“Our comprehensive regulatory proposal on UAM is now ready for public consultation”, Patrick Ky, Executive Director, EASA, at the agency’s High-Level Conference on Drones 2022. Currently in final internal consultation, the proposal is expected to be issued soon for public comment. Mario Pierobon, PhD, reports.
- 'Special conditions' for novel aircraft now; a future merged CS-FSTD using the FCS concept of NPA 2020-15
- SC, too, for A/M/V/XR FSTDs
According to the European Union Aviation Safety Agency, there is currently a need for the airship and eVTOL industries to be able to train on FSTDs before such new aircraft enter service. “In addition, new innovative FSTDs are being introduced that also include use of virtual/augmented reality (VR/AR) technologies. It should be noted that EASA has found that these innovations are also enabling better and more training in an FSTD, leading to an increasing level of safety, especially in the rotorcraft domain,” says Jens Krüger, Senior Expert of Flight Crew Training FSTD at EASA.
Special conditions (SC) are a faster way than the current process to update the existing certification specifications for FSTD (CS-FSTD A/H) to consider both the new categories of aircraft using new technologies as well as new technologies for training devices, observes Krüger. “The legal hook to develop and use SCs is given by the implementing rules in Part-ORA of the EASA Aircrew regulations (1178/2011),” he told CAT.
Since the SCs can only be defined by the relevant aircraft manufacturers knowing about the specific operation and the specific training needs, an industry-led task force, in collaboration with EASA, has been established, working on an SC-FSTD document which shall serve as a guideline and basis for upcoming FSTD evaluations for these aircraft categories, affirms Krüger. “The definition of specific training tasks necessary to operate the novel categories of aircraft and the definition of tests for the evaluation and qualification of associated training devices to cover those specific training tasks are two of the major tasks of the industry-led task force, respectively, of the individual OEMs”, he says. “Another important point is to get flight test data or engineering data, following CS-SIMD operational suitability data to validate the FSTD in those areas and to be used for the evaluation and qualification of the training devices. This can only be done by the industry, not by EASA.”
Indeed, one of today’s challenges is that there are no specifications available containing specific tests for novel aircraft types to be used for FSTD validation, as these are only available for fixed-wing aircraft (CS-FSTD(A)) and rotary-wing aircraft (CS-FSTD(H)). “The industry-led task force has been considered to be the most effective and most efficient way to work out the needed SCs because the different aircraft manufacturers facing the same need for SCs can collaborate to develop a common set of guidelines that addresses the needs in a consistent and structured way,” says Krüger. “The work is facilitated by EASA with a view to ensure that the developed special conditions enable the qualification of FSTDs for novel types of aircraft and ensure a smooth integration into a future issue of CS-FSTD.”
The guidelines and conditions developed by the industry task force are planned to contain common parts, such as cueing and environment features, and features specific to these novel aircraft categories. “This will form the basis before the manufacturers of the different novel aircraft categories will define their training – and aircraft-specific SCs”, says Krüger. “The structure of the SCs under development will follow the future structure of a merged CS-FSTD as well as include the FSTD capability signature (FCS) concept as published in NPA 2020-15. The alignment with this structure will enable an easier process for including these SCs with each subsequent revision of CS-FSTD”.
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During EASA’s High-Level Conference on Drones 2022 in late March, Christian Kucher, Senior Expert, Flight Crew Licencing, outlined the expectation that pilots who fly the new eVTOL aircraft will initially be licenced through the current CS-FSTD A/H path, but with an additional type rating for the new vertical takeoff and landing aircraft. A Notice of Proposed Amendment (NPA) is expected to be issued within the next few weeks with a targeted implementation of 2024.
This would be followed quickly by NPA #2 next year to define a new VTOL Pilot Licence (VPL), which would feature both a one-time basic practical training module and an aircraft-specific practical module (following ICAO CBTA guidelines) in effect a type-rating for each aircraft the pilot wishes to fly on a commercial basis (whether carrying passengers or cargo). The VPL scheme is expected to be implemented by 2025; however, during the interim, EASA intends to collect substantial scientific data to validate the safe operation of the new urban air mobility airships.
Special Conditions for Virtual Reality FSTDs
In parallel, a similar activity is ongoing to define specifications when A/M/V/XR training technology is used. “The work is using the existing CS-FSTD (A/H) as a basis where validation tests will be amended or partially replaced by SCs which are tailored to the aircraft type-specific requirements and to new FSTD technologies”, says Krüger. “Although the approach to use special conditions may be the same for new technologies for FSTD, like VR/AR, the development of conditions for those immersive solutions is not part of the airship eVTOL task force’s objectives.”
As to what is currently happening for the acceptance of A/M/V/XR technology, everything is being done on a case-by-case basis. “The evaluation principle (methodology) as once applied for the FNPT can be used for FTD as well, but detailed and tailored SCs shall consider the individual class or type of aircraft and the composition of FSTD parts, e.g., manufacturers of the visual or motion systems,” says Krüger.
To date, SCs have been used in the case of the already qualified devices for display systems (VR), motion systems, and the cockpit, according to Krüger. “If a helicopter FNPT is equipped with a motion system, the motion system shall comply with the motion requirements for a helicopter FFS level A. However, the stroke of the already qualified device is not meeting those requirements,” he says. “As for the cockpit, there is no full representation of the real aircraft since the cockpit representation is a combination of aircraft hardware and VR technology, i.e., visual system, instruments and panel.”
In terms of credit recognition, currently it is only possible to talk about the capability as demonstrated by the devices as currently qualified. “The devices are capable to provide parts of a type-rating training, parts of IFR training, as well as initial licensing such as PPL/CPL. The training credits are to be demonstrated by the training organisation to its competent authority prior to obtaining course approval,” says Daan Dousi, Manager of the Aircrew and Medical Standards and Implementation section at EASA.
The maximum amount of crediting is limited by the existing regulation. “However, we believe that VR/AR technology-based FSTDs can be used for a greater number of exercises,” says Krüger.
VR/AR/XR “is a new feature used on FSTDs, which we believe can possibly be integrated into FFSs in the future,” Krüger concludes.