RAeS FSTD Regulatory Workshop                                                           London, 22nd Sept 2009

RAeS FSTD Regulatory Workshop London, 22nd Sept 2009 PowerPoint PPT Presentation


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Challenges Ahead. International Committee on FSTD Qualification ICFQEstablished by the RAeS to maintain the currency of ICAO Doc 9625 in the future for

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RAeS FSTD Regulatory Workshop London, 22nd Sept 2009

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1. RAeS FSTD Regulatory Workshop London, 22nd Sept 2009

2. Challenges Ahead International Committee on FSTD Qualification ICFQ Established by the RAeS to maintain the currency of ICAO Doc 9625 in the future for… New training types or methodologies New FSTD technologies Industry best practice 1 or 2 meetings/year representing the interests of... Aircraft manufacturers (FW & RW) Air Transport Carriers Pilot Representative bodies Simulator & Visual System manufacturers Simulation user representative bodies Independent Training service providers Regulatory Authorities

3. Principal Issues. International Committee on FSTD Qualification ICFQ The principal issues shall include                  assessing feedback from recognised organisations on the extant authorised technical criteria, ·                  oversight of the training analysis described in Volume II of the ICAO 9625 rev.3 Document, ·                  monitoring the implications to training criteria of new training programmes such as MPL, ·                  reviewing the impact of technical and training developments in all fields of FSTD manufacture and use, including such aspects as the simulated environment including air traffic management.   It shall also act to facilitate the establishment of mutual recognition between national and multi-national aviation authorities.

4. Challenges Ahead International Committee on FSTD Qualification ICFQ Regulatory Workshop How to Move Ahead Current progress Apparent difference in Regulatory Interpretation Adoption of the New Standard by NAAs Workshop Objectives Brief attendees on progress, current difficulties and how to move ahead Find out how the ICFQ can help with the overall process This is not a conference: Its a Workshop, so please contribute

5. Status Report on the RAeS IWG-A RAeS Training Conference Sept 2009

6. 5 These regulations continue to be updated by industry when and as required but the training environment in which they apply has arguably changed greatly from that for which they were originally conceived. EASA – European Aviation Safety Agency MPL – Multicrew Pilot License Level B / Non-Zero Flight Time / Level E FFS Full Integration of ground and ATC simulation Military FSTD accreditation Air to Air Refueling Credit Sequences Rapid growth in capability and diversity of FSTD types Rotary wing Lower level devices (FNPTs) New simulation technology Laser visual display systems Electric Motion System These regulations continue to be updated by industry when and as required but the training environment in which they apply has arguably changed greatly from that for which they were originally conceived. EASA – European Aviation Safety Agency MPL – Multicrew Pilot License Level B / Non-Zero Flight Time / Level E FFS Full Integration of ground and ATC simulation Military FSTD accreditation Air to Air Refueling Credit Sequences Rapid growth in capability and diversity of FSTD types Rotary wing Lower level devices (FNPTs) New simulation technology Laser visual display systems Electric Motion System

7. ICAO doc 9625 as the baseline of NAA FSTD Standards SC: Harmonization of standards Common, clear, vocabulary & definitions Uniform interpretation More mutual recognition INCREASED OVERALL EFFICIENCY SC: Harmonization of standards Common, clear, vocabulary & definitions Uniform interpretation More mutual recognition INCREASED OVERALL EFFICIENCY

8. 7 Methodology – Step 1 – Training Task Analysis EASA/ICAO/FAA training task lists MPL1,2,3,4 Multi-crew Pilot License IR Initial Instrument Rating PPL Private Pilots License CPL Commercial Pilots License CR Class Rating TR Type Rating RL Recurrent License (Training & Checking) RO Recurrent Operator (Training & Checking) Re Recency (Take-off and Landing) CQ Continuing Qualification IO Initial Operator Training (T) – The FSTD feature fidelity levels required for each listed task that supports the training objective. Training to Proficiency (TP) – The FSTD feature fidelity levels required for each listed task that supports the training objective to proficiency and allow testing and checking towards the issue of a licence, rating, or qualification.

9. 8 Methodology – Step 2 - Simulation Features

10. 9 Methodology – Step 3 - Training Task Matrix Concept Combine data from Steps 1, and 2 into a single matrix

11. Device Types

12. RAeS Sept 09 16/03/2012 11 High Level Requirements for non Ab-initio Full Task FSTDs Color code: blue = specific, green = representative, yellow = generic, red = none Ascending order of training « prestige », not ascending order of fidelity MOTION Second-level Device (MPL phase 3) Similar to top-level device but focuses on motion awareness cues and stimulus of reduced magnitude compared to top-level device. Objective motion cue fidelity criteria -To reduce variability caused by subjective tuning Being developed & studied in the IWG - Complete motion loop: software + hardware AIR TRAFFIC CONTROL - Mandated by ICAO MPL for phases 3 and 4 Training need also expressed by IWG Training sub WG for 5 out of 7 ICAO Standard Device levels - ATC = new qualification requirement - Also expressed by IATA and JAA Based on an IATA an doc. (2002) - Based on JAR TGL (2006) doc INSTRUMENT AND PANELS: - very high-fidelity at least for level 7 Ensure 3D remains 3D Do not allow errors such as parallax, viewing angles, wrong dimensions, wrong locations etc. Color code: blue = specific, green = representative, yellow = generic, red = none Ascending order of training « prestige », not ascending order of fidelity MOTION Second-level Device (MPL phase 3) Similar to top-level device but focuses on motion awareness cues and stimulus of reduced magnitude compared to top-level device. Objective motion cue fidelity criteria -To reduce variability caused by subjective tuning Being developed & studied in the IWG - Complete motion loop: software + hardware AIR TRAFFIC CONTROL - Mandated by ICAO MPL for phases 3 and 4 Training need also expressed by IWG Training sub WG for 5 out of 7 ICAO Standard Device levels - ATC = new qualification requirement - Also expressed by IATA and JAA Based on an IATA an doc. (2002) - Based on JAR TGL (2006) doc INSTRUMENT AND PANELS: - very high-fidelity at least for level 7 Ensure 3D remains 3D Do not allow errors such as parallax, viewing angles, wrong dimensions, wrong locations etc.

13. 12 Non ab-initio Full Task FSTDs – 2 Types only Color code: blue = specific, green = representative, yellow = generic, red = none Ascending order of training « prestige », not ascending order of fidelity MOTION Second-level Device (MPL phase 3) Similar to top-level device but focuses on motion awareness cues and stimulus of reduced magnitude compared to top-level device. Objective motion cue fidelity criteria -To reduce variability caused by subjective tuning Being developed & studied in the IWG - Complete motion loop: software + hardware AIR TRAFFIC CONTROL - Mandated by ICAO MPL for phases 3 and 4 Training need also expressed by IWG Training sub WG for 5 out of 7 ICAO Standard Device levels - ATC = new qualification requirement - Also expressed by IATA and JAA Based on an IATA an doc. (2002) - Based on JAR TGL (2006) doc INSTRUMENT AND PANELS: - very high-fidelity at least for level 7 Ensure 3D remains 3D Do not allow errors such as parallax, viewing angles, wrong dimensions, wrong locations etc. Color code: blue = specific, green = representative, yellow = generic, red = none Ascending order of training « prestige », not ascending order of fidelity MOTION Second-level Device (MPL phase 3) Similar to top-level device but focuses on motion awareness cues and stimulus of reduced magnitude compared to top-level device. Objective motion cue fidelity criteria -To reduce variability caused by subjective tuning Being developed & studied in the IWG - Complete motion loop: software + hardware AIR TRAFFIC CONTROL - Mandated by ICAO MPL for phases 3 and 4 Training need also expressed by IWG Training sub WG for 5 out of 7 ICAO Standard Device levels - ATC = new qualification requirement - Also expressed by IATA and JAA Based on an IATA an doc. (2002) - Based on JAR TGL (2006) doc INSTRUMENT AND PANELS: - very high-fidelity at least for level 7 Ensure 3D remains 3D Do not allow errors such as parallax, viewing angles, wrong dimensions, wrong locations etc.

14. 13 Some obvious questions Questions How do we address Part Task Trainers qualification? How does this apply to my existing Simulators? Answers Use training matrix... To determine training task applicability based on levels of fidelity of FSTD simulation features present in your device To develop QTG document for qualification if required Note! Grandfather rights are not even mentioned in ICAO 9625 as their applicability are the NAAs perogative!

15. 14 BREAKING NEWS......BREAKING NEWS......BREAKING NEWS......BR ICAO 9625 Edition 3 Published 31 July 09 http://store1.icao.int/search.ch2

16. 15 Also the RAeS Handbook RAeS Evaluation Handbook, Vol 1,revision 4 in draft review. Aligns with 9625 rev. 3. Plan to launch at FSG November Conference. Vol 2, Function and Subjective testing, work has started.

17. IWG Adoption Status - September 2009

18. 17 What it means to industry ICAO 9625 Edition 3 enables... Expansion of international standards to lowest level devices Reduction of harmonization challenge from 27 to 7 FSTD types Full Task and Part Task training device evaluation methodology Evaluation of any type or vintage of FSTD for training suitability

19. 18

21. FSTD Qualification Requirements In relation to issuance of a Pilots License, each Nation requires FSTD training, testing and checking to be completed in a qualified device as approved by the applicable NAA. FAA & JAA/EASA Standards commonly used in the rest of the world FSTD Qualifications generally valid for one year …and require a recurrent evaluation Most NAAs complete individual on-site audits of the FSTD equipment, and associated quality program

22. A Sample of Stakeholders, Many Standards…

23. FSTD Multiple Qualification Requirements – Some Of The Issues FSTD Qualification completed to prescribed/adopted standards Requires different MQTG / Documentation Variation in expectations with NAA performing evaluation Same device will be assessed by a multitude of NAAs during the course of a year Recently much (or too much) emphasis on “Engineering” as compared to “Training Capability” of the device QMS standards vary between NAAs

24. Example Of Recurring Cost…. Time & Effort Money …. Approx 20K Euro / Device / Qualification Loss Of Revenue …… 2K Euro / Device / Qualification Large Operators – 100+ FSTDs Assume 1500 FSTDs Globally > 30MM Euros.. OEM Data Costs due to differing requirements Regulators Costs Are Additional Opportunity to optimize our model….

25. RAeS Sept 09 RAeS FSTD Regulatory Workshop 24 Adoption of New ICAO Doc for NAA FSTD Rules History of Adoption of prior ICAO Doc Editions - Edition 1 of 1995: JAR STD 1A (EU 1995) AC 120 – 40B „International Version“ (US 1993) FSTD 1 (AUS 1993) - Edition 2 of 2003: JAR STD 1A Amdt.3 (EU 2003) CFR Part 60 (US 2005) CASR Part 60 (AUS 2003) Challenges for Adoption of Edition 3 - complete suite of devices, not just level D FFS - Adoption affects FCL& OPS, not just FSTD rules. ICAO Doc must be split up. - Adoption process must capture Rotary Wing Volume trailing Airplane Volume - ICAO PANS TRG Doc (centering around MPL) is supported. - EASA in transfer process for current JAR FSTD A/H + JIP´s into EASA rules Ed 1 developed in 1990-92 by an RAeS led WG, published by ICAO in 1995 was already put into use by Australia in 1992 as IQTG (BAe 146 for Australian) JAA started JAR STD WG in 1992 to develop JAR STD 1A (CAA leadership) Ed 2 was developed under an FAA/JAA initiative in 2001, published by ICAO in 2003. This Ed is reflected in Amdt 3 to JAR STD 1A published July 1, 1993 In the US an International Version of FAA AC 120 – 40B was in use from ? on. A difference list to Ed 2 tests did exist. IWG was to develop a manual that, through ICAO, will form the basis for all national and international standards for a complete range of FSTDs. Adoption of this manual into the regulatory framework is the responsibility of the various NAA´s.Ed 1 developed in 1990-92 by an RAeS led WG, published by ICAO in 1995 was already put into use by Australia in 1992 as IQTG (BAe 146 for Australian) JAA started JAR STD WG in 1992 to develop JAR STD 1A (CAA leadership) Ed 2 was developed under an FAA/JAA initiative in 2001, published by ICAO in 2003. This Ed is reflected in Amdt 3 to JAR STD 1A published July 1, 1993 In the US an International Version of FAA AC 120 – 40B was in use from ? on. A difference list to Ed 2 tests did exist. IWG was to develop a manual that, through ICAO, will form the basis for all national and international standards for a complete range of FSTDs. Adoption of this manual into the regulatory framework is the responsibility of the various NAA´s.

26. Adoption of New ICAO Doc for NAA FSTD Rules Possible Ways Forward - Operators and manufacturers are now starting to use the revised definitions in RFPs and their FSTD requirements. - NAA´s allow FSTD qualification based on ICAO 9625 ed. 3 revised validation / functions & subjective tests from Appendices B and C in Part II as an alternative means of compliance for top level FSTDs. Advantage: profit from ICAO 9625 ed. 3 qualification standards that now cover new a/c and FSTD technologies (e.g. LCOS projectors, visual fov., throughput delay, elec. motion, HUD, EVS,...) At EASA the process of porting JAR FSTD A/H into the new EASA rule structure was kicked off with NPA 2008 – 22 of October 2008. Once this new rule is in place (April 2012) it is binding for all 27 NAA´s in the EU + Switzerland, Liechtenstein, Iceland and Norway. ICFQ took the initiative to comment on NPA 2008 – 22, to ensure that a later incorporation of the new ICAO Doc into EASA Rules is straightforward (does not involve the Commission in Brussels) EASA indicated that stopping their current process of JAR FSTD A/H adoption would jeopardize their April 2012 date. (All EASA Ops + Licensing Rules in Place) At EASA the process of porting JAR FSTD A/H into the new EASA rule structure was kicked off with NPA 2008 – 22 of October 2008. Once this new rule is in place (April 2012) it is binding for all 27 NAA´s in the EU + Switzerland, Liechtenstein, Iceland and Norway. ICFQ took the initiative to comment on NPA 2008 – 22, to ensure that a later incorporation of the new ICAO Doc into EASA Rules is straightforward (does not involve the Commission in Brussels) EASA indicated that stopping their current process of JAR FSTD A/H adoption would jeopardize their April 2012 date. (All EASA Ops + Licensing Rules in Place)

27. Adoption of New ICAO Doc for NAA FSTD Rules What are your Agency´s or NAA´s plans with respect to the adoption of the new ICAO Standard ? - Do you plan to adopt ICAO 9625 Edition 3 into your NAA regulatory framework? - If yes, what timescale do you envisage? - In the interim there is a work-around solution as follows: The Agency or the NAA‘s consider the adoption of ICAO 9625 ed. 3 as an acceptable means of compliance pending any NPA/NPRM process. > How can the RAeS ICFQ help ? At EASA the process of porting JAR FSTD A/H into the new EASA rule structure was kicked off with NPA 2008 – 22 of October 2008. Once this new rule is in place (April 2012) it is binding for all 27 NAA´s in the EU + Switzerland, Liechtenstein, Iceland and Norway. ICFQ took the initiative to comment on NPA 2008 – 22, to ensure that a later incorporation of the new ICAO Doc into EASA Rules is straightforward (does not involve the Commission in Brussels) EASA indicated that stopping their current process of JAR FSTD A/H adoption would jeopardize their April 2012 date. (All EASA Ops + Licensing Rules in Place) At EASA the process of porting JAR FSTD A/H into the new EASA rule structure was kicked off with NPA 2008 – 22 of October 2008. Once this new rule is in place (April 2012) it is binding for all 27 NAA´s in the EU + Switzerland, Liechtenstein, Iceland and Norway. ICFQ took the initiative to comment on NPA 2008 – 22, to ensure that a later incorporation of the new ICAO Doc into EASA Rules is straightforward (does not involve the Commission in Brussels) EASA indicated that stopping their current process of JAR FSTD A/H adoption would jeopardize their April 2012 date. (All EASA Ops + Licensing Rules in Place)

28. Mutual Recognition – Illusion or Realistic Aim ? The Case for Mutual Recognition - Easier use of global FSTD resources. - Savings for operators worldwide (IATA estimate of 2003: 24 M US $ annually, recurrent evaluations only). Current Status of Mutual Recognition - 15 States within JAA have successfully applied it (initial + recurrent). - Some States have one-way recognition (i.e. Australia recognizes Hong Kong, NZ, USA and 15 EU States´ qualification certificates). - BASA´s and SIP´s between USA & UK and USA & CH established, mutual recognition of recurrent evaluations between these States. - Joint FAA/JAA initial evaluations for new airplane type FSTDs carried out. With the cessation of the JAA and the end of the formal Cyprus Agreements on July 1, 2009 the basis for the 15 States mutual recognition no longer exists. The European NAA´s are deloping a process to continue the principles of mutual recognition. A „catch up process“ has come to an end, whereby devices in the US or Canada that do not hold a JAR-FSTD qualification but have an FAA qualification and located within TRTO´s have been evaluated (incl. the quality system) and been given a special qualification that will be annually revalidated with a team of NAA representatives appointed by EASA. This process will continue until EASA rules are in place (2012). From that date on EASA will have full responsibility over qualification f devices outside the EU. The new ICAO Doc is „intended to provide means for authorities of other States to accept the qualification granted by the State which conducted the initial and recurrent evaluation of an FSTD...“ (Vol I Chapter 2 item 2.1.2)With the cessation of the JAA and the end of the formal Cyprus Agreements on July 1, 2009 the basis for the 15 States mutual recognition no longer exists. The European NAA´s are deloping a process to continue the principles of mutual recognition. A „catch up process“ has come to an end, whereby devices in the US or Canada that do not hold a JAR-FSTD qualification but have an FAA qualification and located within TRTO´s have been evaluated (incl. the quality system) and been given a special qualification that will be annually revalidated with a team of NAA representatives appointed by EASA. This process will continue until EASA rules are in place (2012). From that date on EASA will have full responsibility over qualification f devices outside the EU. The new ICAO Doc is „intended to provide means for authorities of other States to accept the qualification granted by the State which conducted the initial and recurrent evaluation of an FSTD...“ (Vol I Chapter 2 item 2.1.2)

29. Mutual Recognition – Illusion or Realistic Aim ? Challenges for Mutual Recognition – There is no Momentum at present - Lack of interest at policy level of NAA (Protection of own industry ?) - Lack of will to relinquish power over qualification. - Lack of trust in the other NAA´s way of doing the qualification. Way Forward Towards Mutual Recognition - ICAO Doc provides up to date, internationally agreed, standard qualification criteria for all FSTDs as a basis for Mutual Recognition. - New EASA rules from 2012 on will provide Mutual Recognition among 27 EU States + 4 additional States. FSTDs outside the EU and evaluated by EASA will become part of the EU + 4 system. (Ed. 2 Std) - Establish auditing procedures to build trust among NAA´s. Use procedures established by former JAA Sim Eval Teams as a model. - Future EASA/FAA Conference presentation? Part II of Doc 9625 „ is intended to provide means for the authorities of other States to accept the qualifications granted by the State which conducted the initial and recurrent evaluation of an FSTD, without repetitive evaluations, when considering approval of the use of that FSTD by applicants from their own State.“Part II of Doc 9625 „ is intended to provide means for the authorities of other States to accept the qualifications granted by the State which conducted the initial and recurrent evaluation of an FSTD, without repetitive evaluations, when considering approval of the use of that FSTD by applicants from their own State.“

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