The comment deadline has been extended 90 days, from October 8 to January 6, on anotice of proposed rulemaking(NPRM) published in July that seeks to amend qualification standards for some flight simulation training devices (FSTDs), specifically those capable of reproducing extended flight envelope and adverse weather training.
The FAA says revised technical evaluation criteria are necessary to fully implement the requirements recently adopted in thecrewmember and aircraft dispatcher training final rulepublished on Nov. 12, 2013. According to the agency, the proposal also addresses several recommendations from the NTSB and the FAA’s aviation rulemaking committee.
The FAA believes the industry needs new technical standards for evaluating an FSTD for full stall and stick pusher maneuvers, upset recognition and recovery maneuvers, maneuvers conducted in airborne icing conditions, takeoff and landing maneuvers in gusting crosswinds and bounced landing recovery maneuvers. The request for a longer comment period came from training organization FlightSafety International, industry trade group Airlines for America and a technical issues working group representing simulator manufacturers and simulator data providers.
As of late September, only a handful of comments were submitted on the proposed rules, and these include the following:
· Table A1A, entry number, 2.1.7.S, contains the wording:“The aerodynamic model must be programmed and evaluated using the best available data to demonstrate the expected aircraft behavior should the stall identification system be overridden or disabled as required for training.” The statement in the entry above, “The aerodynamic model must be programmed and evaluated using the best available data…” is ambiguous. What is considered best available data? Will a non-OEM-provided solution that meets the representative model requirements, as stated in the proposed rule change, be considered for qualification, even in the case where an OEM-provided solution exists? The following re-wording is recommended: “The aerodynamic model must be programmed and evaluated using appropriate OEM and/or non-OEM flight-test, analytical and/or empirical data…to demonstrate the expected aircraft behavior should the stall identification system be overridden or disabled as required for training.”
· In the economic analysis, did the FAA factor in the costs associated with: 1. Acquisition costs of additional OEM data needed to comply with the new requirements. If so what were the costs used for the analysis? 2. Modification costs associated with obtaining licenses for third-party implementation of data acquired in item 1 above. 3. Costs associated with the loss of [full flight simulator] utilization/revenue for the change(s), design implementation, installation, validation and actual FAA qualification activities. 4. It would appear the affect on the industry could include a larger number of Level C and Level D [full flight simulators] than the 322 cited in the analysis. Did the FAA calculate total costs if all currently FAA-qualified Level C and Level D devices were to comply with FSTD Directive 2? 5. Did the FAA calculate the cost to a Sponsor if [a full flight simulator] were not to comply with FSTD Directive 2?
