On 6 March 2018 EASA hosted a workshop on the use of training devices, including flight simulation training devices (FSTDs) at their headquarters in Cologne. The purpose of the workshop was twofold, first to provide industry and competent authority personnel with an update on the current rulemaking task ‘Update of flight simulation devices requirements’ (RMT.0196) and second to gather industry feedback on how the regulations should present information on which devices may be used for particular training tasks. 140 delegates from industry and the competent authorities attended.
The workshop was introduced by Georges Rebender, EASA Head of Aircrew and Medical Department and Daan Dousi, Acting Manager for Standards and Implementation in Aircrew and Medical. Georges stated his desire for innovation in pilot-training and emphasised that innovation requires preparation. As new regulations are drafted these should not react to recent innovations but should be flexible enough to enable new technologies and methods to be introduced. Daan explained the background to the current rulemaking task, including new requirements for upset prevention and recovery training (UPRT) and ICAO guidance on mapping training tasks to the capabilities of flight simulation training devices (ICAO document 9625); he summarised the objective of the work as being to “deliver more effective and efficient pilot training while maintaining the level of safety”.
Status of RMT.0196
Andy Gilbard, chair of the rulemaking task 0196, described the need to update the certification standards for FSTDs (CS-FSTD). Simulation technology has made substantial advances in the 20 years since CS-FSTD was published. As well as accommodating technological developments the revised CS should accommodate the need for UPRT and should be more closely aligned with ICAO guidance and US FAA regulatory requirements. One ‘notice of proposed amendment’ (NPA) has already been published (NPA 2017-17). Subsequent NPAs will deal with technical requirements and update the standards for fixed-base devices qualified as ‘FTD 1’ and ‘FTD 2’.
Andy described that, unlike the US FAA, EASA are not mandating ‘post stall’ UPRT and that EASA-qualified FSTDs therefore do not need to be modified to simulate the post-stall regime. NPA 2017-17 does include standards for post-stall simulation so that FSTD manufacturers and operators have the option to incorporate this capability.
FSTD Capability Matrix
Itash Samani, Global Head of FSTD standards for CAE and a member of the rulemaking group, described the FSTD capability matrix that had been published with NPA 2017-17. The intention of the matrix was to provide users with guidance about the credit available for the use of particular types of FSTD for different pilot training courses. The matrix had been developed by mapping the training tasks associated with each training course, comparing these with the features and fidelity for different types of FSTD and presenting the result in a single table. The matrix published in NPA 2017-17 reflects current regulatory requirements. Further work is to be done to revise the requirements and update the matrix according to new requirements and current technologies. This process puts the ‘horse before the cart’ in that the devices that can be used will be determined by training needs rather than being driven by the available technology as was previously the case.
Andrew McKechnie, Director of McKechnie Aviation LTD, described a methodology that could be used in place of the FSTD capability matrix.Andrew described how the requirements for the use of FSTDs for many training courses are too complex to be summarised in a single line of a table and also that the adequacy of FSTDs depends on the capability of the specific device, not only on the level of qualification of the device. The proposed methodology is a five-step process that could be applied by aircraft operators or training organisations to determine which devices could be used for particular training courses. Competent Authorities would verify that the methodology had been applied correctly before approving the use of a particular device.
Use of FTD for operator recurrent training
Andy O’Shea, Head of Training for Ryanair, described a proposal to use fixed-base training devices qualified as ‘FTD’ to supplement the use of full-flight simulators (FFS) during recurrent training for Ryanair pilots. Andy demonstrated that the regulations do not specify the use of FFS and that competent authorities should have the confidence to approve the use of FTD where operators can demonstrate that such devices meet a training need and can improve safety.
Training Devices for High Performance Single Pilot Complex Aircraft (HPSPCA)
Michel Levy of DGAC France described the difficulties faced in the provision of training and checking for HPSPCA such as the Beech KingAir or Cessna Mustang. The requirement for checking to be conducted on FFS or the aircraft rather than ‘lower-level’ devices means that many checks are conducted using aircraft in-flight which represents a significant safety risk. Simulators are available for some of these types but the cost of using these is reported to be prohibitive for some of the people that own these multi-million dollar aircraft and employ their own highly-paid pilots. DGAC France supports an amendment to the regulations so that fixed-base devices qualified as FTD2 / FNPT II could be used for the conduct of proficiency check (EASA Opinion 5-2017 proposes a change to Part-FCL that could facilitate such a change).
After a buffet lunch Daan Dousi hosted a discussion on the relative merits of the FTSD Capability Matrix and the alternative methodology. The objective of this discussion was to determine whether the matrix, the methodology, or some combination of both should be published as ‘acceptable means of compliance’ or ‘guidance material’ to the regulations. As well as the discussion Daan was able to gather dozens of comments from the delegates by using a smartphone app (‘sli.do’). The discussions and comments will inform the decision of the rulemaking group and the a resulting AMC/GM can be expected later in 2018.
David Solar, Acting Head of Rotorcraft Department, EASA, described the need for more simulation for rotorcraft training. In particular he highlighted the much lower level of safety achieved in rotorcraft operations and the number of accidents that occur during on-aircraft training. He asked for delegates to assist with the innovation and development of new training devices for helicopter operations.
Virtual Reality and Augmented Reality
Arie Slagter, Accountable Manager and Experimental Test pilot with Helio Aero Services described the application of virtual reality (VR) and augmented reality (AR) to pilot training. VR involves a ‘total immersion’ environment where a trainee uses goggles that project a 3D image and exclude external vision. VR is still limited by image resolution and image lag as the trainee looks around the virtual environment. Both of these cause motion sickness and so limit the value of VR as a training aid. Motion tracking can be used to allow users to control the virtual environment by hand gestures, but the feel of controls is not replicated unless a physical environment is provided (e.g. a replica flight deck). AR can be used to introduce virtual objects into real world training. Trainees use see-though goggles which use projection to allow the user to see computer-generated images in their normal field of view. AR could be used in both simulator and ‘on-aircraft’ training. Arie gave the example of confined area helicopter pilot training. This training could be conducted on a real aircraft in an open space, with the AR introducing images to simulate the confined area.
Anneke Nabben of the Netherlands Aerospace Centre (NLR) provided an overview of work that is underway on ‘aviation blended learning environments’ (ABLE). This work is associated with another EASA rulemaking task (RMT.0599). Anneke highlighted the need for a blend of training solutions, which include hardware, software and technology, to be adapted to support a task-specific Training Needs Analysis. This work extends beyond the scope of RMT.0196 because it encompasses all training media including Virtual Reality, Augmented Reality, distance and cloud-based learning, etc., as well as qualified FSTDs. Anneke described the Comprehensive Analysis Process for Aviation Blended Learning Environment (CAPABLE) which is the methodology proposed to select suitable training media for different training tasks and highlighted that there are similarities between this and the methodology proposed earlier in the workshop for the selection of FSTDs.
The full benefit of the FSTD workshop will only be realised once EASA and the rulemaking group for RMT.0196 have reviewed the comments and contributions of the attendees at the workshop. It was evident to those who attended that the management of EASA are keen to promote the adoption of innovative training solutions within a ‘performance-based’ regulatory environment. Under performance-based regulation for pilot training the focus for regulators will be to ensure pilots who complete training are competent, rather than to specify the particular means that should be used to develop that competence. Moving to a performance-based environment creates many challenges for both industry and regulators. A particular challenge is to ensure that a consistent standard is applied across the many EASA Member States and that the Competent Authorities are able to assess whether different training means and different devices can be used to achieve uniform training objectives.