The European Union Aviation Safety Agency (EASA) on 16 December released Notice of Proposed Amendment (NPA) 2020-15, “Update of the flight simulation training device requirements.”

The amendment has been in development since 2016. Anticipated proposal to the European Commission is Q1 2022 with adoption and implementing rules, acceptable means of compliance and guidance material by Q1 2023.

The NPA is available here.

Comments may be submitted using the automated Comment-Response Tool (CRT) available on EASA's website. The deadline for submission of comments is 31 March 2021.


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EASA stated: “The objective of this Notice of Proposed Amendment (NPA) is to amend the EU regulatory framework with a view to maintaining a high level of aviation safety by applying an innovative approach to the capabilities classification of future flight simulation training devices (FSTDs) that ensures harmonisation with the guidance established in Doc 9625 ‘Manual of Criteria for the Qualification of Flight Simulation Training Devices’ by the International Civil Aviation Organization (ICAO). In addition, it aims at introducing a paradigm shift into the regulatory framework for initial (Flight Crew Licensing (FCL)) and recurrent (Air Operations (OPS)) pilot training. Further to the paradigm proposed, training providers are required to identify the device capabilities (referred to as ‘FSTD capability signature’ (FCS)) based on analysing regulatory training task objectives against FSTD features and fidelity levels. The identified FCS is subsequently matched with training devices available on the market having at least the same FCS. This allows training providers to use the most appropriate and latest innovative training devices.

The application of features and fidelity level criteria enables:

  1. more flexibility in obtaining training credits by using other types of training devices — different from a full flight simulator (FFS);
  2. improvement of the visibility from the training side on the capabilities of the different devices; and
  3. the use of new technologies in training thereby improving safety by making a clear link between FCL (type rating training) and OPS (operator recurrent training) and the Certification Specifications for Aeroplane Flight Simulation Training Devices (CS-FSTD(A)).

“This NPA proposes the amendment of:

  • the acceptable means of compliance (AMC) and guidance material (GM) to Appendix 9 to Annex I (Part-FCL) to Regulation (EU) No 1178/2011 (the ‘Aircrew Regulation’) by introducing a training matrix that defines the fidelity levels required to achieve the type-specific training objectives for each training task;
  • Annex VI (Part-ARA) and Annex VII (Part-ORA) to the Aircrew Regulation and the associated AMC and GM; in particular, amendments are proposed to the qualification certificate (QC) and the equipment and specifications list (ESL) is introduced;
  • CS-FSTD(A); in particular, as regards changes to the simulator levels. Furthermore, the structure of the CS has been reviewed to facilitate the set-up of standards in accordance with the European Union Aviation Safety Agency (EASA) rulemaking principles.

“The proposed amendments are expected to maintain safety, promote more cost-effective training and ensure alignment with ICAO. The stakeholders mostly affected by the proposed changes will be aircraft manufacturers, FSTD data providers, FSTD manufacturers and organisations operating FSTDs. Competent authorities (CAs) and approved training organisations (ATOs) will be affected in a varying degree, depending on the type and qualification of the FSTD and its use in training.”