Once is Rarely Enough

Flight simulation training device qualification is one of those common processes that every regulator does a bit differently … and separately. Global harmonization would save the training industry millions, but few seem to be in a rush to make it happen. Rick Adams reports on the status quo.

If it’s Tuesday, that must be the FAA National Simulator Program two-man evaluation team coming in the training center door. By Thursday afternoon, the duo will be headed for home, and another flight simulation training device (FSTD) will be qualified for use in a commercial airline, business aviation, or civil helicopter training curriculum.

FSTD qualification has almost become that routine, at least in the United States and Europe where the Federal Aviation Administration (FAA) and European Aviation Safety Agency (EASA), respectively, handle hundreds of evaluations a year.

In other parts of the world, though, where there may be less experience dealing with the myriad technical details of a full-motion Level D flight simulator, or where there are distinct culture differences from the Western norms of aviation training, sim qualification may be less streamlined and occasionally frustrating for simulator manufacturers and FSTD operators.

(Note: the correct term for flight simulator approval is qualification, not certification as with aircraft types.)

Most simulator manufacturers and training center operators are reluctant to mention any problems with specific national aviation authorities (NAAs). After all, their business is dependent on the multi-million dollar FSTDs being approved by the regulators. No sim qualification, no training customers.

“The regulatory agencies play a large part in why we’re in business,” said FlightSafety International’s John Van Maren, vice president of Simulation. “It’s hard to argue that the regulations have not improved safety.”

“It’s a very mature process,” noted Jim Takats, president and CEO of the new TRU Simulation + Training organization formed recently by Textron. “The examiners we’ve dealt with at the FAA and EASA are good people, knowledgeable. You know what to expect.”

“FSTD certification is a difficult and long process,” Jean-Claude Streel of new market entrant Venyo Aviation told me. Belgium-based Venyo hopes to certify its first flight simulator this year. “We’re working closely with the Belgian Civil Aviation Authority in order to clearly understand EASA legislation and rules.”

Most everyone acknowledges that some of the qualification standards are subjective and therefore an individual examiner may apply his own interpretation. Or apply a lawyerly focus on an area where he/she has a great deal of expertise, such as instrument landing systems. “But there are no big differences, nothing horrendous,” said John Frasca, vice president at Frasca International. “The inspectors we see all seem to be very serious business people.”

Examiners in some countries, most manufacturers told me, can be somewhat “more challenging.” For example, if an examiner has little experience in conducting simulator evaluations, he or she may be unsure of themselves and be inclined to “dot i’s and cross t’s.” Oftentimes if a test result is borderline, a newer evaluator will not allow it to pass, concerned about being held accountable by agency superiors for granting any leeway.

One Step at a Time

The biggest frustration expressed by simulator operators about qualification is the variability in the process itself. Something as basic as different document formats for different NAAs. “At the end of the day, it’s the same device, the same process,” said Takats. “The differences add cost but they don’t really add value.”

One NAA, whose name we won’t mention (not FAA or EASA), evaluating an FSTD for a training company, who shall also be nameless here, would not even reveal their qualification process in advance. Instead, they insisted on meeting face-to-face with the training operator representatives, who were required to speak the NAA’s native language (not English). Only after revealing the first part of the process and receiving the operator’s feedback would the NAA unveil the next step in the process.

After a couple of weeks of process iterations, the NAA revealed that the Qualification Test Guide (QTG), the data document which reflects hundreds of performance parameters for the simulator and the central element of evaluation, was required to be translated into the country’s native language as well.

Counting translation time, which required subcontracting to a third party with both the language fluency and technical aviation/simulation expertise, the entire qualification took about three months compared to the typical three days with the FAA or EASA. Once the translated QTG was completed, the onsite FSTD evaluation took only four days.

Slow Tempo to Harmony

With the majority of new aviation growth ever-shifting to the non-Western world, simulator operators can expect more frequent dealings with less-experienced NAAs, some approving FSTDs for the first time.

A word you’ll hear often in the aviation community, whether on training, pilot licensing, or other topics, is “harmonization.” This holy grail of standardization and common best practices, in the flight training domain, is represented by Document 9625.

After several years of analysis, drafts, and comments by an industry working group under the auspices of the Royal Aeronautical Society (RAeS), the International Civil Aviation Organization (ICAO) published the updated Manual of Criteria for the Qualification of Flight Simulation Training Devices, Volume I – Aeroplane (Doc 9625, 3rd Edition) in July 2009. This was followed in 2012 by Volume II, separately addressing helicopter FSTDs for the first time.

Now under the banner of the International Pilot Training Consortium (IPTC) – a group sponsored by ICAO, the RAeS, the International Air Transport Association (IATA), and the International Federation of Air Line Pilots’ Associations (IFALPA) – potential changes continue to be reviewed. An amendment to Volume 1 is expected this year.

“We need to get together across the globe and harmonize the qualification process,” said Dr. Nidal Sammur, FlightSafety director of Engineering.

TRU’s Takats, who has been active in both the fixed- and rotary-wing training device working groups, urged NAAs to “incorporate the guidance” in Doc 9625. “It’s not just about simulator qualification. The document addresses training needs, fidelity of features, and the performance of many training tasks. It has a lot of flexibility for the industry.”

But not everyone is on board with the ICAO consensus guidance. One longtime Europe-based simulator engineer who has shepherded dozens of simulators through qualification believes Doc 9625 “is an unworkable and non-practical document.” The problem, he added, “is in how the inspectors interpret the current rules and standards and the ensuing quality of the end-product for training. It's still very, very subjective and quality is dependent on how good the individual inspector is.”

He calls it “a missed opportunity to bring the FAA and EASA together.”

To date, only one NAA has adopted the Doc 9625 standards, the Singapore Civil Aviation Authority. Despite being represented in the working groups which developed the documents, neither the FAA nor EASA has implemented the ICAO guidance (although it could be argued that elements of the in-development 9625 were incorporated into the FAA’s Part 60 rule issued in 2006 and Part 60 Change 1 in 2008).

New EASA regulations for commercial air transport, including pilot licensing and training (EASA Ops instead of the former EU-Ops), became law in October 2012. However, the European states have taken a two-year derogation from applying the “Total System Approach” implementing rules, and even though the deadline is October 28, 2014, there’s an appeal process for further delay.

John Frasca doubts the FAA or EASA “will ever adopt the ICAO guidance 100 percent. They’ll want to retain their own flavor and independence.”

Last September, the triennial ICAO Assembly endorsed a working paper submitted by IATA, which represents 240 airlines, encouraging NAAs “to use common criteria, thus improving reciprocity of qualifications whilst allowing, at the same time, the inclusion of particular administrative needs of States.” IATA stated, “The absence of recognition of FSTD audits by the States where they are operated has resulted in a cost to the industry of millions of dollars and decreased the availability of training devices by a considerable amount.”

A 2012 IATA study estimated the direct cost burden for the aviation training industry at US$32 million a year, not including lost business opportunities and the expenses of regulatory personnel. Some training centers cited examples in which a single FSTD was evaluated by as many as a dozen separate NAAs.

Some of the overkill is attributed to the not-evaluated-here syndrome. Training operators have also complained over the years that multiple regulatory agencies, as well as larger than necessary evaluation entourages, are more likely to show up in attractive travel and shopping destinations. Of course, the cost of the NAA qualification visit is borne by the simulator operator and, ultimately, by the organization whose pilots train there.

One new simulator capability training operators are quickly moving to implement is upset prevention and recovery training (UPRT) as a means of mitigating the risk of loss of control in-flight (LOCI), the leading cause of aviation fatalities. With ICAO’s Doc 10011, Manual on Aeroplane Upset Prevention and Recovery Training, published earlier this year, and the FAA’s proposed advisory circulars AC 120-UPRT and AC 120-109A, new guidelines for pilot upset training, FSTD manufacturers are scrambling to adapt simulators to provide validated stall and unusual attitude training capability, as well as instructor education on simulator limits so as to preclude any negative training transfer.

Trail Guides

The larger simulator manufacturers such as CAE, FlightSafety, Frasca, L-3 Link, and Rockwell Collins have staff regulatory specialists to navigate the nuances of NAAs around the world. For manufacturers and operators who may not have sufficiency personnel or expertise to manage the process, there’s a cottage industry of independent consultants who provide FSTD qualification and training services.

One of the better-known FSTD consultants is Montreal, Canada-based Training Technology International. TTI specializes in three- and five-day evaluator courses, held at locations in each major world region. The consultancy was founded by Brian Hampson, formerly simulator superintendent for British Airways and CAE; former American Airlines director of simulator support Joe DePaola; and Bob Earp, who managed CAE training centers in Canada.

The UK CAA’s commercialized arm, CAA International, offers a “Technical Evaluation of Flight Simulation Training Devices Course,” covering the spectrum from generic flight navigation procedural trainers through type-specific full flight simulators.

UK company Highview Aeronautics, led by Andrew Brand, specializes in flight simulator qualification, flight test data matching, and quality control, and has worked with the former Thales (now L-3 Link), CAE, and others.

SimHelp, part of Avia Solutions Group and connected with Baltic Aviation Academy in Lithuania, claims a network of 300 engineers by working with partners such as air traffic control simulation specialist Adacel and component support company Aerotron.

Swiss-based Avigate, founded by Dr. Peter M. Lenhart, who led business development and qualification for Elite Simulation Solutions, has qualified numerous FNPT devices throughout Europe.

Two by Two

Although the FAA sends two evaluators and EASA two or three, the simulator operator qualification team can include a dedicated qualification manager, the training center program manager, a quality manager, an aero engineer, a visual engineer, support technicians, and others.

On the first morning, the regulators typically fly the simulator for an hour or so, and then take over a conference room to evaluate the objective data in the QTG. At the end of the day there’s a quick overview debrief and outline of the day two agenda, usually focused on manual testing. The third day is reserved to cover any gaps or areas the evaluators wish to further explore.

For Level D helicopter simulators, of which many more are being produced the past few years, FlightSafety’s Dr. Sammur said autorotation maneuvers always trigger questions because quite often data from the aircraft manufacturers is incomplete in this area.

One scenario simulator operators don’t like to see is evaluators from two regulatory agencies coming through the door at the same time. Adjusting in real time for the differences in a joint evaluation is “painful,” one training center manager told me. If you must qualify the FSTD with both, and one won’t accept the other’s professional opinion for harmony’s sake, better to deal with them separately.