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
ME or SE landi
ngs
Operator
Recurrent
Training
AMC1
Route/Area/ ORO.FC.105(b
Aerodrome )(2);(c)(a)(2)(ii)
Knowledge + (c)(2) NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
AMC 1
ORO.FC.11
CRM 5(a)(1) +
Training (a)(4) NO NO NO NO NO ? NO NO YES YES YES YES YES YES YES YES
Command ORO.FC.20
Course 5 NO NO NO NO NO ? NO NO YES YES YES YES YES YES YES YES
Operator
Conversion
Training AMC 1
and ORO.FC.22 PARTIALL
Checking 0(a)(iii) NO NO NO NO NO NO NO NO PARTIALLY PARTIALLY Y PARTIALLY PARTIALLY PARTIALLY YES YES
Recurrent
Training
and ORO.FC.230(f PARTIALL
checking ) NO NO NO NO NO ? NO NO PARTIALLY PARTIALLY Y PARTIALLY PATIALLY YES YES YES
Instrument
Rating
FCL.615(a)(2
) + Appendix
6, Subpart
IR-SE (H) B(7) 50 50 NO NO 20 35 35 35 35 NO 35 35 35 35 35 35 35 35
FCL.615(a)(2
) + Appendix
6, Subpart
IR-ME (H) B(8) 55 55 NO NO 20 40 40 40 40 NO 40 40 40 40 40 40 40 40
IR-SE (H)
IR-ME (H) FCL.625.H
revalidation IR(H)(a)(2) NO NO NO NO NO NO NO NO YES* YES* YES* YES* YES* YES* YES* YES*
Extension
of FCL.630.H
Privileges IR(H) +
from IR (SE) AMC2 FCL.72
to IR (ME) 5 5 5 NO NO NO YES (3) YES (3) YES (3) YES (3) NO YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3)
Extension
of IR (H) to
Further AMC2
Types FCL.725(e) 2 2 NO NO NO NO NO NO NO NO YES (2) YES (2) YES (2) YES (2) YES (2) YES (2) YES (2) YES (2)
FCL.615(a)(2
) + Appendix
SE-IR (A) to 6, Subpart
IR-SE (H) B(9.2) 10 10 NO NO NO YES (7) YES (7) YES (7) YES (7) NO YES (7) YES (7) YES (7) YES (7) YES (7) YES (7) YES (7) YES (7)
FCL.615(a)(2
ME-IR (A) ) + Appendix
to IR-ME 6, Subpart
(H) B(9.2) 10 10 NO NO NO YES (7) YES (7) YES (7) YES (7) NO YES (7) YES (7) YES (7) YES (7) YES (7) YES (7) YES (7) YES (7)
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
Multi Crew
Cooperatio
n
MCC/VFR
Modular FCL.735.H(a)(2
Course ) 15 15 NO NO NO NO YES NO YES NO NO YES NO YES YES YES YES YES
MCC/IR
Modular FCL.735.H(a)(1
Course ) 20 20 NO NO NO NO YES NO YES NO NO YES NO YES YES YES YES YES
MCC/VFR
to MCC/IR
Modular
Course FCL.735.H(e) 5 5 NO NO NO NO YES NO YES NO NO YES NO YES YES YES YES YES
AM
C2
FCL.
72(
Instructor 5)(a
Training )
FCL.930.FI YES
FI (H) FI (b)(3) 30 25 NO NO (5) YES (5) YES (5) YES (5) YES (5) NO YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5) YES (5)
FCL.930.IRI YES
IRI (H) IRI (3)(ii) 10 10 NO NO NO (10) YES (10) YES (10) YES (10) NO YES (10) YES (10) YES (10) YES (10) YES (10) YES (10) YES (10) YES (10)
FCL.930.M
CCI MCCI
MCCI (H) (a)(3) 3 3 NO NO NO NO YES (3) NO YES (3) NO YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3)
FCL.930.STI
STI (H) STI 3 3 NO NO NO YES (3) YES (3) YES (3) YES (3) NO YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3) YES (3)
TR TR
FCL.930.SFI programm programm
SFI (H) SFI e +10 e +10 NO NO NO NO NO NO NO NO YES (10) YES (10) YES (10) YES (10) YES (10) YES (10) YES (10) YES (10)
FCL.930.TRI
TRI SP (H) TRI 5 5 NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
FCL.930.TRI
TRI MP (H) TRI 10 10 NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
Examiner
Training
FCL.1000 +
FCL.1015 +
AMC1.FCL.101 2 skills
FE (H) 5 tests NO NO NO NO YES YES YES YES NO YES YES YES YES YES YES YES YES
FCL.1000 +
FCL.1015 +
AMC1.FCL.101 2 skills PARTI PARTIALL PARTIAL PARTIALL PARTI
IRE (H) 5 tests NO NO NO NO ALLY Y LY Y NO NO PARTIALLY ALLY PARTIALLY PARTIALLY PARTIALLY PARTIALLY PARTIALLY
FCL.1000 +
FCL.1015 +
AMC1.FCL.101 2 skills
SFE (H) 5 tests NO NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
FCL.1000 +
FCL.1015 +
AMC1.FCL.101 2 skills
TRE SP (H) 5 tests NO NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
TRE MP (H) FCL.1000 + 2 skills NO NO NO NO NO NO NO NO NO YES YES YES YES YES YES YES YES
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EASA Training Provisions (hours) Maximum FSTD Training Credits (hours)
AIRCREW/
AIROPS Flight Solo FNP FNPT FNPT II FNPT III FTD 3 FFS Level FFS Level FFS Level C,
reference Instructions Dual SPIC (PIC) T1 II MCC FNPT III MCC FTD 1 FTD 2 FTD 2 MCC FTD 3 MCC A/AG B/BG CG, interim C FFS Level D/DG
Type of
Training
FCL.1015 + tests
AMC1.FCL.101
5
FCL.1000 +
FCL.1015 +
AMC1.FCL.101 2 skills
FIE (H) 5 tests NO NO NO NO YES YES YES YES NO YES YES YES YES YES YES YES YES
(*) for each alternate proficiency
check
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Rationale
One of the activities of WP1 is to develop guidance on the use of each FSTD based on its qualification
level, and specifically to:
— identify the FSTD credits for each Part-FCL licence and associated ratings for fixed-wing and
rotary-wing aircraft; and
— for each license and rating issued, define the suitability of the FSTD for each task, as partial,
complete or none; when partial, the proportion or elements to be credited should be specified.
This GM is expected to assist training providers in defining the use of appropriate FSTDs to support the
course syllabus, as well as CA inspectors in evaluating the training programme and the appropriate use
of FSTDs, thus improving standardisation of both crediting and training.
3.2.2 AMC/GM to Part-ARA
1. New AMC1 ARA.FSTD.101(a) is added as follows:
AMC1 ARA.FSTD.101(a) FSTD inspector competency and training
(a) FSTD inspector competencies
(1) For the qualification of inspectors involved in the FSTD domain, the competent authority
should develop criteria identifying the various competencies required from inspectors to
perform their activity. These competencies should be defined for each task concerned,
such as technical and flight inspections, initial qualifications, recurrent evaluations, FSTD
operators’ compliance-monitoring system (CMS) audits, etc.
(2) Considering the areas to be covered and the tasks to be performed, the competent
authority should define the level at which these competencies have to be demonstrated.
(b) FSTD inspector training
(1) The competent authority should define the prerequisites required to be appointed as an
FSTD inspector. The inspectors should have relevant education and/or experience
providing the necessary understanding of the FSTD domain.
(2) The competent authority should prepare a customised training plan for the trainee to
reach the required competency. That plan should include the trainee’s experience and
training needed to develop the required competencies. The initial training should cover
those areas where the competency is not yet achieved (please refer to (b)(1) above). If
certain training items are omitted due to the competency the trainee acquired earlier, the
justification of this omission should be documented.
(3) A formal statement in the training records should be made that the inspector is released
to work as an FSTD technical inspector (TI) or FSTD flight inspector (FI).
(4) Continuation, recurrent and/or refreshment training is necessary to maintain the acquired
competency. The procedures and depth of such training should be defined by the
competent authority.
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2. New GM1 ARA.FSTD.101(a) is added as follows:
GM1 ARA.FSTD.101(a) FSTD inspector competency
FSTD inspector competency levels
(a) Table 1 below shows the desired competencies and observable behaviours. The observable
behaviours should take into account the following elements:
(1) role (technical inspector/flight inspector (TI/FI);
(2) FSTD evaluation type (initial/recurrent);
(3) FSTD type; and
(4) FSTD qualification level.
(b) Please refer to GM1 ARA.FSTD.100(a) for further guidance on the appropriate topics of training.
(c) The levels of inspector’s competencies are defined in ascending order as follows:
(1) awareness (A):
(i) common knowledge or understanding of basic techniques and concepts; and
(ii) no need to complete tasks related to this competence;
(2) familiarisation (F):
(i) level of experience gained in classroom and/or as a trainee on the job;
(ii) acting as a team member, often requiring help from others; and
(iii) understanding and using terminology, concepts, principles, and practices;
(3) working level (W):
(i) successfully completing tasks mostly independently, but help from experts may be
required from time to time;
(ii) understanding and discussing applications and their changes; and
(iii) understanding causal connections and combining different aspects affecting the
subject matter; and
(4) expertise (E):
(i) successfully completing tasks fully independently;
(ii) explaining and taking a stand on difficult questions; and
(iii) participating in the development of reference and resource materials.
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Table 1 — FSTD inspector’s competencies
Core Description of Observable behaviour in FSTD Compliance- Initial and Recurrent
competencies the domain monitoring special evaluation
competency system evaluation
(CMS) audit
Init Rec TI FI TI FI
Theoretical Basic Demonstrates the appropriate
knowledge knowledge and level of understanding of the
understanding following FSTD
of flight features/systems and their
simulation integration:
— motion-cueing system; F F E W W W
— hardware (e.g. F F E W W W
architecture,
real/simulated parts,
interface, host);
— visual (e.g. image F F E W W W
generation, projectors,
optics, collimated/direct
projection);
— software (e.g. basics, W W E W W W
re-hosted/retargeted
avionics, binary- and
loadable-software
aeroplane part solutions)
and configuration control
processes;
— databases (e.g. types and W W E W W W
correlation);
— flight controls/control F A E W W W
loading (e.g.
passive/active,
reversible/non-reversible);
— sound-cueing system (e.g. F A E W W W
limitations,
subjective/objective);
— modelling of aeroplane W F E W W W
performance and handling
characteristics;
— validation data and F A E W W W
validation data roadmaps;
and
— aeroplane system F A E W W W
modelling and data
package types.
Regulatory Understanding Demonstrates the appropriate
knowledge and application level of understanding and
of regulation application of the following:
and procedures — concept and basis of W W E W W W
applicable primary
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reference documents;
— all applicable regulations E W E W W W
(e.g. Regulation (EC)
No 216/2008, Annex VI
(Part-ARA)/Annex VII (Part-
ORA) to Regulation (EU)
No 1178/2011;
— internal work instructions; W W W W W W
— guidance material on
industry best practices E W E W W W
(e.g. RAeS, ARINC, and
20
ICAO publications ).
Teamwork Leading and Demonstrates appropriate
skills management of teamwork ability in the
the oversight following:
process — oversight preparation; E W E E W W
— organising E W E E W W
evaluation/audit
processes and resources;
— briefing and debriefing; E W E E W W
and
— task allocation. E W E E W W
FSTD Knowledge of Demonstrates the appropriate
operations FSTD level of understanding and
acceptance application of the following:
process and — acceptance and testing E W E W W W
operations processes;
— additional equipment (at E W E W W W
qualification level);
— modifications (e.g. AD, E W E W W W
updates);
— maintenance; and E W E W W W
— performance metrics. E W E W W W
FSTD use Knowledge of Demonstrates the appropriate
FSTD use in level of understanding of the
pilot training following:
— FSTD as part of an W W W E F W
approved training course;
— credits vs different FSTD W W W E F W
qualification levels;
— FSTD training, testing and W W W E F W
checking considerations;
and
— air operations and flight W W W E F W
crew implications for
FSTDs.
20
Royal Aeronautical Society, Aeronautical Radio Incorporated, and International Civil Aviation Organization, respectively.
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FSTD Understanding Demonstrates the appropriate
evaluation and application level of understanding and
of FSTD balanced application of the
evaluation following:
components — QTG/objective testing; W W E W W F
— functional/subjective W W E E W W
testing;
— engineering judgement; W W E W W F
— proportionate W W E E W W
decision-making;
— additional training W W E E F W
considerations; and
— categorisation of findings. E E E E W W
CMS FSTD Demonstrates the appropriate
assessment qualification level of understanding and
certificate application of the following:
holder’s CMS — assessment of the E W F F F F
manual management system
assessment and (CMS, safety management
auditing system (SMS));
— auditing techniques; and
— what is expected from the E W F F F F
FSTD operator’s processes. E W F F F F
3. GM2 ARA.FSTD.101(a) is amended as follows:
Draft rule text
GM2 ARA.FSTD.101(a) FSTD inspector training
(a) Prerequisites for FSTD inspectors
When defining the prerequisites required to be appointed as a FSTD inspector, the following
guidance should be taken into account:
(1) the inspectors should have relevant experience providing an adequate understanding of
the FSTD domain in the following areas: flight mechanics and aerodynamics, image
generation systems, electronics/avionics, computer programming, aeroplane systems and
structures, methods of simulation, flight training and methods, and flight operations and
methods;
(2) technical inspectors should hold a degree in aviation engineering; and
(3) AMC4 ARA.FSTD.100(a)(1) describes what is expected from a flight inspector; in addition
to that:
(i) if the flight inspector’s instructor privilege has expired more than three years
before, the practical experience in FSTD evaluation as flight inspector should consist
of at least eight recurrent FFS evaluations within the last three years to remain valid
for the evaluation tasks; and
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(ii) if the flight inspector’s instructor rating has expired more than eight years before,
the flight inspector’s practical experience is not deemed valid for the evaluation
tasks.
(b) Initial training of FSTD inspectors
The competent authority should ensure that the inspectors are competent in the domains they
will be working on. In that respect, the following principles should be taken into account:
(1) inspectors working with experience in initial and special evaluations should have a higher
level of competency than the inspectors with experience in recurrent evaluations;
(2) the training details (e.g. on QTG and subjective testing) should be differentiated between
aeroplane and helicopter FSTD inspectors;
(3) inspectors should be trained, competent and assessed on all those FSTD qualification
levels (i.e. FFS, FTD, FNPT, BITD) they will be working on;
(4) additional competency is required when evaluating specific areas related to special
training considerations such as PBN, UPRT, stall, HUGS, EVS, helicopter special scenarios,
etc.; and
(5) evaluation/audit teams should be composed so that they have the appropriate
competencies.
(c) Any appropriate training methods such as lectures or self-study may be used. The training
material should support the development of competencies. The trainers of FSTD inspectors
should be qualified as described in AMC1 ARA.GEN.200(a)(2) and should have the following:
(1) expert-level competency in their instruction areas;
(2) wide experience in their instruction areas; and
(3) adequate pedagogic skills.
(d) Guidance on the training topics is provided in Table 1 below. The purpose of each training topic
is to establish a certain level of competency in the topics and their associated rules, which the
inspectors need in order to perform their tasks.
Table 1 — Training topics regarding inspectors performing FSTD evaluations and/or audits of FSTD
qualification certificate holders
Area of training Key learning points
(a) International (1) Chicago Convention on International Civil Aviation and ICAO Annexes and
aviation Documents;
safety and (2) European Union (EU) regulations; and
regulation
(3) EASA AMC/GM
environment
(b) Applicable (1) History and generation of PRDs; and
primary (2) Notable differences between different PRDs.
reference
documents
(PRDs)
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Area of training Key learning points
(c) CS-FSTD(A) (1) Structure;
and/or CS- (2) Main contents;
FSTD(H) (as
(3) Definitions of different FSTD levels and their differences; and
applicable)
(4) Specific case of interim Level C.
(d) FSTD cues (1) Human aspects;
(2) Human self-motion perception;
(3) Technology and ways to create and combine cues in FSTDs and;
(4) Positive and negative transfer of training.
(e) Computing (1) History;
and (2) Limitations;
real-time
(3) Simulation loop;
simulation
(4) Host computer;
(5) Nodes; and
(6) Latency/transport delay.
(f) FSTD (1) Computer architecture; and
common (2) Control loading systems.
hardware
solutions
(g) Visual (1) History of visual systems;
system (2) Different projection types;
(3) Image generation;
(4) Visual-database creation;
(5) Visual-system geometry;
(6) Requirements for different FSTD qualification levels; and
(7) Objective visual tests.
(h) Motion (1) Degrees of freedom;
system (2) Generation of motion cues;
(3) Limitations;
(4) Motion algorithms;
(5) Fast Fourier-transformation; and
(6) Power spectral density.
(i) Avionics (1) For generic FSTDs, acceptable system characteristics as in CS-23, CS-25, CS-27, and
simulation CS-29;
(2) Reference documents for avionics (e.g. aircraft flight manual (AFM), flight crew
operating manual (FCOM), data package);
(3) Concept of re-hosting;
(4) Use of real avionics boxes;
(5) Use of simulated avionics;
(6) Pros and cons of different solutions;
(7) Simsoft (Aeronautical Radio Incorporated (ARINC) 610); and
(8) Control system operation.
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Area of training Key learning points
(j) Navigation (1) Principles of common navigation systems operation (e.g. INS, VOR, NDB, DME, ILS,
systems and GNSS, etc.);
their (2) Principles of common interfaces of different generations (e.g. GNSS, FMS,
simulation integrated avionics suites, etc.);
(3) Simulation of navigation databases; and
(4) Performance-based navigation (PBN) procedures and required equipment.
(k) Flight (1) Theoretical parts of pilot type course (e.g. competency-based training (CBT)) of at
operations least two different aircraft types (e.g. turboprop and jet); and
in different (2) Flight training (e.g. in FNPT) to gain understanding of instument flight rules (IFR)
aircraft procedures and multi-engine handling (note: not necessarily targeted for a pilot
license).
(l) Simulation (1) Simulation loop;
of (2) Limits of models;
aerodynamics
(3) Upset simulation and exceedance of simulated envelope; and
and engines
(4) Aircraft stability and associated provisions of CS-23, CS-25, CS-27, and CS-29.
(m) Validation (1) Data gathering;
data (2) Validation data roadmap (VDR) concept, approval and management of updates;
(3) Data package;
(4) Data acceptance;
(5) Operational suitability data (OSD);
(6) CS-SIMD;
(7) Proof of match;
(8) Use of engineering data;
(9) Alternative engine/avionics data; and
(10) Concepts of generic data and footprints.
(n) Qualification (1) History of QTG testing;
test guide (2) Text part of QTG;
(QTG)
(3) Master QTG (MQTG) and its revisions;
(4) Concept of validation;
(5) Tolerances;
(6) QTG testing process;
(7) Integrated testing;
(8) Differences between automatic and manual testing;
(9) Exercises;
(10) Typical problems;
(11) Use of open- and closed-loop controllers; and
(12) Purpose of each individual QTG test (for training on aeroplanes using the RAeS
Aeroplane Flight Simulator Evaluation Handbook, Vol I).
(o) Functions (1) Requirements;
and (2) Methods for effective testing;
subjective
(3) Team cooperation;
testing
(4) Reference documents (e.g. AFM, FCOM, etc.);
(5) Malfunctions testing;
(6) What to expect from generic FSTDs i.e. characteristics of different aircraft classes;
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Area of training Key learning points
(7) Purpose and testing methods of each individual test required by CS-FSTD(A) and/or
CS-FSTD(H) (for training on aeroplanes using RAeS Aeroplane Flight Simulator
Evaluation Handbook, Vol II); and
(8) Additional training considerations (e.g. UPRT and stall recovery, RNP AR, HUGS,
etc.).
(p) FSTD (1) Initial, recurrent and special evaluations;
evaluation, (2) Documentation;
qualification,
(3) Dossier;
and their
processes (4) How to keep evaluation as objective as possible;
(5) Team cooperation;
(6) Conducting all the phases of the evaluation and qualification processes;
(7) Classification and management of findings;
(8) Content, language and form of the certificate and evaluation report;
(9) Maintaining the FSTD qualification; and
(10) Updates and upgrades.
(q) Training, (1) Overview of credits granted by Annex I (Part-FCL) to Regulation (EU) No 1178/2011
testing and and Subpart FC of Annex III (Part-ORO) to Regulation (EU) No 965/2012 ; and
checking (2) OSD reports.
credits
(r) Internal (1) Applicable processes; and
organisational (2) Use of documents.
procedures
and work
instructions
of the
competent
authority
(s) Working as a (1) Participating as an observer on at least three evaluations (all phases);
professional (2) Hands-on evaluation training in FSTD; and
inspector
(3) Acting as a trainee team member under supervision on at least three evaluations
(all phases). The total number of evaluations as a trainee should be determined by
the trainee’s development progress. The evaluations should cover those FSTD
qualification levels (i.e. FFS, FTD, FNPT, BITD) where the inspector is planned to be
working after training.
(t) Soft skills (1) Communication skills;
(2) Conflict management;
(3) Teamwork;
(4) Time management; and
(5) Human factors (HF).
(u) Ability to (1) Justification of findings (i.e. always based on evidence and documentation, such as
exercise requirements, or on operator manuals (OMs), but not on personal preferences);
proper (2) Engineering judgement; and
judgement
(3) Examples of different kind of problems that can be encountered, as well as findings
of different levels and basis for their classification.
(v) Expectations (1) Requirements concerning FSTD OMs, for example:
of FSTD OMs (i) AMC1 ORA.GEN.200(a)(5);
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Area of training Key learning points
(ii) AMC1 ORA.GEN.200(a)(6);
(iii) GM1 ORA.GEN.200(a)(5);
(iv) GM1 ORA.FSTD.100; and
(v) GM2 ORA.FSTD.100; and
(2) Ways of presenting a process (e.g. text, checklists or flow process charts indicating
when, how, and by whom something is performed).
(w) Auditing (a) Concept and definitions of process, audit and inspection (please refer to
process and GM3 ORA.GEN.200(a)(6));
general (b) ’General’ auditing procedures and methods; e.g. preparation, conduction
auditing (interviewing, documentations practices, etc.), reporting, follow-up and closure of
methods an audit; and
and
(c) Practical training on CMS audits. The competent authority should define the
procedures
number of audits in which the trainee should participate as an observer and then as
a trainee team member under supervision before acting as a full audit team
member. The total number of audits as a trainee should be determined by the
trainee’s development progress.
(x) Expectations (1) QTG management process:
of FSTD (i) annual test plan;
operator’s
(ii) approval of results;
processes
and their (iii) actions in case of failed test;
main steps (iv) MQTG and its revisions;
(v) subjective testing process;
(vi) functions testing process;
(vii) annual test plan;
(viii) used documentation; and
(ix) contents of fly-out vs PRDs;
(2) Reliability analysis (e.g. ARINC 433):
(i) measured indicators; and
(ii) targets for indicators;
(3) Personnel training:
initial and recurrent training;
(4) Safety instructions for personnel and users;
(5) Preventive maintenance:
(i) program contents; and
(ii) revisions to the programme as needs for change are identified;
(6) Configuration control system:
(i) management of software, hardware and database changes (e.g. planning,
specification, development, acceptance, documentation);
(ii) practices to test the integrity of an FSTD; and
(iii) software backups;
(7) Defect rectification (i.e. ’snag’ handling):
(i) how users can report defects;
(ii) how users are notified of open defects; and
(iii) prioritisation of defects;
(8) Spare parts and tools management:
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Area of training Key learning points
(i) management of spares;
(ii) how disconnected parts are managed; and
(iii) calibration and checks of applicable tools;
(9) Document control and logs:
(i) archiving of documents;
(ii) retention periods;
(iii) management of document versions (e.g. manuals, logs, instructions, etc.); and
(iv) applicable logs;
(10) Compliance monitoring:
(i) monitoring of regulatory updates;
(ii) planning;
(iii) internal audits;
(iv) internal inspections;
(v) auditors;
(vi) management of findings;
(vii) root cause analysis;
(viii) measurement of effectiveness and continuous improvement; and
(ix) reporting to the competent authority; and
(11) Safety management system (SMS):
(i) recognition and management of FSTD operator’s risks;
(ii) mitigation of negative training; and
(iii) cooperation between FSTD operator and users.
(e) Continuing competence of and recurrent training programme for FSTD inspectors
(1) In order to ensure an acceptable level of practical experience and the retention of the
appropriate skills and routines, the inspectors should have recent experience of
evaluations and audits. If needed, refreshment training should be provided before acting
as a team member. The competent authority should ensure that the inspectors remain
competent (please refer to AMC4 ARA.FSTD.100(a)(1)) in oversight activities, and
recurrent training should be focused on that aspect as well.
(2) The recurrent training should concentrate at least on the following areas:
(i) areas where improvement is needed (please refer to ARA.GEN.200(a)(4));
(ii) new FSTD and aeroplane technologies; and
(iii) changes to rules affecting the FSTD domain.
(3) Some or all of the below-presented methods should be used for recurrent training:
(i) in-house training;
(ii) self-study (professional literature and/or magazines);
(iii) web-based training courses; and
(iv) participation in FSTD conferences.
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Rationale
The current rules are not detailed enough regarding expectations and provisions for the FSTD
inspectors’ competency. The incorporation of AMC1 ARA.FSTD.101(a), GM1 ARA.FSTD.101(a), and
GM2 ARA.FSTD.101(a) into the AMC/GM to Part-ARA will facilitate the standardisation of rules for CAs.
Furthermore, through those new AMC on the competency requirements, as well as GM on how to
acquire that competency, the FSTD industry will be better served, and the level-playing-field objective
met. Some competent authorities have already implemented the training programme of the new GM,
and have provided positive feedback. Generally, it is acknowledged that the FSTD inspectors have a
wide working domain and, therefore, their required competencies should cover an accordingly wide
range of topics/domains.
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4. Impact assessment (IA)
4. Impact assessment (IA)
4.1. What is the issue
This RMT aims to address the technological changes to FSTDs since the related certification
specifications (CS-FSTD(A)) were transposed from the Joint Aviation Regulations (JARs) (see JAR-STD)
back in 2009. While the fidelity of modern FSTDs has in the meantime significantly advanced,
CS-FSTD(A)21 has not encompassed this advancement; therefore some specifications have become
obsolete, not reflecting technological changes that have occurred during this period. In addition, the
fact that CS-FSTD(A) has not kept pace with the technological advancement affects the training of
pilots, whose training needs in some cases cannot be fully addressed through FSTDs qualified in
accordance with the existing CS-FSTD(A) provisions. Therefore, this RMT proposes to amend
CS-FSTD(A), considering both the evolution of FSTD-related technology and the development of pilots’
training needs.
This RMT is interlinked with RMT.0581 ‘Loss of Control Prevention and Recovery Training’ as RMT.0196
supports the regulatory proposal included in Opinion 06/2017 (RMT.0581). In this context, the update
of CS-FSTD(A) should also facilitate UPRT during recurrent and conversion operator training. Current
FSTDs are not qualified to accurately reproduce the approach to stall in certain conditions, nor the
behaviour of the aeroplane when affected by ice. In addition, FCs do not have the correct exposure to
the above-mentioned situations during training due to FSTD fidelity limitations.
Furthermore, this RMT has another major driver, namely supporting both international cooperation
and harmonisation with ICAO. The existing CS-FSTD(A) is not harmonised with ICAO Doc 962522, nor
with FAA 14 CFR Part 60, Change 2, thus impeding the reciprocity of FSTD qualifications on an
international level.
Moreover, this RMT responds to the safety risks identified through SRs proposing regulatory
amendments based on related incidents/accidents. In that respect, the FAA acknowledges that the
current FSTDs’ lack of fidelity or inability to perform certain training tasks may have been a
contributing factor in recent aircraft incidents and accidents23.
Additionally, the FAA supports the adoption of elements of ICAO Doc 9625, Edition 4, which will
eventually lead to a change of FAA 14 CFR Part 60, Change 2.
Overall, this RMT aims to resolve the following issues that could have undesired consequences:
— FSTDs not reflecting the technological advancements due to obsolete CSs; which should be
enhanced to accommodate current and future training needs;
— exposure to safety risks due to the fact that the current FSTDs’ lack of fidelity or inability to
perform certain training tasks may have been a contributing factor in previous incidents and
accidents;
21
Decision N° 2012/010/Directorate R of the Executive Director of the Agency of 4th July 2012 on Certification Specifications for
Aeroplane Flight Simulation Training Devices (https://www.easa.europa.eu/document-library/agency-decisions/ed-decision-
2012010r).
22
Editions 3 and 4 on the FSTD qualification.
23
Please refer to the related FAA Notice of Proposed Rulemaking (NPRM) 14 CFR, Part 60 ‘Flight Simulation Training Device
Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks’.
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4. Impact assessment (IA)
— non-acknowledgement of reciprocity of FSD qualifications between EASA MS and third countries;
and
— financial burden for the industry due to two different standards between the EASA MSs and
third countries, to be followed by data providers, FSTD manufacturers, and FSTD operators.
4.1.1. Safety risk assessment
Please refer to Section 2.1. ‘Why we need to change the rules’.
4.1.2. Who is affected
The following stakeholders are affected by this RMT’s proposed changes:
— Aeroplane OEMs and/or FSTD data providers: they might be affected due to the alignment of CS-
FSTD(A) with CS-SIMD (Certification Specifications for Simulator Data), especially with regard to
OSD.
— FSTD manufacturers: they would need to change FFSs to display UPRT-related tools on the IOS,
as well as update the FSTD modelling with new data.
— FSTD operators: they would update FFSs and evaluate FSTDs.
— EASA and EASA MSs’ CAs: they would need to evaluate and qualify the update of FSTDs.
— AOC holders/pilots/ATOs and DTOs/instructors/examiners: they are the final users in the chain,
bearing the costs both for the update (one-off costs) and the recurrent evaluation of the FSTDs.
This IA, however, does not explore the impact on the aforementioned stakeholders because
different models and strategies may be used when transferring the FSTD operators’ costs to the
AOC holders/training organisations/pilots. Nevertheless, the analysis acknowledges that the
FSTD operators’ costs are paid by the final users (AOC holders/training organisations/pilots) as
per Opinion 06/2017 which proposes the incorporation of UPRT requirements into the European
Union (EU) pilot training regulatory framework.
4.1.3. How could the issue/problem evolve
Currently, 750 different Level C and D FFSs are qualified by EASA MSs’ CAs as well as by EASA as the CA
for operation outside the EASA MSs24. If CS-FSTD(A) is not updated, it would remain behind the
technological evolution and the development of the pilot’s training needs. More important, these FFSs
would not be able to ensure an appropriate level of fidelity to facilitate the implementation of UPRT
requirements, resulting in a gap between the EU pilot training regulatory framework and the current
technologies. This RMT aims to prevent such a gap by aligning the FSTD technical provisions with the
EU pilot training regulatory framework.
Furthermore, if no action is taken, the safety risks identified above would continue to be unaddressed.
The lack of FSTD fidelity and inability to simulate unexpected or abnormal aeroplane situations might
negatively affect safety in the EASA MSs. The value of UPRT training would be minimised or even
compromised.
24
The related data stem from EASA standardisation inspections in January 2017 as well as EASA databases (please refer to the
following link: https://lisstdis.easa.europa.eu/eqstdis/). It is assumed that this is the maximum number of the affected FFSs as
there might be some devices that are already qualified by the FAA in the USA, complying with ICAO Doc 9625.
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4. Impact assessment (IA)
Moreover, if the EU regulatory framework remains unchanged, the fact that third countries align their
rules with the recent updates of ICAO Doc 9625 would likely lead to having two different standards to
be followed by data providers, FSTD manufacturers, and FSTD operators both in EU MSs and third
countries. This poses an unnecessary financial and administrative burden to industry. The
harmonisation of the EU rules with elements of ICAO Doc 9625 would ensure consistent application of
the relevant FSTD provisions when qualifying FSTDs. A (partial) alignment with FAA 14 CFR Part 60,
Change 2 is also considered to be of importance for improving the reciprocity of FSTD qualifications
between EU MSs and third countries.
4.2. What we want to achieve — objectives
Please refer to section 2.2 ‘What we want to achieve — objectives’
4.3. How it could be achieved — options
The following options have been identified to solve the issues explained above.
Table 2 — Selected policy options
Option No Short title Description
0 Do nothing No policy change (no change to the existing CS-FSTD(A)). The
issues identified in Section 1.1 would remain unchanged. The
value of the training would be minimised/compromised, but the
training itself would still be allowed.
1 Develop UPRT IOS This would provide mandatory provisions for updating FSTDs to
feedback tools support UPRT, in accordance with applicable Part-FCL
requirements and ICAO Doc 10011 guidance. This Option includes
technical and qualification provisions for operators to install IOS
feedback tools that support UPRT.
The proposed amendments would be applied to new and existing
FSTDs.
2 Option 1 + increase In addition to Option 1, this would provide mandatory provisions
FSTD fidelity to for updating FSTDs to support approach-to-stall training.
better facilitate Approach to stall is conducted today; however, the simulation
approach-to-stall fidelity provisions may not always be appropriately validated:
training
— current objective testing provisions only validate the take-off
(second-segment climb) and either approach or landing
configuration; Option 2 proposes to extend the testing to
include the cruising configuration, as well to require
validation of both the approach and landing configurations;
and
— additionally, current objective testing provisions do not
validate the effects of icing on stall speeds, therefore, this
Option includes considerations for the proper aerodynamic
modelling of ice in accordance with the ICAO Doc 9625
guidance as well as for the effects of icing on stall warning,
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Option No Short title Description
stall identification, and aerodynamic stall.
The new provisions would be applicable both to new and existing
FSTDs.
Based on the initial analysis of all options, the following options were discarded, as explained in Table 3
below:
Table 3 — List of discarded policy options
Title Rationale for being discarded
Mandate to update The updated CS-FSTD(A) would apply both to new FSTDs (ready for the market
CS-FSTD(A) for new and after the new CS-FSTD (A) is issued) and existing FSTDs (Level C and D FFSs
existing FSTDs qualified by EASA or EASA MSs’ CAs). This option was discarded as the restrictions
of ICAO Doc 10011 do not allow to apply it to existing FSTDs.
Mandate to update The updated CS-FSTD(A) would only apply to new devices, ready for the market
CS-FSTD(A) for new after the CS-FSTD(A) is issued. This option was discarded as the restrictions of
devices ICAO Doc 10011 do not allow to apply it to new devices.
Partially align with ICAO This option incorporates all of the provisions proposed by the previous two
Doc 9625, Edition 4 discarded options and allows for alignment with FAA 14 CFR Part-60, Change 2
provisions. It would apply to both new and existing devices. It was discarded as it
goes beyond the scope of WP1 (please refer to TOR RMT.0196, Issue 1). It may be
considered at the WP2 stage.
Fully align with ICAO This option provides for more effective and efficient means to update FSTD
Doc 9625, Edition 4 standards and qualification provisions. It would apply to both new and existing
devices. It was discarded as it goes beyond the scope of WP1. It may be
considered at the WP2 stage.
4.4. Methodology and data
The objective of this IA is to assess the costs and benefits of the different options for various
stakeholders. The scope of the IA is limited to that of WP1 (please refer to Section 2.3 for further
details).
The other two WPs (WP2 and WP3) will be developed after concluding WP1, and the related IAs will be
similarly incremented.
For this IA, only Level C and D FFSs, qualified by EASA and EASA MSs’ CAs are considered as those
devices will be mainly affected by the proposed changes. During the development of the IAs for WP2
and WP3, data on other devices (FTD, FNPT, BITD) will also be used to feed the analysis. The IA does
not take into account devices qualified by other regulators (e.g. FAA-qualified FFSs).
Out of the scope of this IA is the update of the FSTD inspector competencies framework as this NPA
proposes amendments also to Part-ARA which are out of the scope of the CS-FSTD(A) update. The
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4. Impact assessment (IA)
related recommendations may be considered further in another RMT. Therefore, the IA does not
analyse the impact of proposed changes on the FSTD inspector competencies framework.
4.4.1. Data collection
This IA has been performed using the following data sources:
— data from OEMs, data package providers, FSTD manufactures, FSTD operators, CAs, airlines, as
members of RMG RMT.0196;
— 2017 data from the EASA standardisation inspections, on the number of active FFSs qualified by
the EASA MSs’ CAs;
— 2017 data from the EASA database on Level C and D FFSs qualified by EASA25; and
— World Simulator Census 201526.
4.4.2. Methodology applied
The IA was developed combining various IA tools:
(a) Multi-criteria analysis (MCA)
MCA covers a wide range of techniques that aim at combining positive and negative impacts into
a single framework for an easier comparison of scenarios. The scoring of the impacts uses a scale
of – 5 to + 5 to indicate, respectively, the negative and positive impacts of each option (ranging
from ‘very low’ to ‘very high’ negative/positive impacts). The intermediate scores are termed
‘low, ‘medium’, and ‘high’, providing a total of five levels of all impacts in each direction (positive
and/or negative). A ‘no impact’ score is also possible.
Table 4 — Scoring of impacts
Positive Score Negative Score
impact impact
+5 Very high positive impact –5 Very high negative impact
+4 High positive impact –4 High negative impact
+3 Medium positive impact –3 Medium negative impact
+2 Low positive impact –2 Low negative impact
+1 Very low positive impact –1 Very low negative impact
0 Neutral/insignificant 0 Neutral/insignificant
25
https://lisstdis.easa.europa.eu/eqstdis/
26
https://www.halldale.com/sim-census
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4. Impact assessment (IA)
Table 5 — Economic scale
Competent OEMs/data FSTD FSTD
authorities package manufacturers operators
(CAs) providers
Turnover 1 000 52 800 3 000 4 800
(in million EUR)
Qualitative Score Turnover
description impact
Very high +/– 5 > + 1.5 % 15 792 45 72
impact
1-1.5 % 15 792 792 72
High impact +/– 4 0.8-1 % 10 528 30 48
0.6-0.8 % 8 422.4 24 38.4
Medium +/– 3 0.4-0.6 % 6 316.8
18 28.8
impact
0.2-0.4 % 4 211.2 12 19.2
Low impact +/– 2 0.1-0.2 % 2 105.6 6 9.6
0.05-0.1 % 1 52.8 3 4.8
Very low +/– 1 0.02-0.05 % 0.5 26.4
1.5 2.4
impact
0-0.02 % 0.2 10.6 0.6 0.9
No impact 0 0 0 0 0
(b) Case studies
Due to the different business strategies/models that FSTD manufacturers/operators might apply
to comply with the proposed rules, the impacts are illustrated and visualised more realistically
through examples of impacts of the different options for different stakeholders.
(c) Impacts analysed
The impacts have been analysed using various criteria: safety, environmental, social, economic,
proportionality and General Aviation (GA). These criteria are derived from the main objectives of
the Basic Regulation. The impact on harmonisation with the FAA, ICAO and other organisations is
analysed using the economic criterion as harmonisation has economic implications in terms of
costs and benefits.
In addition, the following important remarks on methodology should be taken into consideration:
— Each option has been analysed separately, in comparison with Option 0. As Option 2 is a
combination of Option 1 and some additional proposals, it has been considered in the analysis as
a combination of the costs/benefits of Option 1 with those of the additional proposals (e.g. icing
model implementation).
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— The IA has been performed using a compensatory method27 for assessing the impacts. This
method allows a trade-off between different impact assessment criteria, e.g. low scores on one
criterion may be compensated by high scores on another. Furthermore, the same principle is
applied to the assessment of impacts for different stakeholders within one criterion (e.g. safety,
social, economic, etc.).
4.5. What are the impacts
4.5.1. Safety impact
Option 0 — Do nothing
Current safety issues remain unchanged, as mentioned in the issue analysis. The safety risks identified
above would continue to be unaddressed. The lack of FSTD fidelity and inability to simulate
unexpected or abnormal aeroplane situations might negatively affect safety in the EASA MSs. The
value of UPRT training would be minimised or even compromised. The safety level score is assessed as
neutral (0) to negative.
Option 1 — Develop UPRT IOS feedback tools
The safety level is expected to increase by providing instant feedback to the instructor on how
recovery was performed. However, the increase is assessed as low since the feedback to the instructor
would not include reporting on major safety issues, especially in abnormal-recovery cases. Therefore,
the overall safety benefits would be very marginal.
Option 2 — Option 1 + increase FSTD fidelity to better facilitate approach-to-stall training
Safety would improve more than through Option 1 because the objective testing provisions would
validate not only the cruising configuration, but also the approach and landing configurations. Current
FSTDs are not qualified to accurately reproduce the approach to stall in certain conditions, nor the
behaviour of the aeroplane when affected by ice.
As mentioned in the issue analysis, EU AOC holders estimated that in 6 (2 fatal accidents, 4 serious
incidents) out of the 58 cases in the period 2012-2016, the training of the flight crew in an enhanced-
capability FSTD would have provided them with additional resources, thus facilitating the detection of
approach to stall. In 4 cases (serious incidents) out of the 6, accretion of ice modified the aerodynamic
performance of the aeroplane. In the other 2 cases (fatal accidents), the flight crew was neither able to
detect the approach to stall nor to provide efficient flight control inputs to recover from the stall. In all
cases, a clear indication of an imminent stall, such as buffeting, did not lead the fight crew to take
correct action.
It is expected that the updated FSTD testing provisions will validate the effects of icing on stall speeds,
in accordance with the ICAO Doc 9625 guidance, as well as the effects of icing on stall warning, stall
identification, and aerodynamic stall. The flight crew will be exposed to such situations during training
in order to be able to appropriately react when confronted with these situations in real operations.
Therefore, the training of flight crew in enhanced-capability FSTDs to facilitate the approach-to-stall
training is expected to provide a clear safety benefit, especially in the simulation of icing conditions.
27
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4. Impact assessment (IA)
Overall, this option is expected to improve flight crew training, as a safety barrier, to mitigate the risk
of LOC-I. The overall safety impact is considered to be positive although the fidelity of the FSTD used by
flight crew for the type rating or refresher training may have only a limited contribution in preventing
LOC-I. Nevertheless, the strengthening of this barrier is expected to facilitate the early detection of the
aeroplane upset safety issues and, hence, prevent the LOC-l; therefore, the overall safety impact of
Option 2 is considered to be medium positive.
Based on the analysis above, the assessment of safety impacts is summarised in Table 6 below:
Table 6 — Safety impacts per option
Criterion Option 0 Option 1 Option 2
Do nothing Develop UPRT IOS feedback Option 1 + Increase FSTD fidelity to
tools better facilitate approach-to-stall
training
Safety Safety issues Limited safety benefit due to Improved safety level due to the
remain unchanged unchanged modelling/motion- validated cruising configuration, in
cueing fidelity of FSTDs. addition to the approach and landing
Better awareness of instructors, configuration, as well as due to the
which facilitates UPRT. validation of the effects of icing on stall
warning and identification.
Strengthened training of flight crew to
prevent and/or mitigate the risk of
LOC-I.
0 +2 +3
Neutral Low positive impact Medium positive impact
4.5.2. Environmental impact
N/a
4.5.3. Social impact
Option 0 — Do nothing
No social impact is expected from Option 0.
Option 1 — Develop UPRT IOS feedback tools
Through this Option, knowledge and skills of the pilots in handling recognition and prevention of, as
well as recovery from, upset situations would be improved, by updating FSTD provisions in accordance
with the applicable Part-FCL requirements, and ICAO Doc 10011 guidance.
This Option would have a positive impact for instructors receiving better feedback on the performance
of the pilots through the installed IOS feedback tools. The instructor competence would further
increase due to the newly introduced UPRT course.
However, the overall social impact is considered to be very low as the pilots would still not be trained
in FSTDs qualified to accurately reproduce the approach to stall in certain conditions or the behaviour
of the aeroplane when affected by ice.
Based on the analysis above, the overall social impact of Option 1 is scored with + 1 (very low positive).
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4. Impact assessment (IA)
Option 2 — Option 1 + increase FSTD fidelity to better facilitate approach-to-stall training
Apart from the social benefits of Option 1, the additional changes included in this option would have
even more social benefits for pilots.
The pilots would receive training in an environment with higher-fidelity FSTDs, hence, be better
prepared for unexpected situations and improve their resilience. As mentioned in the issue analysis, in
3 out of 10 fatal accidents and serious incidents28, the flight crew was unable to detect the approach to
stall and apply efficient flight control inputs to recover from the stall. In those cases, it was
acknowledged that the flight crew had suffered a cognitive saturation, making it difficult to process
sensorial information. Therefore, the increased FSTD fidelity to validate the take-off, approach or
landing configuration, as well as the effects of icing on stall speeds, would expose flight crews to those
situations during training.
Apart from pilots, instructors would also be positively affected by the higher FSTD fidelity when
instructing pilots in properly reacting to an approach to stall in certain conditions.
Table 7 — Social impacts per option
Criterion Option 0 Option 1 Option 2
Do nothing Develop UPRT IOS feedback tools Option 1 + increase FSTD fidelity to
better facilitate approach-to-stall
training
Social No change Improved knowledge and skills of Considerably improved training for
instructors in terms of training and pilots due to the increased FSTD
evaluating the UPRT outcome. fidelity, facilitating the approach to
However, this alone would have a very stall in certain conditions. Pilots
low impact due to the existing would therefore be better prepared
limitations of FSTDs in supporting the to cope with such situations in real
approach-to-stall training in certain operations.
conditions, including in icing conditions.
0 +1 +2
Neutral Very low positive impact Low positive impact
4.5.4. Economic impact
The economic impacts are analysed for all stakeholder groups, starting with the OEMs/data package
providers and ending with the airlines, ATOs, and pilots, who will benefit from the improved FSTD
fidelity.
The economic impacts have been analysed on the following assumptions:
— OEM/data package providers would have to cover the costs for updating the FSTD data packages
with required data. For Option 1, there would be negligible costs related to the instructor
feedback tools as the data package would remain within the existing training envelope.
However, for Option 2, there would be costs related to the updating of data packages, which are
considered in the analysis.
28
Review of the loss of control CAT aeroplane accidents and serious incidents worldwide between 2012 and 2016.
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4. Impact assessment (IA)
— FSTD manufacturers would bear the costs for the development of IOS UPRT display tools
(Option 1), and for the deployment of FSTD modelling and its update with new data (Option 2) in
the existing/new devices. The FSTD manufacturers’ costs for the development of FSTD modelling
are analysed as a lump sum at the manufacturer’s level. The reason is that every manufacturer
may have its own strategy to group the FSTDs into categories depending on the specific costs
incurred in each case, the age of the FSTD (the older FSTDs typically require more effort to be
updated), etc.
— FSTD operators would have to pay for the FFS update and the evaluation of FSTDs (for normal
and, in some cases, for special evaluations). It is assumed that they would be the most affected
stakeholders bearing the overall costs. However, these costs would eventually be incurred by the
AOC holders, ATOs, pilots, passengers, etc. as UPRT training would require the use of updated
FSTDs with higher fidelity, as proposed by Opinion 06/2017 amending Part-FCL. Therefore, the
FSTD operators would bear the costs only up to a certain point, depending on the business
model and strategy of the AOC operators, ATOs, etc. For the IA, the overall economic impact is
analysed up to the FSTD operators’ stage.
— EASA MSs’ CAs would bear the costs for the updated training of inspectors based on the new
requirements, as well as possible additional costs for the evaluation and qualification of the
updated FFSs (normal or special evaluations in some cases). It is assumed that one hour of the
CA’s time to evaluate/quality an FFS costs EUR 230.
— In the analysis, the 5 major FSTD manufacturers have been taken into account, making up the
majority of the FFS market.
— There are in total 755 Level C and D FFSs, qualified by the EASA MSs’ CAs29 or by EASA as the
CA30. This is the maximum amount of devices to be qualified, as some devices might be located
in the USA and qualified by FAA. They will need to be updated to respond to the new
requirements if used to provide EASA-qualified training.
— In the coming three years, new FFSs are expected in the market (indicatively, 150 Level C and D
FFSs), equipped with the updated FSTD model. It is assumed that they would be proportionally
distributed on a yearly basis, e.g. 50 FSSs per year.
— The costs are analysed within one year’s time after the date of applicability of the updated rules.
— All FFSs (existing and new ones) in the market are expected to be updated within a one year’s
period31. These assumptions are based on the transition period that would be granted for the
implementation of the current draft rules, which is proposed to be one year after the date of
applicability of the new CS-FSTD(A). Nevertheless, it is assumed that not all FFSs would be
updated in that transition year. Depending on the strategy of the FSTD operator, this process
may take two years or even more.
— The costs for every type of stakeholder are compared with each stakeholder’s turnover in order
to indicate the impact of the costs per type of stakeholder.
29
2017 data from the EASA standardisation inspections (January 2017) on the number of active FFSs qualified by EASA MSs’ CAs.
30
2017 data from the EASA database on EASA-qualified Level C and D FFSs (https://lisstdis.easa.europa.eu/eqstdis/).
31
However, a transition period of two years would be granted.
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4. Impact assessment (IA)
— The overall costs to be borne by the FSTD operators are compared with the turnover of the
affected industry in general, following the assumption above that those costs would be incurred
by the ATOs/airlines/pilots.
Option 0 — Do nothing
No economic impact is expected.
Option 1 — Develop UPRT IOS feedback tools
Direct costs/economic impact for OEMs/data providers
The economic costs for OEMs/data providers for providing data for IOS UPRT display tools would be
negligible as the data package would remain within the existing training envelope. The impact of this
Option is considered to be very low negative.
Impact for OEMs/data providers (in million EUR) Option 1
(in million EUR)
Total one-off cost for updating the FSTD data package with required
data (for new aeroplanes, as well as old ones with or without data) 2.4
32
33
Total industry turnover (OEMs) 52 800
Impact in % 0.00 %
Negligible
Direct costs/economic impact for FSTD manufacturers
As mentioned above, the costs for modifying FSTDs to support UPRT IOS tools might be grouped in
several categories with specific costs. For simplicity reasons, the costs are considered as a lump sum
per manufacturer.
Impact for FSTD manufacturers Option 1 (in EUR)
One-off development costs per manufacturer for updating the FSTDs’ 690 250
devices
Number of manufacturers 5
Recurrent costs 0
Total costs for the industry 3 451 250
Total FSTD manufacturers turnover 3 000 000 000
Impact in % 0.12 %
Low negative
32
The amount might be lower as the OEMs/data providers could not explicitly differentiate between the costs of Option 1 and those
of Option 2.
33
Please refer to Table 4 —Scoring of impacts.
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4. Impact assessment (IA)
Direct costs for the FSTD operators
The table below presents the direct costs to be borne by FSTD operators to comply with the updated
rules.
Impact for FSTD operators Option 1 (in EUR)
1. One-off costs
1.1. Additional recurrent evaluation per FFS 1 100.00
2. Recurrent costs
2.1. Additional costs during standard recurrent evaluations (one hour in 230
addition to evaluate the FFS)
3. Total unit cost per FFS 1 330
4. Number of existing active EASA-qualified Level C and D FFSs in EASA 755
MSs and third countries
4.1. FFSs qualified by EASA MSs — Source: EASA standardisation 426
inspections, January 2017
4.2. FFSs qualified by EASA MSs — Source: EASA database 329
(https://lisstdis.easa.europa.eu/eqstdis/)
5. Number of new FFSs in the market in 2018 (projection) 50
6. Number of all FFSs in 2018 (sum of 4. + 5. (projection)) 805
Total costs for the industry (unit cost multiplied by the number of FFSs) 1 070 650
As mentioned above, FSTD operators would bear the overall costs, starting from the costs for the
OEMs/data providers and ending with their direct costs for evaluating the FFSs. Therefore, the IA
analysed the overall impact of the costs for FSTD operators. The FSTD operators turnover is used as a
reference to illustrate the overall impact of these costs as it is assumed that the costs will be incurred
at a later stage by the users of the updated FFSs (airlines, ATOs, pilots).
Overall costs/economic impact for FSTD operators
Overall impact on FSTD operators
Option 1 (in EUR)
Direct costs for OEMs/data providers 2 400 000
Direct costs for FSTD manufacturers 3 451 250
Direct costs for FSTD operators 1 070 650
Overall costs for FSTD operators 6 921 900
Total FSTD operators turnover 4 800 000 000
Impact in % 0.14 %
Low
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4. Impact assessment (IA)
Economic impact for CAs
Option 1, the CAs would have additional costs for the evaluation and qualification of the updated FFSs.
It is assumed that no training would be needed for the CA inspectors. As regards the time needed for
the evaluation and qualification of updated FFSs, it is assumed that the evaluation of a UPRT FFS
update would take five working hours.
Impact for CAs Option 1 (in EUR)
Training of inspectors 0
One-off costs for evaluation and qualification of updated FFSs 1 150
Total costs for CAs for evaluation and qualification of 755 updated FFSs 868 250
Overall costs for CAs 868 250
34
Total budget for all EASA MSs’ CAs 1 000 000 000
Costs for the CAs as % of their budget 0.09 %
Low
Summing up the economic impacts for all stakeholders, the overall economic impact of Option 1 would
be low negative. The score of Option 1 is – 2.
Option 1
Costs per stakeholder Costs as % of the turnover
Total costs (in EUR)
per stakeholder
Total costs for OEMs/data providers 2 400 000 Negligible
0.12 %
Total cost for FSTD manufacturers 3 451 250
Low negative
Total costs for FSTD operators 1 070 650 See the cell below
0.14 %
Overall costs to be borne by FSTD operators 6 921 900
Low negative
0.09 %
CAs costs 868 250
Low negative
Total costs 7 790 150 Low negative
Option 2 — Increase FSTD fidelity to better facilitate approach-to-stall training, in addition to Option 1.
Direct costs/economic impact for OEMs/data providers
The economic impact for OEMs/data providers for updating the FSTD modelling in order to
accommodate the enhanced approach-to-stall training, as well as for developing and deploying IOS
display tools, is expected to be a very low negative one.
34
Please refer to Table 4 — Scoring of impacts.
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4. Impact assessment (IA)
Impact for OEM/data providers Option 2
(including Option 1)
(in million EUR)
35
Total one-off cost for updating FSTD data package with required data 12
(for new aeroplanes, as well as old ones with or without data)
Total industry turnover (manufacturers) 52 800
Impact in % (manufacturers) 0.02 %
Very low
Direct costs/economic impact for FSTD manufacturers
The same approach as for Option 1 was followed. The costs were analysed per manufacturer and
multiplied by the number of manufacturers, giving the overall costs for the industry.
Impact for FSTD manufacturers Option 1 Option 2 Option 2
(only for icing (including
model validation) Option 1)
One-off development costs per manufacturer 690 250 705 650 1 395 900
for updating the software for their FSTDs
Number of manufacturers 5
Recurrent costs 0
Total costs for the industry 6 979 500
Total FSTD manufacturers turnover 3 000 000 000
Impact in % 0.23 %
(low to medium)
Direct costs for FSTD operators
In contrast to Option 1, FSTD operators would need to perform as a one-off cost a special evaluation of
the FSTDs in conjunction with the normal evaluation. Consequently, there would be additional
recurrent costs for the extra three hours during standard recurrent evaluation.
Impact for FSTD operators Option 2
(including Option 1)
(in EUR)
1. One-off costs
1.1. Special evaluation per FSTD in conjunction with a normal recurrent
evaluation 10 000
2. Recurrent costs(
2.1. Additional costs during standard recurrent evaluations 690
3. Total costs per FSTD 10 690
4. Number of existing active EASA-qualified Level C and D FFSs in EASA MSs and
third countries 755
35
The amount might be lower as the OEM/data providers could not explicitly differentiate between the costs of Option 1 and those
of Option 2.
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4. Impact assessment (IA)
4.1. FFSs qualified by EASA MSs — Source: EASA standardisation inspections,
January 2017
4.2. FFSs qualified by EASA MSs — Source: EASA database
(https://lisstdis.easa.europa.eu/eqstdis/)
5. Number of new FSSs in the market in 2018 (projection) 50
6. Number of all FSSs in 2018 (sum of 4 + 5. (projection)) 805
Total costs for the industry 8 605 450
In addition, as mentioned under Option 1, FSTD operators would bear the overall costs, therefore, the
IA analysed the overall impact of the costs for FSTD operators. The FSTD operators turnover is used as
a reference to illustrate the overall impact of these costs as it is assumed that the costs will be incurred
at a later stage by the users of the updated FFSs (airlines, ATOs, pilots).
Overall costs/economic impact for FSTD operators
Overall impact on FSTD operators Option 2 (in EUR)
Direct costs for OEMs/data providers 12 000 000
Direct costs for FSTD manufacturers 6 979 500
Direct costs for FSTD operators 8 605 450
Overall costs for FSTD operators 27 584 950
Total FSTD operators turnover 4 800 000 000
Impact in % 0.57 %
Medium
Economic impact for CAs
Under Option 1, the CAs would have additional costs for the training of the staff as well as for the
evaluation and qualification of the updated FFSs. As regards the training, it is assumed that each CA
would train up to three inspectors for a total amount of EUR 10 000 per CA, with total training costs of
EUR 310 000 for all EASA MSs’ CAs. As regards the time for the evaluation and qualification of the
updated FFSs, it is assumed that 15 working hours are needed for the special evaluation of an
approach-to-stall update, including the UPRT update.
Impact for CAs Option 2 (in EUR)
Training of inspectors
(approximately 15 hours for three inspectors per CA) 310 000
Costs for CAs for evaluation and qualification of the updated FSTDs (per FSTD) 3 450
Number of existing FSSs 2 604 750
Total costs for the CAs 2 914 750
Total budget for all EASA MSs’ CAs 1 000 000 000
Costs for the CAs as % of their budget 0.29 %
Low to medium
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4. Impact assessment (IA)
Summing up the economic impacts for all stakeholders, the overall economic impact of Option 2 would
be medium negative. The score of Option 2 is – 3.
Option 2
Costs per stakeholder Costs as % of the turnover per
Total costs (in EUR)
stakeholder
0.02 %
Total costs for OEMs/data providers 12 000 000
Very low negative
0.23 %
Total cost for FSTD manufacturers 6 979 500
Low to medium negative
Total costs for FSTD operators 8 605 450 (see the cell below)
0.57 %
Overall costs to be borne by FSTD operators 27 584 950
Medium negative
0.29 %
CAs costs 2 914 750
Low to medium negative
Total costs 30 499 700 Medium negative
The table below illustrates the economic impacts per stakeholders for both Option 1 and Option 2:
Option 1 Option 2
Costs per stakeholder Costs as % of the
Total costs Total costs Costs as % of the
turnover per
(in EUR) (in EUR) turnover per stakeholder
stakeholder
Total costs for 0.02 %
2 400 000 Negligible 12 000 000
OEMs/data providers Very low negative
Total costs for FSTD 0.12 % 0.23 %
3 451 250 6 979 500
manufacturers Low negative Low to medium negative
Total costs for FSTD See the cell
1 070 650 8 605 450 See the cell below
operators below
Overall costs to be borne 0.14 % 0.57 %
6 921 900 27 584 950
by FSTD operators Low negative Medium negative
0.09 % 0.29 %
CAs costs 868 250 2 914 750
Low negative Low to medium negative
Total costs 7 790 150 Low negative 30 499 700 Medium negative
Alignment/Harmonisation with the FAA/ICAO
The economic analysis includes also the assessment of the impacts of the alignment with FAA 14 CFR
Part 60, Change 2 and ICAO Doc 9625.
Option 1
This option does not propose full alignment with the requirements of the aforementioned documents.
Therefore, it may have some negative impact for FSTD operators operating dual-qualified FSTDs. These
operators would be required an additional FSTD qualification by their CA/EASA, to meet the applicable
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4. Impact assessment (IA)
EU provisions. Consequently, this could possibly delay the amendment of EU-US BASA Annex 4 ‘FSTD’
as this document is based on FAA 14 CFR Part 60, Change 1.
Option 2
This option proposes to closely align with the FAA 14 CFR Part 60, Change 2 and ICAO Doc 9625
requirements. It would ensure harmonisation with the FAA and ICAO, by facilitating enhanced
approach-to-stall training, which would have a negative impact for FSTD operators operating
dual-qualified FSTDs. To reduce this possible negative impact as well as the administrative burden for
the FSTD operators, this Option includes the following possibility for operators who wish to conduct
full-stall training: the CA would perform a special evaluation in order to ensure that the FSTD has the
appropriate fidelity to provide full-stall training, thereby mitigating the effect of negative training. As
Option 1, it could also possibly delay the amendment of EU-US BASA Annex 4 ‘FSTD’ as the document is
based on FAA 14 CFR Part 60 Change 2, Change 1.
Table 8 — Economic impacts per option
Criterion Option 0 Option 1 Option 2
Do nothing Develop UPRT IOS feedback tools Option 1 + Increase FSTD fidelity to better
facilitate approach-to-stall training
Economic No impact is The overall impact is considered to The overall impact is considered to be
expected. be low negative. medium negative.
0 –2 –3
4.5.5. General Aviation (GA) and proportionality
Option 0 — Do nothing
No impact is expected.
Option 1 — Develop UPRT IOS feedback tools
The option would affect only business aviation, not the full GA community. The latter would not be
affected at all. The business aviation industry would be affected in the same way as CAT operators. The
GA and proportionality impact is analysed in terms of its economic impact.
Option 2 — Option 1 + Increase FSTD fidelity to better facilitate approach-to-stall training
The same impact as under Option 1 is expected.
Table 9 – GA and proportionality impacts per option
Criterion Option 0 Option 1 Option 2
Do nothing Develop UPRT IOS feedback tools Option 1 + Increase FSTD fidelity
to better facilitate
approach-to-stall training
GA and No impact is The impact on the business aviation Same as under Option 1.
proportionality expected. industry is analysed in terms of its
economic impact. Business aviation is
treated as CAT operations. There is no
impact on the other segments of the
GA community.
0 0 0
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4. Impact assessment (IA)
4.6. Conclusion
The table below summarises the impacts of all options.
Table 10 — Assessment of all options
Criteria Option 0 Option 1 Option 2
Do nothing Develop UPRT IOS Option 1 + Increase FSTD
feedback tools fidelity to better
facilitate
approach-to-stall
training
Safety 0 +2 +3
Social 0 +1 +2
Economic 0 –2 –3
GA and proportionality 0 0 0
TOTAL 0 +1 +2
The IA shows that Option 2, proposing mandatory provisions for the update of FSTDs to support
approach-to-stall training in certain conditions, as well as for the development and deployment of IOS
feedback tools, is the most beneficial option.
This option would strengthen the training of the flight crews (safety barrier in the system) to facilitate
early detection of aeroplane upset safety issues, thus preventing LOC-I.
It would also ensure full implementation of the UPRT requirements and provisions as part of the EU
pilot training regulatory framework, proposed by Opinion 06/2017. It would result in positive social
benefits for the pilots receiving training in higher-fidelity FSTDs; this way, they would be better
prepared for unexpected situations and improve their resilience.
As regards the economic impact, Option 2 is expected to cost all stakeholders a total of approximately
EUR 30 million for updating in accordance with the new provisions the FFSs currently on the market.
The overall impact is considered to be medium negative in case most of the FFSs are updated within
one year’s time after the date of applicability of the new rules. However, the economic impact would
be lower if the cost for updating the existing FSTDs would be spread over a longer transition period,
e.g. of two years or more.
Option 2 is cost-efficient as the total costs of approximately EUR 30 million to be borne by FSTD
operators, if spread over one year (approximately EUR 40 000 per FSTD), would compensate for the
cost of at least one catastrophic accident which is estimated at EUR 170 million36.
This option envisages alignment to a large extent with FAA 14 CFR Part 60, Change 2 and ICAO
Doc 9625. It would ensure harmonisation with FAA and ICAO, by facilitating enhanced
approach-to-stall training. However, it also acknowledges that there might be a negative impact for
FSTD operators operating FSTDs qualified in compliance with FAA requirements. To reduce this
possible negative impact as well as the administrative burden for the FSTD operators, Option 2
includes the following possibility for operators who wish to conduct full-stall training: the CA would
36
According to the EASA assessment of the benefits per accident, the average cost of a catastrophic event is estimated at
EUR 162.6 million.
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4. Impact assessment (IA)
perform a special evaluation in order to ensure that the FSTD has the appropriate fidelity to provide
full-stall training, thereby mitigating the effect of negative training.
Finally, the IA recommends the following:
— mandate provisions for updating FSTDs to support enhanced approach-to-stall training as well as
for developing UPRT IOS feedback tools (Option 2);
— provide industry with a transition period of two years after the date of applicability of the rules,
to update the existing FSTDs on the market; and
— plan a robust monitoring and evaluation of the effects of the proposed rules, based on the
results of training and FSTD updates, in order to assess their effectiveness in improving aviation
safety.
Question to stakeholders
Stakeholders are also especially invited to comment on this IA and to provide any other quantitative information
they consider necessary to bring to the attention of EASA. As a result, the relevant parts of the IA might be
adjusted on a case-by-case basis.
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5. Proposed actions to support implementation
5. Proposed actions to support implementation
EASA is committed to providing support for the implementation of the new CS-FSTD. The range of
activities developed in this regard will vary depending on the complexity of the rules, the affected
stakeholders, as well as on the amount and type of resources allocated by stakeholders to ensure
compliance with the new rules.
The feedback from stakeholders is crucial in determining the type of activities that will be developed.
In that respect, any constructive feedback provided via different communication channels (e.g. regular
meetings with the EASA Advisory Bodies (ABs), development of a related ‘frequently asked questions’
page on the EASA website, or a combination of the above) will be taken into consideration once the
new rules are applicable.
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6. References
6. References
6.1. Affected regulations
N/a
6.2. Affected decisions
— Decision N° 2012/010/Directorate R of the Executive Director of the Agency of 4 July 2012 on the
Certification Specifications for Aeroplane Flight Simulation Training Devices
— Decision N° 2011/016/R of the Executive Director of the European Aviation Safety Agency of
15 December 2011 on Acceptable Means of Compliance and Guidance Material to Commission
Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and
administrative procedures related to civil aviation aircrew pursuant to Regulation (EC)
No 216/2008 of the European Parliament and of the Council ‘Acceptable Means of Compliance
and Guidance Material to Part-FCL’
— Decision N° 2012/006/ Directorate R of the Executive Director of the Agency of 19th April 2012
on Acceptable Means of Compliance and Guidance Material to Commission Regulation (EU)
No 1178/2011 of 3 November 2011 laying down technical requirements and administrative
procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the
European Parliament and of the Council ‘Acceptable Means of Compliance and Guidance
Material to Part-ARA’
6.3. Other reference documents
— Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008
on common rules in the field of civil aviation and establishing a European Aviation Safety Agency,
and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and
Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1), in particular Article 21(2)(b)(i) and (ii)
— Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical
requirements and administrative procedures related to civil aviation aircrew pursuant to
Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311,
25.11.2011, p. 1) in particular Part-ARA
— Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements
and administrative procedures related to air operations pursuant to Regulation (EC)
No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1)
— Draft Annex 4 to the Bilateral Air Safety Agreement (BASA) between EU and USA on FSTDs
— ED Decision 2015/012/R of 4 May 2015 amending the Acceptable Means of Compliance and
Guidance Material to Part-Definitions and Part-ORO of Regulation (EU) No 965/2012 ‘GM to
Part-Definitions — Amendment 3’ ‘AMC and GM to Part-ORO — Issue 2, Amendment 2’, in
particular on UPRT
— Opinion 03/2015, Revision of operational approval criteria for Performance-Based Navigation
(PBN), 31 March 2015
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6. References
— ICAO Doc 9625, Manual of Criteria for the Qualification of Flight Simulators, fourth Edition, Vol I
— Aeroplanes, 2015
— ICAO Doc 10011, Manual on Aeroplane Upset Prevention and Recovery Training, 1st edition,
February 2017
— FAA 14 Code of Federal Regulations (CFR), Part 60, Change 2
— Safety Recommendation FRAN-2012-045 (BEA)
— Safety Recommendation RUSF-2013-002 (AIB)
— Safety Recommendation SPAN-2011-020 (CIAIAC)
— Safety Recommendation FRAN-2016-006 (BEA)
— ICAO Doc 8335, Manual of Procedures for Operations Inspection, Certification and Continued
Surveillance, Part I, paragraphs 5.3.1 and 6.2.3, Edition 5, 2010
— International Air Transport Association (IATA), Flight Simulator Evaluator Pilot Guide, Chapter 5,
1st Edition, 2000
— EASA CAs Common-Training Initiative Group, Airworthiness Inspectors Qualification Criteria,
Issue 2
— Aeronautical Radio, Incorporated (ARINC) Report 432-2 Training Requirements for Flight
Training Equipment Support Personnel, 19 November 2014, especially Appendix A
— Joint Aviation Authorities (JAA) Administrative & Guidance Material, Section Six: Synthetic
Training Devices (STD/FSTD), Part Two: Procedures, Chapter 3
— International Organization for Standardization (ISO) 10015:1992, Quality management —
Guidelines for training’, Edition 1, December 1999
— Finish Transport Safety Agency (Trafi) internal work instructions on FSTD inspector experience
and training requirements
— The National Institutes of Health (NIH), Competency Proficiency Scale of the Office of Human
Resources (https://hr.od.nih.gov/workingatnih/competencies/proficiencyscale.htm)
— IATA, Evidence Based Training Implementation Guide, Appendix A, 1st Edition, July 2013
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7. Appendices
7. Appendices
N/a
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